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The eventual suspension of bluefin tuna fishing mentioned by the ICCAT external advisory panel in 2008
(ICCAT, 2009) does not necessarily include the listing of the stocks in CITES Appendix 1, but strict
management measures. As a matter of fact, the CITES option is not mentioned at all in the report. Furthermore,
it doesn’t take into account any social, cultural and economic aspects of the fisheries. For example, the closure of
the bluefin tuna fishery, even for only one year, will result in losing the tuna trap and the harpoon fisheries (two
historical activities having a very limited impact on the bluefin tuna stock) forever, because they are not able to
stay in stand-by even for one year only. The harpoon fishery, targeting mostly swordfish, has bluefin tuna9 as an
important component of its little economy and without this species it will be not profitable anymore. The tuna
trap fishery has a huge labour component and stopping the activity even for only one year will cause an
immediate loss of the staff and great economic damage for each factory. Both of these fisheries are “survivors”
from ancient times and a part of the Mediterranean culture. Like for the traditional Inuit activities in whale
hunting, at least historical fisheries should be excluded from all these discussions and kept alive and active
independently of any management decision.

It is useless to examine here in detail all the other points of the proposal, because many parts are more than
questionable. Discussions should go on for long times and they usually occur every year in the SCRS.

7. Conclusions

Poor knowledge of the natural history of this species by someone is rapidly becoming science in the public
domain, forgetting about centuries of scientific papers. At the same time, it is clear that the scientific information
on this species and its fishery must be seriously improved, including the necessary fishery-independent data.

The CITES is a very important Convention, highly reputed all over the world, that has been efficient and
effective in protecting many species from extinction in the wild. All the species listed in Appendix 1 have or had
serious conservation problems in terms of threat of extinction and the CITES is designed exactly for this. The
CITES offices are used to deal with those problems and the level of controls, fines and other legal provisions is
very high in most of the signatory countries.

This is the reason why the use of CITES for widely distributed species not having a real conservation problem in
terms of zoological extinction is really inappropriate and pertains to a political issue more than a conservation
problem. And no one has ever demonstrated or even reported that Atlantic bluefin tuna are threatened by
extinction. The discussion is mostly driven about a possible “stock collapse” according to the outlook of the
stock assessment, contradicted by the recent observations included in the 2008 and 2009 SCRS reports.

The 2009 bluefin fishing season had, for the very first time, a serious enforcement of the ICCAT regulation at
least among all the EC Countries (following a strong political will by the European Commission), with full
observers coverage for the EC purse seiners and the established percentage of coverage on other activities,
immediately resulting in full compliance for these fleets in terms of respecting the rules and the quota. The direct
involvement of the Community Fishery Control Agency (established in 2005) and the strict monitoring of the
VMS data made a strong contribution to demonstrate that, when there is a common political will, it is possible to
control a certain fishing activity and strictly enforce the rules.

Since some years ago, there has been clear general mismanagement problem and the bluefin tuna are overfished,
particularly in the last decade when fleets increased too much, but this is still a serious fishery management
problem and we are all lucky that it is not a conservation issue, because, again, bluefin tuna are not threatened by
extinction.

It is commonly accepted that the modelling of fisheries, and particularly for large migratory species, is not
reliable in terms of predicting the future: fishery statistics are certainly extremely useful to understand the
present by analysing the past, but data should be as reliable as possible. When a scientific committee like the
ICCAT SCRS states very clearly that the bluefin tuna data are unreliable, it is absolutely impossible to get
reliable forecast for the stocks.

The unreliable and unrealistic outlook of the stock, caused by the unreliable data, and the continuous shifting of
the forecast (and the overfishing figure) after each assessment are all clear indications that the situation is serious
but it is not extremely dramatic. The unreliability of the data and the outputs of the assessment make difficult to

9 Total bluefin tuna catches might be on the order of not more than 2 tons per year.

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