"José A. Speroni"
jsperoni at enviroweb.org
Thu Nov 8 12:40:14 EST 2001
November 8, 2001
SPEAK OUT FOR STRONGER SEA TURTLE PROTECTION.
With Congress preoccupied over national security and wrapping up the
FY'02 spending bills, much of the "action" has now shifted to the less
visible but vitally important issues surrounding how protections for
imperiled species are implemented. A case in point are newly proposed
regulations to expand the size of sea turtle excluder devices (TEDs) on
shrimp trawling nets. Marine biologists say that the trawling nets are
a big reason sea turtles are endangered, because once the turtles get
caught in the nets they cannot surface and are drown before the nets
are hauled in.
About a decade ago, the National Marine Fisheries Service began
requiring shrimpers to install TEDs and they are credited with
significantly helping to reverse the decline of critically endangered
species such as Kemp's Ridley sea turtles. Unfortunately, the TEDs
currently in use are too small for large mature turtles, especially
loggerheads and leatherbacks.
The shrimping industry, however, is determined to fight these new
regulations saying that the larger TEDs would hurt their profit margins
by allowing too many shrimp to escape. Although the NMFS estimates that
shrimp loss will only be 1% to 3%, the industry has a powerful ally in
Louisiana Representative Billy Tauzin, chairman of the House Energy and
Commerce Committee. In a Nola.com, AP story 11/7, Rep. Tauzin announced
that he is "ready to fight proposals to make shrimpers install larger
turtle excluder devices in their nets." Its now up to us to give the
NMFS support it needs to resist what should be some intense political
pressure to abandon these new sea turtle protective measures. Brock is
currently out of town but if was here, I'm sure he would be urging you
to take a few minutes and speak out for the sea turtles because if we
don't who will? Thanks!
ESC communications director
From the Endangered Species Coalition
ACTION ALERT provided by Oceana
Below is the sign on and sample comment letter from Oceana regarding
increased protection of endangered and threatened sea turtles from
shrimp fishing nets. Oceana would like to encourage ESC members both to
sign on to our letter as well as to use the letter as a template to
send in their own comments to NMFS.
The letter basically supports NMFS' proposed rule to enlarge turtle
excluder device openings to help large sea turtles escape from shrimp
trawl nets. However, the letter points out several problems with the
1) The regulations propose delaying implementation of the sea turtle
protection measures for an entire year after the final rule goes into
effect-this would result in the killing of thousands of endangered and
threatened sea turtles;
2) The sea turtle protection measures for try nets (otter trawl nets
btw 12 and 16 ft. wide that shrimpers use to test for shrimp abundance
in certain areas), which often capture and
drown sea turtles, are too weak;
3) The impact of recreational shrimp trawl fisheries on sea turtles
should be assessed and measures to prevent sea turtles mortality during
recreational fishing operations, which use gear similar to try nets,
should be clarified; and
4) Increased funding of enforcement and monitoring measures should
accompany enactment of these regulations.
The DEADLINE to send comments in to the National Marine Fisheries
Service (NMFS) is FRIDAY, NOVEMBER 16th.
For organizations interested in SIGNING ON, Oceana will need to know by
Thursday, Nov. 15th C.O.B. Folks should respond directly to Tanya
Dobrzynski, Oceana Marine Ecosystems Specialist: ( td at oceana.org ) and
include their name, title, and organization.
Organizations are strongly encouraged both to sign on to our letter as
well as to use our letter as a template to send in their own comments.
We really need to make a strong showing of support because we have
learned that the Gulf Congressional delegation (i.e., Rep. Billy Tauzin
(R-LA)) plans to obstruct issuance of these regulations. In the past,
Mr. Tauzin has been responsible for numerous assaults on efforts to
protect sea turtles from shrimp fishing. We hope your organization
will help join in this fight.
Oceana; 2501 M Street, NW, Suite 300; Washington, D.C. 20037-1311
ph 202-833-3900; fax 202-833-2070; td at oceana.org .
Sign On and Sample Comment Letter:
November 7, 2001
Mr. Phil Williams;
Chief, Endangered Species Division;
Office of Protected Resources;
National Marine Fisheries Service;
1315 East-West Highway;
Silver Spring, MD 20910.
Re: Proposed rule amending regulations to protect sea turtles (66 Fed.
Dear Mr. Williams:
The undersigned organizations oppose destructive fishing practices,
which result in the incidental capture or injury of non-target
species, overfishing, or damage to ocean habitats. Therefore, we
appreciate this opportunity to comment on the National Marine
Fisheries Service's (NMFS) proposed rule to enlarge turtle excluder
device (TED) openings and impose other measures to prevent the
mortality of threatened and endangered sea turtles in the process of
shrimp fishing operations (66 Fed. Reg. 50148, October 2, 2001).
At a time when all six species of sea turtle are listed as either
endangered or threatened under the Endangered Species Act, the
proposed regulations take a crucial step toward ensuring that shrimp
fisheries do not further jeopardize the continued existence of these
magnificent marine animals. While we support enlarging TED openings
to protect large sea turtles from shrimp nets and numerous other
proposed changes to reduce sea turtle mortality, we urge NMFS to
strengthen the proposed rule and other sea turtle mortality reduction
efforts in the following key areas.
First, we oppose the proposal to delay implementation of the
regulations until one full year after publication of the final rule to
minimize adverse socioeconomic effects. It is unlawful for NMFS to
imperil endangered and threatened sea turtles to alleviate short-term
economic discomfort. Furthermore, such a delay in implementation
would result in the killing of thousands of sea turtles, and would
allow NMFS to violate its own standard that TEDs must be at least 97
percent effective to be approved. Therefore, we urge NMFS to implement
these new TED requirements as swiftly as possible.
Second, while we applaud NMFS' acknowledgement of the impacts of try
nets on sea turtles, we are concerned about the lack of enforceability
and effectiveness of the proposed tow time restrictions, and urge NMFS
to adopt more stringent measures to prevent sea turtle mortality
during the deployment of this gear. In the case of bait shrimpers,
NMFS acknowledged that "tow time restrictions are extremely difficult
to enforce and have only been authorized in limited cases where
particular fishing practices limit the length of tows." (66 Fed. Reg.
50150.) The lack of enforceability, and therefore effectiveness, of
tow time restrictions led NMFS to propose more stringent restrictions
on bait shrimpers, a measure we strongly support. We fail to
understand why tow time restrictions would be any more enforceable or
effective at reducing sea turtle mortality from shrimp fishing try
nets than they are when applied to bait shrimpers. We urge NMFS to
revisit and strengthen restrictions to prevent sea turtle mortality in
the course of try net operations.
Third, we urge NMFS to investigate the impact of recreational shrimping
on sea turtles. The Environmental Assessment (EA) accompanying the
proposed rule indicates that a recreational shrimp trawl fishery occurs
seasonally in the inside waters of the Gulf states. The EA indicates
that recreational trawl size may reach 16 feet in width and estimates
the recreational shrimp trawl fleet at 8,000 boats. At 16 feet,
recreational trawls are the same size as try nets, which the
regulations propose to regulate because they are known to capture and
kill sea turtles. Yet, it is unclear what, if any, restrictions apply
to recreational shrimpers. We urge NMFS to conduct a more rigorous
assessment of the impacts of recreational trawlers on sea turtles and
to clarify what management measures are in effect to ensure that
recreational shrimp trawling does not contribute to sea turtle
Finally, we urge NMFS to direct adequate funding toward ensuring that
shrimpers comply with these regulations and monitoring the
effectiveness of the proposed measures. If properly monitored and
enforced, these regulations have the ability to save thousands of
endangered and threatened sea turtles from being drowned in shrimp
nets. To this end, NMFS should establish a mandatory observer program
to cover a representative sample of shrimp vessels in the southeast
region. Furthermore, NMFS should allocate increased funds to establish
additional Protected Resources Enforcement Teams and to carry out other
enforcement measures to ensure compliance with the new TED regulations
in the vast shrimp fishery of the southeast region.
We thank you for your consideration of our comments. We look forward
to working with you in the future to establish safe waters for sea
turtles and to end other destructive fishing practices that result in
excessive bycatch, overfishing, or habitat degradation.
Oceana, Tanya Dobrzynski, Marine Ecosystems Specialist.
Endangered Species Coalition, Brock Evans, Executive Director.
José A. Speroni, DVM E-mail: jsperoni at enviroweb.org
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