Sea Turtles

"José A. Speroni" jsperoni at
Thu Nov 8 12:40:14 EST 2001


   November 8, 2001



   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, 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!

   Ed Lytwak
   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 ) 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.

   Tanya Dobrzynski

   Oceana; 2501 M Street, NW, Suite 300; Washington, D.C. 20037-1311
   ph 202-833-3900; fax 202-833-2070; td at .

   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.
   Reg. 50148).

   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
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gratefully acknowledges the support received from:

Birgit Schmettkamp Verlag (Germany),  Mantella Publishing (UK)
Research Information Systems, Inc. (USA),  Reptilia (Spain)
Clark Development Company, Inc. (USA),  FTP Software, Inc. (USA)
Key Tronic Corporation (USA),  Colorado Memory Systems, Inc. (USA)
"Many feel that Gary Kildall, the inventor, should have received the 
dollars and kudos that went to Bill Gates, the merchandiser." CS, Nov. 1994

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