More on sea turtles

iso-8859-1] "José A. Speroni jsperoni at
Wed Nov 21 19:32:55 EST 2001


November 20, 2001



Below is an update on an action alert that the ESC sent out
several weeks ago. It makes clear the importance of taking the
time to write into the National Marine Fisheries Service to help
them withstand the political pressures to weaken or abandon
protections for endangered species. Thanks to all those groups
who have already signed on and to those activists who have sent
comments in.

Ed Lytwak
ESC communications director

P.S. The ESC's original action alert cover letter is below for
those who want a little more background on this issue.

 >From the Endangered Species Coalition

ACTION ALERT provided by Oceana.

pressure from Rep. Billy Tauzin (R-LA) and the commercial
shrimping sector yesterday when the agency agreed to extend the
public comment period on a proposed rule to enlarge the openings
in turtle excluder devices (TEDs) to allow large endangered and
threatened sea turtles escape from shrimp trawl nets.  This
comment period extension enables NMFS to further delay taking
action to protect sea turtles from destructive fishing practices.

Thanks to all the organizations and individuals who have shown
interest in this issue over the past few weeks by sending in
their own letter to Phil Williams, NMFS' Endangered Species
Division Chief, and for signing on to our organizational sign-on
letter.  We have 40+ signatories so far!...but we will need many

For those who have not yet had a chance to review this letter, we
need your help to ensure that NMFS does not continue to cave to
special interests.  Please review our letter below which urges
NMFS to implement new requirements to enlarge TED openings
immediately without the proposed one-year delay.  We urge you to
send in your own letter to NMFS as well as to sign your
organization on to our letter.  For organizations interested
in signing on to our letter, please email me at td at ,
and include the name of your organization, your name, and title.

Deadline for sign ons is December 20, 2001.

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

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 rule:

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 MONDAY, DECEMBER 31.

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

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

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 mortality.

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.

BACKGROUND, ESC original action alert cover letter:


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 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, even though 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 and
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

Ed Lytwak
ESC communications director


José A. Speroni, DVM             E-mail: jsperoni at
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Buenos Aires                    Phone:  +54(2245)44-2350
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gratefully acknowledges the support received from:

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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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