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United in Conservation 

 


 
Coastal Conservation Association
Comment on Draft EIS for Amendment 31
to the Gulf of Mexico Reef Fish Fishery Management Plan

Submitted Dec. 26, 2009

 
The Coastal Conservation Association, representing more than 80,000 members in state chapters along the Gulf Coast, has been concerned over the use of bottom longline gear in the commercial Gulf of Mexico Reef Fish fishery for well over a decade. 
 
Bottom longline gear is exceptionally destructive. It destroys bottom habitat and has a serious finfish bycatch problem.  Its devastating impact was most recently highlighted by the loss of as much as 800,000 pounds of red snapper discarded dead annually by the longline fleet operating off the west coast of Florida. The gear has been prohibited from use inside of 50 fathoms in the western Gulf since 1990.  
 
Recent research has revealed that bottom longline gear, along with longline gear set for sharks, is taking more than 20 times the number of sea turtles anticipated by the 2005 biological opinion required by the Endangered Species Act.  The loss of more than 900 sea turtles a year to bottom longline gear is the most egregious affront to U.S. efforts to protect endangered sea turtles since the shrimp trawl mortalities were addressed more than 20 years ago with the implementation of turtle excluder devices (TEDs). 
 
This mortality of sea turtles should be a source of serious concern to the National Marine Fisheries Service (NMFS), the Gulf Council, and all those involved in the management of this country’s marine resources.
 
None of the preferred options currently listed in the DEIS are likely to reduce turtle interactions to levels identified as acceptable by the most recent biological opinion. Additionally, recent discussions to evaluate the reintroduction of fish traps, which were banned as excessively destructive gear by the Gulf Council in 1996, as a substitute to longline gear are simply alarming. Rather than searching for ways to perpetuate a marginal commercial fishery, CCA urges the Council and the NMFS to focus on alternatives that effectively reduce destructive commercial fishing effort to the greatest extent possible.
 
Toward that end, it remains CCA’s position that bottom longline gear should be prohibited inside 50 fathoms as a permanent resolution to this problem. Such an action would achieve a 94 percent reduction from current levels of turtle takes to about 220 per three-year period.
 
There is no reasonable or rational argument for allowing the loss of endangered sea turtles to continue under the watch of these institutions charged with managing the valuable marine resources of the Gulf of Mexico.

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