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|2/22/2017 17:35:38||Cassie Burdyshaw|
Thank you to the Gulf of Mexico Fishery Management Council for holding this public hearing and providing the opportunity to comment. These comments are on behalf of Turtle Island Restoration Network’s over 80,000 active supporters, including over 9,000 active supporters in the Gulf of Mexico.
For Action 2, Turtle Island supports the preferred Alternative 2 because the aggregate Optimum Yield that would be established would have the least negative effects on the physical and biological environments. Alternative 2 would keep effort levels at or below levels that are consistent with those established by the biological opinion of the shrimp fishery that is intended to minimize sea turtle bycatch. This alternative would help prevent expansion of the shrimp fishery.
Turtle Island does not support Alternative 1, which would create an Optimum Yield set at a level that would be more than the current number of active permits in the shrimp fishery is capable of producing. This alternative could allow for more effort in the future.
Turtle Island does not support increased effort by the shrimp industry because the shrimp industry causes a high level of harm to sea turtles and the ocean ecosystem.
For Action 3, Turtle Island prefers Alternative 4, which involves the lowest threshold out of the proposed alternatives. A lower threshold and fewer permits could result in a lower number of vessels actively fishing, which would decrease bycatch and impacts on the environment.
Table 2.3.3. indicates the relative risk of exceeding the sea turtle effort threshold for each alternative under Action 3. Turtle Island supports only alternatives that have a low relative risk of exceeding the sea turtle effort threshold. Only actions 3, 4 and 5b have a low relative risk of exceeding the sea turtle effort threshold.
Turtle Island does not support the preferred Alternative 2, which involves a moderate relative risk of exceeding the sea turtle effort threshold. The shrimp industry is already extremely damaging to sea turtle populations and the ocean ecosystem. Turtle Island will not support actions that potentially lead to increased bycatch such as Alternative 2.
For Action 4, Turtle Island supports Alternative 1, which would result in no new management measures if and when the threshold is met. The other alternatives under Action 4 provide the shrimp industry with a means of maintaining participation at the level determined by Action 3. Because of the high level of harm to sea turtles and the ocean ecosystem caused by the shrimp industry, Turtle Island supports lowering the fishing effort of this industry.
Under alternative 2, the creation of a permit pool may have negative effects on the physical and biological environment because it may allow for an increase in effort in the fishery at some point in the future. Similarly, Alternatives 3 and 4 could also lead to future increased shrimp fishing effort. Alternatives 3 and 4 convene a review panel and, if the threshold is reached, the Council may respond with new management measures or re-evaluate the threshold. One action the review panel could recommend is the creation of a permit pool, which again would allow for an increase in fishing effort.
The public hearing draft for Shrimp Amendment 17B notes that it is unlikely that the effects of potential increased effort from the creation of a permit pool would be more than the effects already experienced from fishing activities of the shrimp fishery. However, the effects already experienced from fishing activities of the shrimp fishery are highly harmful to sea turtles and the ocean ecosystem. Turtle Island strives to reduce this harm instead of only striving to make sure this harm does not become even worse.
For Action 5, Turtle Island expresses its concern with Alternatives 2 and 3, which would allow vessels possessing shrimp but without a valid federal shrimp permit to transit through federal waters. Transit through federal waters with shrimping gear and shrimp on board currently requires a federal commercial Gulf shrimp moratorium permit.
The public hearing draft for Shrimp Amendment 17B notes that Alternatives 2 and 3 would have positive effects on the environment by lowering emissions of greenhouse gases from vessels. Both alternatives would allow for a shorter transit from fishing grounds to port by not requiring vessels to travel farther distances to avoid federal waters. Turtle Island supports the reduction of greenhouse gases.
However, Turtle Island is concerned that the ability to transit through federal waters with shrimp on board, without a permit, might create an incentive for unintended, increased fishing effort in federal waters. Observer rates are extremely low for this industry and enforcement of current regulations is lacking. Bad actors may exist who would use the ability to transit through federal waters with shrimp and without a permit as an opportunity to conduct fishing effort in federal waters without a permit.