April 2018 Exempted Fishing Permits (EFP) (Responses)
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TimestampEmail AddressFirst NameLast Name
City, State, Zip Code
Check all that applyPlease select the EFP that you are providing comment.Comments
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3/28/2018 12:05:10test1@gulfcouncil.orgTest1Test1Test, FL 55555OtherGolden Crab EFPThis is a test.
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3/28/2018 12:06:35test2@gulfcouncil.orgTest 2Test 2Test, FL 11111OtherAquaculture EFPThis is test number 2.
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4/12/2018 11:52:29wjaap@tampabay.rr.comWalterJaapFlOtherGolden Crab EFP"Pursuant to the request

The proposal has several concerning elements.

The proposal area has reef structures with coral in close proximity that could be impacted by gear deployment.

The region specified in the proposal has unpredictable and fast moving oceanographic currents that add risks to the deployment and recovery of trap lines resulting in habitat impact.

Studies in this area noted some habitat impacts from fishing gear in the Pulley Ridge area. See comments and report by Reed and others for details

Earlier exploratory fishing for golden crab in the gulf during the 1980s had coral bi-catch (WC Jaap personal observation)

I request that Council and NMFS delay the offering a permit for Golden Crab exploratory fishing for 60 days to give Coral SSC and GMFMC additional time to evaluate the proposal and possibly offer modifications to minimize potential problems.
Walt Jaap, Chair Coral SSC
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4/12/2018 11:55:06jlang@riposi.netJudithLangOtherGolden Crab EFPDear Gulf Council members,
Thank you for the opportunity to comment on the application of some SA golden crab trappers to for an EFP to explore the viability of a fishery in the Gulf of Mexico along the Okeanos Ridge. This area, which is well known for its high currents, has healthy, deep-water Lophelia reef structures that are easily damaged by fishing activities. Evidence of bottom gear was recently observed here (PJ Etnoyer, NOAA pers. comm. to Coral SSC). It would be irresponsible to approve an EFP for golden crab traps in this habitat, and I urge the Council to deny this EFP application.
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4/12/2018 11:59:59jreed12@fau.eduJohnReedNorth Fort Pierce, FL 34946OtherGolden Crab EFPDear Gulf Council members,

I strongly concur with what Judy Lang states below. I have dived these sites and documented some in my previous proposal to the council to make the entire escarpment along the 500 m contour protected from bottom tending gear.
Although the Council selected a couple sites along this region as proposed HAPCs, I strongly endorse my orginal proposal to make the entire region an HAPC.
It is foolish and irresponsible to allow this gear in this habitat.
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4/12/2018 12:43:09psammarco@lumcon.eduPaul WSammarcoHouma, LA 70364OtherGolden Crab EFP
Dear folks,

I agree with the comment made by Dr. Judy Lang. My question, however, is this: Are there any alternate areas in this region which could be used for Golden Crab trawling, which will not endanger the Lophelia reefs? Or are there not sufficient data at this time to make such a judgement?

Thank you.

Best Wishes,

Paul W. Sammarco


Paul W. Sammarco, Ph.D.
Professor
Louisiana Universities Marine Consortium (LUMCON)
8124 Hwy. 56
Chauvin, LA 70344-2110

1-985-851-2876 (tel)
1-985-851-2874 (FAX)
1-985-232-6575 (Cell)
psammarco@lumcon.edu
www.lumcon.edu
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4/13/2018 11:55:29sbrooke@fsu.eduSandra BrookeCrawfordville, FL 32327OtherGolden Crab EFPI am an Associate Research Faculty at the Florida State University. I have worked on deep sea coral biology and ecology for 20 years and am a member of the Coral AP for the SAFMC, Coral SSC for the GMFMC and the working group for GMFMC Coral Amendment 9.

I am writing to express my concern regarding the recently submitted exempted fishing permit (EFP) for Golden Crab in the Gulf of Mexico, requested by Golden Crab fishers Mr. Whipple and Mr. Hau.

My concerns are as follows:
The proposed operational area (south of 25oN, 83oW-84oW) has extremely hazardous conditions. This area contains rugged steep habitat and high currents. Setting lines of traps in these conditions could easily result in inaccurate deployment causing gear loss and habitat damage, especially within the proposed depth range (1,500-2,200 ft.), which creates a narrow working area (1-6-miles wide, depending on location).

There is a danger of conflict with coral habitat. High current and rugged habitat create ideal conditions for corals and the NOAA Deep Sea Coral data portal confirms their presence in the proposed EFP region. The target depth range for the proposed EFP coincides with the optimal depth range for the reef building deep coral Lophelia pertusa, which is very abundant on the west Florida slope. One ROV dive was performed on the slope a little deeper than the proposed EFP area and dense coral assemblages (including L. pertusa) were observed.

Golden crabs are often observed near deep-sea corals, although their densities are greater on soft sediment (Reed et al 2017); however, abandoned crab traps and coral rubble have been observed near the Lophelia habitats on the west Florida slope, particularly in an area called Okeanos Ridge (25.6oN; 84.6oW). Although the fishers’ intent is to deploy on soft sediment, the chances of error are high and the consequences are damage to long lived fragile ecosystems. The red crab fishery in the Mid-Atlantic Bight also targets sediment but we have seen abandoned traps and lines wrapped around the corals

The proposed operations include a 17-day soak time and a 40-trap line (as one of the experimental options). Given the strong bottom currents there is a real possibility of the traps being pushed along the bottom during that time until they encounter rocks (and probably corals) and the traps would become entangled. Recovery would cause more damage to both benthos and traps as they are dragged across the substrate.

The EFP only mentions isopods and red crabs as bycatch, but there are other deep sea species that occur near these habitats. Black belly rosefish, conger eels, tilefish etc. could be captured as bycatch and a 17-day soak time seems sufficient to create a string of effective ghost traps.

In my opinion the proposed region is not an appropriate target area for this endeavor. The habitat, currents and presence of fragile sensitive habitats create a high risk of habitat damage and gear loss. My recommendation would be to reject the proposal. However, if the Council choses to move forward with the EFP, I would strongly recommend a review by the Coral SSC and/or AP to identify target areas and operational practices that would minimize conflicts.




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4/16/2018 10:56:15george.schmahl@noaa.govGeorgeSchmahlGalveston, TX 77551OtherGolden Crab EFPI am the superintendent of the Flower Garden Banks National Marine Sanctuary and member of the GMFMC Coral SSC. The views expressed here are my own, and do not necessarily reflect those of NOAA.

The Golden Crab fishery has very high potential to negatively impact deepwater coral communities and associated habitats. Similar fisheries have been documented to have caused significant injury to deepwater coral habitats throughout the world's oceans. Deepwater corals have extremely slow growth rates and recover very slowly from injury.

There are known deepwater coral communities, including areas containing stands of the fragile branching coral Lophelia, in the proposed fishing area. Some of these areas have been documented and presented previously to GMFMC by John Reed in 2014, with a recommendation that some of theses areas be designated as HAPC's.

Due to the high probability that the Golden Crab fishery will cause injury to important deepwater coral habitats, I recommend that the requested exempted fishing permit request be denied.

At a minimum, the proposal should be referred to the GMFMC Coral SSC for evaluation and more specific recommendations. No area in the Gulf of Mexico should be approved for a deepwater fishery with bottom tending gear until the proposed area has been mapped and ground-truthed for sensitive marine resources, especially deepwater corals.

Thank you for the opportunity to comment on this proposal.

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