|Timestamp||Enter your full name||email address||Affiliation||City, State, Zip Code||Check all that apply||Comments|
|6/2/17||Alison Johnsonfirstname.lastname@example.org||Oceana||NGO||Dear Chairwoman Bosarge:|
Oceana is writing today to provide written comment on Draft Options for Amendment 9 to the Fishery Management Plan for the Coral and Coral Reefs of the Gulf of Mexico (”Draft Options”). We are enthusiastic about the development of this amendment to identify and conserve corals, especially deep sea corals, in the Gulf of Mexico (“GoM”).
Oceana applauds Action 1 in the Draft Options paper which would incorporate deep-water octocoral species into the fishery management unit of the Fishery Management Plan for Coral and Coral Reefs of the Gulf of Mexico and the South Atlantic (“FMU”).1 Although this is a step in the right direction, we feel that a comprehensive list of all deep sea coral species potentially present in the region must be added to the FMU including all stony and black corals. Further, we commend Action 2 in the Draft Options paper which would establish management benchmarks for octocoral species. Overfishing limits (“OFL”), Annual Catch Limits (“ACL”), Annual Catch Targets (“ACT”) and overfished thresholds must be developed for every FMU. Although the above Actions are a positive stride toward deep sea coral protection, we believe that the Draft Options paper is premature and incomplete. We previously provided oral and written comments on the Scoping Document for Amendment 9 (formerly, Amendment 7).2 Scoping is a critically important part of the environmental review process under the National
Environmental Policy Act (“NEPA”).3 Oceana’s detailed and thoughtful comments which were directly relevant to the subject of the deep sea coral amendment, have been largely dismissed.In order to comply with NEPA requirements for scoping as well as NOAA policy for conservation and management of deep sea corals under the Magnuson-Stevens Fishery Management and Conservation Act, the Gulf of Mexico Fishery Management Council (“Gulf Council”) must significantly amend and improve Amendment 9. Oceana urges the Gulf Council to incorporate the following recommendations: Amendment 9 should include a mechanism and range of alternatives to conserve deep sea coral under the discretionary deep sea coral authority of Magnuson-Stevens Act Section 303(b)(2) including alternatives that are guided by NOAA’s 2010Strategic Plan for Deep- Sea Coral and Sponge Ecosystems and 2014 Agency Guidance on Deep-Sea Corals.4 Amendment 9 should include a pathway for areas to be considered and managed if and when new science becomes available.
Although the Actions described in the Draft Options paper are a positive step to protecting deep sea coral in the GoM region, Oceana recommends that the Gulf Council include more clarification and additional management authorities to protect deep sea coral in this region. Please see Oceana’s written comments on the Gulf Council website.5 Oceana looks forward to working with and providing additional input to the Gulf Council as Coral Amendment 9 moves forward. Oceana appreciates the chance to provide written comment on this very important issue.
|11/28/2016 13:12:58||Jeffery Dunbar||JDUNBAR@SWISHER.COM||Fernandina Beach, fl 32034||Private Recreational Angler||As an avid king mackerel angler who travels all over the SE to fish, from my point of view, allowing the 'unused' recreational catch to roll over to the commercial fishery is just a bad idea. This proposed amendment does nothing to help the fishery and only places more control of it into commercial hands. This amendment, if passed likely will result sometime in the future in a closed recreational fishery. This has obvious affects upon the local marinas, hotels and other businesses that support us and again does nothing to help sustain the king mackerel stocks for either recreational or commercial anglers.|
|2/24/2017 16:08:20||Felicia Lewisemail@example.com||Philadelphia||Private Recreational Angler||I urge you to establish strong protections for deep water corals and essential fish habitat. I ask you to use new scientific information to designate new HAPCs. These deep water corals are a national treasure and are essential to a sustainable, healthy gulf and healthy fish that we can all enjoy for generations.|
|2/26/2017 9:32:06||john firstname.lastname@example.org||35446||Private Recreational Angler||None of your options for "rebuilding" the trigger fishery are suitable. No matter what the flawed data says, the triggerfish population in the Gulf is healthy. How can fisheries decisions be made when the best available data is known to be corrupt? But once again we go down the same wrong path. This style of "protection" is devastating not only for the fishermen and coastal economies, but also for the health of our Gulf ecosystems. The damaging agenda of The Environmental Defense Fund needs to be removed from future fisheries decisions, because it has become obvious that the health of the Gulf environment is not their concern. Here are four options that the council should have to choose from: (1) Data providers are incompetent. (2) Data providers are corrupt. (3) Data providers are carrying out the radical agenda of the EDF. (4) All of the above.|
|2/28/2017 15:15:39||Cynthia Merkeyemail@example.com||Ocala||Other||I support any efforts to protect deep sea corals. We are losing too many of these fragile systems everyday. Restrict fishing that damages these reefs. This will.benefit fishermen in the long run.|
|2/28/2017 16:39:50||Marc Aleep||Angkorday2@Yahoo.com||Tallahassee||In recent years, scientists have discovered corals scattered in dense patches throughout the Gulf, spanning the edge of the continental shelf, primarily at depths of 165 to 660 feet and also more than 9,000 feet below the surface. |
These sensitive corals, some of which grow slowly for thousands of years, thrive in the cold, dark depths.
Yet deep-sea corals face many threats and once damaged may take centuries or longer to recover. They are susceptible to warming waters and ocean acidification, and can be harmed by oil spills, underwater pipelines, and communications cables that are dragged along the seafloor and kick up sediment, which can suffocate marine life. Similarly, boat anchors, crab traps, and some methods of deep-water fishing, such as trawling (dragging large nets along the seafloor), may also stir sediment or break corals. Fishing lines and weights deployed on the sea bottom can harm corals, too.
Current policies safeguard only some of these fragile coral hot spots by prohibiting anchoring or the use of certain types of deep-fishing gear in these areas. It’s important to protect more of these ancient jewels.
Please implement tough, long-lasting protections for corals, sea animals, and the entire ecosystem. What we do will return to us in the future.
|3/1/2017 11:53:06||Barbara Beierlfirstname.lastname@example.org||Nashua, NH 03062||NGO, Other||We must preserve the corals of the world. We are destroying our planet and must stop. It is a self-evident truth. But, selfishly, we act on our own selfish interests and motives and forget about the larger picture. Pleasure-seeking is not the way to live!|
|3/2/2017 12:10:08||Mary Ann Cernakemail@example.com||Howell, NJ 07731||Private Recreational Angler, Other||As someone who wants to be able to continuing enjoying fishing and snorkeling I want to express my strong support for actions that will protect, not destroy and jeopardize the coral reefs in the Gulf. The reefs are already under severe stress; failure to take every action possible to save them will result in this vital resource being destroyed.,|
|3/3/2017 16:52:37||Joanie Steinhausfirstname.lastname@example.org||Galveston||NGO||Comments for Deep Coral Amendment 7|
Thank you to the Gulf of Mexico Fishery Management Council, on behalf of Turtle Island Restoration Network, for giving the public an opportunity to comment on Amendment 7.
Due to the incredible diversity that coral reefs provide, organisms benefit from many things that they have to offer. They are used for feeding grounds, breeding, nursery, and commuting. Deep-sea coral life spans can range from hundreds to thousands of years, maturing at an extremely slow rate, but their vulnerability to human activities puts them at risk of a much shorter life cycle and less time to reproduce.
Deep-sea coral already resides in low temperature, low light, low oxygen water but they are not completely safe from human impacts. The many species of black coral and stony coral are spread throughout the Gulf of Mexico. With human activities such as commercial fishing increases carbon dioxide in the water, the development of coral species slows. When damaged, they may take hundreds of years to recover. There are a few things that can be done to provide these complex systems with more protection which will therefore increase biodiversity, fisheries, and even biomedical research.
By designating new Habitat Areas of Particular Concern, the deep water coral through the Gulf will have less human impact on its growth. Limiting the commercial fishing (bottom trawls, traps, fishing gear) can improve not only the maturation of coral but also increase fish and invertebrate diversity as the coral thrives. The increase in quantity and diversity will improve commercial fishing and the quality of target species used for consumption, increasing their value. This will also help to decrease overfishing.
Habitat Areas of Particular Concern fall under four categories, one of the four being habitat sensitive to human induced degradation. Any and every coral falls under this category. This does not mean every area with coral/coral reefs needs to be designated a HAPC. Redefining an HAPC will provide a better understanding when deciding regulations for protecting these habitats. Although all coral is important, some reproduce slowly and mature slowly (deep-sea coral.) Focus should be placed on coral that is impacted the most and most often by human activities.
Fifteen areas are being proposed to fall under HAPC and eight more to be HAPC’s without fishing regulations. Twenty three total areas are being considered to become HAPC’s, about 621 square miles of the Gulf of Mexico. The Gulf is over 600,000 square miles with commercial vessels often commuting hundreds of miles for days at a time so the new proposed HAPC’s of deep-sea coral should only improve fishing conditions. Lastly, reincorporating Octocorals into the Fisheries Management Unit could only benefit the ecosystem, therefore benefiting the organisms affected by them and then fisheries as well.
Turtle Island Restoration Network stands in support of designating all the proposed areas as HAPCs, and reincorporating the Octocorals into the Fisheries Management Unit.
Thank you again for your time and consideration.
|3/4/2017 15:51:47||Dan Silveremail@example.com||Los Angeles, CA 90012||NGO||The Gulf of Mexico Fishery Management Council should protect corals in at least 15 areas by restricting the use of certain kinds of fishing gear that could damage these vulnerable marine animals.|
|3/20/2017 2:34:53||Carol Gliddenfirstname.lastname@example.org||Kalamazoo, MI 49008||Other||In order to survive, the human race needs healthy oceans, which are not possible without healthy, THRIVING coral reefs.|
We must hope that it is not too late for us to rein in our shortsighted hubris, and to act AS QUICKLY AS POSSIBLE to restore the health of our oceans.
|3/27/17||Breg Southworthemail@example.com||To whom it may concern,
The Offshore Operators Committee (OOC) appreciates the opportunity to provide comments on the proposed Deep Sea Coral Amendment 7 to the Gulf of Mexico Fisheries Management Council (GOMFMC). The OOC is an offshore oil and natural gas trade association that serves as a technical advocate for companies operating in the Gulf of Mexico (GoM). Founded in 1948, the OOC has evolved into the principal technical representative regarding regulation of offshore oil and natural gas exploration, development, and producing operations. The OOC’s member companies are responsible for approximately 90% of the oil and natural gas production from the GoM. The comments below are provided on the Draft Scoping Document and Scoping Guide for the proposed Deep Sea Coral Amendment 7 and are offered without prejudice to any of our members who may offer differing or opposing views:
1. The Draft Scoping Document does not Offer an Adequate Number of Options for Consideration
The three options listed in the scoping document all lead to the conclusion that action is necessary through the creation of new habitat areas of particular concern (HAPC), redefining existing HAPC, or reincorporating deep octocorals into the fishery management unit (FMU). An adequate analysis should include additional options, including an option of taking no action, or the use of the GOMFMC’s discretionary authority to create “deep- sea coral zones” under §303(b)(2)(B) of the Magnuson-Stevens Act (MSA).
The MSA §303(b)(2)(B) gives Fishery Management Councils discretionary authority to protect deep-sea corals from fishing. Under §303(b)(2)(B), Councils may designate “deep-sea coral zones,” including protecting deep- sea corals from physical damage from fishing gear and establishing measures to limit damage to fishing gear from interactions with deep-sea corals. A “deep-sea coral zone” designation would offer additional protection, and should be considered in the Draft Scoping Document and any future proposed actions.
A sound decision or recommendation cannot be made if there has not been an evaluation of sufficient options. It appears that the use of an HAPC designation has already been selected as the final outcome. The OOC recommends that the GOMFMC expand the number of options considered under this proposal including evaluation of a “No Action” alternative and the use of “deep-sea coral zones” as a protective designation.
2. Impacts on Other GoM Regulatory Programs
The Draft Scoping Document raises questions of how the proposed options will integrate with designations managed by other federal agencies. For example, the National Marine Fisheries Service (NMFS) is currently considering alternatives for expanding the Flower Gardens Banks National Marine Sanctuary. In addition, the Bureau of Ocean Energy Management (BOEM) has requirements for the avoidance and protection of
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biologically sensitive features (water depths < 300m) and deepwater corals (water depths > 300m) that are used when leasing tracts for oil and natural gas exploration, development, and transportation activities. The GOMFMC should consider how proposed Amendment 7 integrates and/or overlaps with the proposals and existing regulations of other federal agencies. Failure to do so will create unnecessary confusion with additional, and potentially conflicting, regulatory requirements that are not well understood, nor easily implemented. The Draft Scoping Document does not outline how the proposed options for creating HAPC’s are different from, overlap with, or are made redundant by, the other federal programs in the GoM. The OOC strongly recommends that the Scoping Document clearly describes how Amendment 7 interacts with other GoM offshore federal and state regulatory requirements/guidance. As discussed earlier, Fishery Management Councils may designate “deep-sea coral zones” under the MSA. Use of a “deep-sea coral zone” designation would provide protection, and would mitigate potential conflicts and confusion with other regulations and activities in the GoM. 3. Economic Analysis is Missing from the Draft Scoping Document The GoM is an environmentally important resource, but it is also a significant economic resource to the nation. Therefore, it is critically important that proposals, such as Amendment 7, also address economic cost/benefits. The Draft Scoping Document, in its current form, does not address economic resources and the potential impact that proposed Amendment 7 may have on those resources. It is also important not to limit economic analysis to only the fishing industry. A robust and thorough analysis must include economic cost/benefit impacts to all industries that rely on access to the GoM. The OOC recommends that any future evaluation include not only environmental impacts, but economic impacts as well. The OOC is a strong advocate for balancing all concerns related to the GoM. We believe that environmental protection, safety at sea, and economic development can coexist and thrive. The GoM is proof that effective management of a national environmental resource and a significant economic and energy engine can be achieved. To maintain an effective balance of all interested parties, including the public, all potential interests must be considered in proposals such as Amendment 7. Thank you for this opportunity to provide constructive comments. If you have any questions, or would like to discuss these comments in more detail, please contact me at firstname.lastname@example.org. Sincerely Greg Southworth Associate Director Offshore Operators Committee
|3/28/2017 12:38:07||Derek Breauxemail@example.com||New Orleans, LA, 70115||NGO||March 23, 2017|
Gulf of Mexico Fishery Management Council
2203 N Lois Avenue
Tampa, Florida 33607 USA
Re: Coral Amendment 7 Scoping Document
Dear Gulf of Mexico Fisheries Management Council,
We strongly support the proposed idea of establishing 15 more HAPCs for corals, so long as these protection zones have fishing and boating regulations. Bottom trawls, dredges, bottom longlines, traps and pots, bottom-set nets, and fixed longlines are all directly damaging to corals, as well as anchors latching onto or getting dragged over corals; there needs to be regulations on these in order for protection zones to actually work.
The amendment also suggests creating 8 HAPCs for deep-sea corals that don’t need fishing regulations. Although we support the creation of the HAPCs, the lack of fishing regulations is problematic. Just because corals at far depths aren’t currently being affected by fishing gear doesn’t mean that it’s not a possibility in the future. Deep-sea corals in particular are some of the oldest and slowest growing organisms in the ocean. If damage, they will take hundreds of years to regenerate (if they regenerate at all). Thus, we should be proactive in protecting them against any possible human-induced damage.
Bottom trawls are particularly damaging corals both directly (by physical contact) and indirectly (by drowning them in sediments); the most significant destruction occurs during the initial sweep over the corals. The simplest way to save an abundance of these corals is to create more HAPCs (as suggested in the amendment) and tighten regulations for bottom trawling in these areas. Additionally, instead of completely outlawing bottom trawls, gear modifications could be implemented to minimize coral damage, such as raising the sweeps off the seafloor using disk clusters.^1
We also agree with the proposal to redefine existing HAPCs using new research technologies and information that was not available when these areas were initially designated in 2005. This will allow the Gulf Council to evaluate how effective the current regulations have been in protecting corals, and if the boundaries of the HAPCs need to be broadened or if they can be made smaller.
Lastly, we agree with the final proposal to reintroduce octocorals to the coral and coral reefs fishery management plan. These corals provide structure and habitat at depths that many other species can’t grow in, making them an important species for deep-sea coral conservation.
Intern to Fisheries Associate
1 Ryer, Clifford H. and Rose, Craig S. and Iseri, Paul J. (2010) Flatfish herding behavior in response to trawl sweeps: a comparison of diel responses to conventional sweeps and elevated sweeps. Fishery Bulletin, 108 (2), pp. 145-154.
|6/7/16||Dylan Hubbardfirstname.lastname@example.org||FL||Charter/headboat||To start, a little background on us and our company. At Hubbard’s Marina, we operate two federally permitted head boats with 50+ passengers and four charter boats all with federal permits, two of those are multi passenger USCG inspected charter vessels. Hubbard’s Marina carries around 60,000 anglers on average per year for near shore and offshore deep sea vertical line fishing. Typically fishing depths of 10-1,000 foot off the central west coast of Florida as a family owned and operated business since 1928.|
The following are our recommendations to the council regarding what has been discussed this far at the meeting.(Tab N – 4) Options Paper – Coral Amendment 9
Chapter 2.1 – Action 1 – We suggest Alternative 1 no action, as to not conflict with the current rules set forth by Florida allowing these octocorals to remain under Florida’s state management.
Chapter 2.3 – Action 3 – We suggest alternative 1 no action, not increasing the Pulley ridge south HAPC with regulations.
Chapter 2.4 – Action 4 – We suggest alternative 1 no action, do not establish any HAPCs on West Florida Shelf
Chapter 2.5 – Action 5 – we suggest alternative 1 no action, do not establish any HAPCs in the Northeastern region
Chapter 2.6 – Action 6 – We suggest alternative 1 no action, do not establish any new HAPCs in the Northwestern Gulf Region
Chapter 2.7 – Action 7 – We suggest alternative 1 no action, do not establish any new HAPCs in Southwest region
Chapter 2.8 – Action 8 – We suggest alternative 1 no action, do not establish any deep-water coral HPACs