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Originally Posted: August 27, 2008
Protect Loggerhead Sea Turtles
From Sea Turtle Protection Society
Public Comment ends September 8th!
In 2004, the U.S. government closed the West Coast High Seas Swordfish Fishery when it determined the by-catch of loggerhead sea turtles violated the Endangered Species Act (ESA). Now, however, the National Marine Fisheries Service (NMFS) may re-open this dangerous fishery just a few years later, gearing up for a dramatic increase in swordfish fishing with deadly consequences for imperiled sea turtles, whales, dolphins, and seabirds.
NMFS has announced it will prepare an Environmental Impact Statement (EIS) to evaluate the impacts of allowing up to 20 boats to set up to 1.5 million hooks each year on 30 to 60-mile fishing lines. At a time when NMFS should be looking for ways to further decrease the impacts of longlining on ever-shrinking populations of marine wildlife, they are posed to allow even more fishing and by-catch of sea turtles.
Help force NMFS to honestly analyze the impacts of this fishery! Add your voice to the rousing chorus of opposition!
HOW TO SUBMIT COMMENTS:
1. Click http://www.regulations.gov/fdmspublic/component/main?main=SubmitComment&o=09000064806b88c9
2. Enter your first & last name under "Submitter Information"
3. Write your own message; use information from the sample comment letter under "Public Comment or Submission."
SAMPLE COMMENT LETTER
Dear Mr. Helvey,
I am deeply concerned that National Marine Fisheries Service is considering approval of a West Coast-based High Seas Shallow-Set Longline (SSLL) Swordfish Fishery. The PFMC made the right decision in 2004 when it implemented a ban on SSLL longline fishing west of 150° W longitude in the Fisheries Management Plan. If approved, the High Seas SSLL fishery would undermine successful conservation measures protecting the critically endangered Pacific leatherback and threatened loggerhead sea turtle as well as billfish, seabirds, marine mammals, and sharks. I urge you to carefully consider the following points in the Supplemental Environmental Impact Statement (SEIS):
• Evaluate a formal alternative the maintains the fishery closure while also closing a loophole that allows WESPAC permit holders to deliver landed swordfish along the West Coast
• Explain how no mortality of Pacific Leatherback and Loggerhead species will occur in the High Seas Longline Swordfish Fishery. Scientific evidence suggests that Pacific leatherback and loggerhead sea turtle populations cannot withstand increased mortality, therefore, any expansion of shallow-set pelagic longlining effort in the Pacific would likely jeopardize the recovery of Pacific leatherback and loggerhead sea turtles.
• Explain how authorizing up to 15 loggerhead takes-3x as many permitted in the Incidental Take Statement for the West Coast Drift Gillnet fishery-is consistent with the Endangered Species Act given the loggerhead's declining population and the scientific uncertainties regarding the implications of non-lethal fishery interactions.
• Explain how the High Seas Longline Swordfish Fishery will avoid capturing marine mammal species whose incident rate of mortality or serious injury is already above the required Zero Mortality Rate Goal due to other fisheries
• Include the Western Pacific Fishery Management Council's (WESPAC) recent recommendation to increase the "turtle cap" in the Hawaii Shallow Set Longline fishery and lift set limit restrictions as part of the environmental baseline and as part of the cumulative effects analysis of the SEIS.
• Provide evidence for assumptions underpinning the purpose of the High Seas Swordfish Longline Fishery. For example, the assumptions that this fishery is likely to reduce drift gillnet fishing effort is unrealistic since gillnet boats often are not equipped to venture far enough offshore to fish in the EEZ and are not equipped with the necessary longline gear.
• Likewise, please provide evidence to support the assumption that a High Seas Swordfish Longline Fishery would (1) reduce imports and (2) is necessary to decrease a reliance on imports given other regulatory approached available through provisions of the Magnuson-Stevens Act and import restrictions contained in the Marine Mammal Protection Act.
Thank you for the careful consideration of the above-mentioned issues. I look forward to your response.
For more information, visit Sea Turtles Restoration Project http://salsa.democracyinaction.org/o/1723/t/6251/campaign.jsp?campaign_KEY=25271, SeaShepherd Longline Campaign http://www.seashepherd.org/longline/.
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