I am writing to urge you not to delay important protections for critically endangered North Atlantic right whales and other endangered whales. Current regulations would require all East Coast pot, trap and gillnet fishermen to convert their groundlines from floating line to sinking line by October 5, 2008, to reduce entanglements of whales. The proposed rule would delay the effective date of this requirement for pot and trap fishermen for 6 more months, leaving whales vulnerable to entanglement in pot and trap gear during the delay. The proposed rule is unnecessarily broad in scope. It would relax requirements for the use of sinking line that are already in place and being used by many New England lobster fishermen. Lobster fishermen have been required to convert portions of their gear to sinking lines to comply with seasonal and dynamic area management requirements since 2002, and the state of Massachusetts implemented sinking line requirements for all lobster gear used in state waters as of January 1, 2007. More importantly, the proposed rule would leave no protections in place for whales during the delay, except for the requirement to use weak links. The National Marine Fisheries Service (NMFS) has determined that weak links alone are inadequate to prevent entanglements of whales. Other gear restrictions that have been in place under seasonal and dynamic area management measures will be completely phased out by October 5, 2008. Three out of four known right whales show signs of entanglement, and 9 new entanglement cases have already been documented this year, including 5 entangled right whales. NMFS is required by law to ensure that sufficient protections are in place to prevent human caused activities from jeopardizing whales. In the case of right whales, NMFS has determined that the loss of even a single whale could hasten the demise of the entire species. It has been more than 10 years since fishing gear was determined to be a major source of death for right whales, humpback whales, and fin whales. The requirement to convert portions of pot, trap, and gillnet gear to sinking line is an important step in reducing the probability that more whales will become entangled. Delaying the implementation of much needed protections without having alternative protections in place is irresponsible and leaves endangered whales unprotected from harm. Thank you for considering these comments in opposition of the proposed rule. Please think beyond this time and this place to where your children and grand- children will live. Sincerely, Brigid Geroux
Taking of Marine Mammals Incidental to Commercial Fishing Operations; Atlantic Large Whale Take Reduction Plan Regulations
Activity
Defenders of Wildlife filed 2 comments on this docket between Jul 9, 2008 and Jun 26, 2014. 29 other organizations filed here. The comment window closed 6595d ago.
What Defenders of Wildlife filed (2)
Filed on regulations.gov — full text not in the inline record.
Abstract
The National Marine Fisheries Service (NMFS) proposes to amend the regulations implementing the Atlantic Large Whale Take Reduction Plan (ALWTRP), to delay the effective date of one of the broad-based gear modifications and remove one of the gear-related definitions required in the recent amendment to the ALWTRP (72 FR 57104, October 1, 2007; 73 FR 19171, April 9, 2008). Specifically, NMFS is proposing to delay the October 5, 2008, broad-based sinking groundline requirement for trap/pot fishermen in the Atlantic for an additional six months to April 5, 2009. Additionally, the proposed rule would delete the “neutrally buoyant line” term from the regulations to avoid any potential confusion with the requirements and assist enforcement efforts.
View on regulations.gov →Co-filers (29)
See everyone who commented →- Defenders of WildlifeTHIS ORG2 filings · confidence 97%
- Ocean Alliancetrade assoc.2 filings · confidence 85%
- Beta Beta Beta Biological Honor Societytrade assoc.1 filing · confidence 85%
- Conservation Science Institutetrade assoc.1 filing · confidence 85%
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- Environmental Marine Systemsunverified attribution1 filing · confidence 70%
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- Madison Teachers Inc.unverified attribution1 filing · confidence 70%
- Maine Lobstermen's Associationtrade assoc.1 filing · confidence 85%
- Massachusetts Humane Society Animal Sheltertrade assoc.1 filing · confidence 85%
- Mississippi State Universityunverified attribution1 filing · confidence 70%
- National Coral Reef Institutetrade assoc.1 filing · confidence 85%
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- the Atlantic Offshore Lobstermen's Association on AW84trade assoc.1 filing · confidence 85%
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- the Island Institute on AW84trade assoc.1 filing · confidence 85%
- The Whale and Dolphin Conservation Society on AW84trade assoc.1 filing · confidence 85%
- Union of Concerned Scientistsunverified attribution1 filing · confidence 70%
- University of Delawareunverified attribution1 filing · confidence 70%
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- University of New Mexicounverified attribution1 filing · confidence 70%