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Southern Shrimp Alliance Reiterates Strong Support for Coral Amendment 11 / Shrimp Amendment 12

Last week, the Southern Shrimp Alliance (SSA) submitted formal comments requesting that the National Marine Fisheries Service (NMFS) approve, in full, Amendment 11 to the Fishery Management Plan for Coral, Coral Reefs, and Live/Hardbottom Habitats of the South Atlantic (Coral FMP) and Amendment 12 to the Fishery Management Plan for the Shrimp Fishery of the South Atlantic Region (Shrimp FMP). 

If adopted, these amendments would create a shrimp fishery access area (SFAA) within a stretch of 14.1 square nautical miles on the eastern boundary of the northern extension of the Oculina Bank habitat area of particular concern (OHAPC). The amendments do not impact any other restrictions imposed on activities within the OHAPC and would only permit bottom trawling for rock shrimp by vessels that hold a valid Federal limited access permit for rock shrimp.

What is the OHAPC?

In 1984, NMFS published a final rule implementing the designation of a 92 square nautical mile portion of the Oculina Bank as the OHAPC in order to protect the unique coral reef ecosystem of Oculina varicosa (ivory tree coral). As explained by NMFS: “As part of the OHAPC designation there is a prohibition on the use of bottom trawls, bottom longlines, dredges, traps, and pots within the OHAPC to mitigate the risk of damage by fishing gear to Oculina coral.” Further, there is also a prohibition on anchoring within the OHAPC for all fishing vessels “to prevent physical impact to the coral structures.”

In 2000, the geographic coverage of the OHAPC was expanded through Amendment 4 to the Coral FMP and fourteen years after that, in 2014, the boundaries of the OHAPC were extended northward through Amendment 8 of the Coral FMP.

Why is the shrimp industry advocating for an SFAA within the OHAPC?

When the OHAPC was extended northward through Coral Amendment 8, participants in the commercial rock shrimp fishery raised concerns “that a narrow portion of the expanded OHAPC along the eastern boundary was a historically important rock shrimp fishing ground.” In response, the South Atlantic Fishery Management Council determined that these comments were raised too late to be appropriately considered with respect to the proposed expansion of the OHAPC as demarcated by Coral Amendment 8 and, moving forward, the Council would “instead [] consider the fishermen’s request of a possible OHAPC boundary adjustment through a new amendment to the Coral FMP.”

Over the next twelve years, the domestic shrimp industry has worked with the Council and NMFS to develop a reasonable, workable proposal to address the concerns of rock shrimp fishermen. In 2021, the Council recommended approval of an amendment developed to create an SFAA within the OHAPC – Coral Amendment 10 – but NMFS disapproved of Coral Amendment 10 in July 2022.

In response to any possible deficiencies with Coral Amendment 10, the Southern Shrimp Alliance has coordinated closely with the Council and NMFS to put forward a solution that “provides the best balance between historical rock shrimp fishing access and habitat protection.”

As developed, proposed Coral Amendment 11 and Shrimp Amendment 12 impact a small portion of the expansion of the geographic boundary of the OHAPC implemented through Amendment 8 to the Coral FMP in 2014 and make no changes to the OHAPC as originally demarcated or expanded through Amendment 4 to the Coral FMP in 2000. Within the sliver of the OHAPC that would hold the SFAA, no other activities are permitted, as “{a}ll other existing restrictions in the OHAPC, including the prohibitions on anchoring and the use of bottom longline, dredge, pot, or trap gear, would continue to apply in the proposed SFAA.” 

At present, there are only 100 valid Rock Shrimp (South Atlantic EEZ) Limited Access permits issued by NMFS. Only these vessels will be permitted to operate within the SFAA, allowing a return to fishing grounds that had been utilized without causing environmental damage for sixty years prior to the adoption of Coral Amendment 8. If implemented, Coral Amendment 11 and Shrimp Amendment 12, would provide substantial economic benefits to the families working within the commercial rock shrimp fishery that has been consistently operating well below optimum yield and maximum sustainable yield levels.

Who opposes these Amendments?

Comments on proposed Coral Amendment 11 and Shrimp Amendment 12 are due to NMFS by no later than midnight on November 17th and can be submitted through the online portal of Regulations.gov.

To date, the vast majority of comments received by the agency have expressed opposition to the proposed Amendments. Many of the comments submitted are forms developed by environmental and recreational fishing interest groups that broadly deride any commercial fishing operations and assert that any activity within the boundaries of the OHAPC will harm the unique coral reef ecosystem of Oculina varicosa (ivory tree coral).

The comments in opposition do not offer scientific support or any other objective evidence of their claims. Moreover, they ignore the work done by NMFS to confirm the lack of potential harm resulting from the creation of the proposed SFAA. 

Specifically, the federal agency described two recent surveys conducted by NMFS that covered the area that would encompass the proposed SFAA:

“Two new surveys are incorporated into the record in Amendments 11/12. In 2022, a NMFS Southeast Fisheries Science Center visual survey using a towed camera system covered approximately 35 kilometers over an area that included the proposed SFAA and found no evidence of live, dead, or rubble Oculina coral within the proposed SFAA. Additionally, in April 2025, the NOAA Ship Nancy Foster completed a high-resolution acoustic mapping expedition that included the area of the proposed SFAA.  This mapping data confirms that the proposed SFAA consists of low-relief sandy and muddy bottoms, lacking the high-relief mounds required to support Oculina colonies.” 

Further, NMFS also described the results of a bycatch practicability analysis conducted by the agency:

“As part of Amendments 11/12, a bycatch practicability analysis (BPA) was developed to identify bycatch and habitat impacts that were not described in Coral Amendment 10.  The BPA reviews rock shrimp fishery observer data from 2018 through 2022 and documents that bycatch in the rock shrimp fishery is primarily composed of non-managed invertebrates.  The occurrence of South Atlantic snapper-grouper species managed by the Council and NMFS is negligible in any bycatch from the rock shrimp fishery.  The BPA also addresses the risk of sedimentation on deep-water coral pinnacles.  Based on the location of the proposed SFAA which is approximately 360 to 1,580 meters away from known coral pinnacles and the oceanographic currents in the area, this buffer is expected to minimize the risk of sedimentation plumes impacts to habitat to the extent practicable.  The BPA also concludes the use of specialized gear (Turtle Excluder Devices and Bycatch Reduction Devices), which combined with the sandy and muddy-bottom location of the SFAA, effectively minimizes bycatch mortality.”

None of this appears to matter to the groups campaigning against a limited correction to the 2014 expansion of the OHAPC. Instead, commercial shrimpers are caricatured as pursuing the destruction of sensitive habitats for short-term financial gain. Although this approach may assist in growing these organizations’ membership and increasing their fundraising, the bad faith arguments presented to NMFS undermine efforts to address valid concerns regarding environmental conservation and resource use.

“Closing fishing grounds without a valid scientific basis and driving American shrimpers out of business does nothing to protect the environment when that production will simply be replaced by foreign imports that do not need to abide by the same regulatory oversight that we are subject to,” said Blake Price, Executive Director of the Southern Shrimp Alliance. “It is well past time for NMFS to approve and adopt Coral Amendment 11 and Shrimp Amendment 12.”

Read SSA’s comments to NMFS in support of Coral Amendment 11 and Shrimp Amendment 12 here: https://shrimpalliance.com/wp-content/uploads/2026/10/SSA_Coral_Amendment_11_Shrimp_Amendment_12_Comments-Oct-15-2026-1.pdf

Review NMFS’s request for comments on Coral Amendment 11 and Shrimp Amendment 12, access comments already filed with the agency, and submit your own comments on the proposed SFAA here: https://www.regulations.gov/document/NOAA-NMFS-2026-1750-0001

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