The Southern Shrimp Alliance (SSA) welcomes the National Marine Fisheries Service’s (NMFS) decision not to implement a requirement for skimmer trawls to have TEDs installed until further research is conducted and the results fully understood. While SSA remains actively committed to sea turtle and all other bycatch conservation in the shrimp fisheries and firmly believes that all sources of sea turtle bycatch mortality must be fully accounted for and properly managed, the skimmer trawl fishery presents some unique challenges that must be resolved before any regulatory action is taken.
When initially proposed as part of a scoping process conducted by NMFS in 2011, SSA performed and submitted extensive analyses documenting the disconnect between the times and areas of shrimp fishing effort and the vast majority of reported sea turtles strandings. https://shrimpalliance.com/wp-content/uploads/2012/11/SSA-Comments-on-Turtle-TEDs-Scoping-document-8-8-11.pdf. Based on the results of its analyses, SSA strongly recommended for the agency to perform research needed to answer critical questions regarding the geographic and seasonal distribution as well as the impacts of sea turtle interactions in the skimmer trawl fishery before considering any regulatory action. At that time, there was virtually no observer data on sea turtle capture and mortality rates in the Gulf skimmer trawl fisheries. Given the lack of empirical data, SSA has argued that the agency simply could not justify the costs to the skimmer trawl fishery in terms of TED equipment and the expected loss of shrimp catch normally associated with TED use.
Should TEDs be found necessary, SSA has further advocated for the agency to work closely with skimmer trawl fishermen to design a new TED that takes into account both the small size of the gear and vessels used in the skimmer trawl fishery as well as the small size of the turtles involved which are almost exclusively Kemp’s Ridley turtles.
“SSA has and will continue to lead the shrimp industry in developing effective solutions to legitimate bycatch issues while maintaining the viability of our fishery. As always, we look forward to working closely with the Agency to resolve these questions and take the appropriate steps if necessary.”