Southern Offshore Fishing
            Association

Summarizing our stance is quite simple.  The Gulf Council has adopted and sent to the NMFS a measure to immediately close the bottom longline ifishery in the Gulf of Mexico due to an unacceptable perceived level of mortality of loggerhead turtles as a result of interaction with this fishery. We don't believe that Gulf of Mexico bottom longline fishermen are responsible for anywhere near the loggerhead turtle mortality numbers that the Conservation groups who threatened the NFMS with litigation claims we are.   The Gulf Council simply acted using a flawed and incomplete set of data.  A quick look at their painfully incomplete data will show that there is little doubt that the numbers they are acting upon are far from an accurate estimation.

As Dr. Kenchington summarized in his report, which the Gulf Council chose to ignore:

• In 2005, NMFS underestimated future loggerhead takes by reef-fish longliners. In 2008, the Service overestimated takes in 2006-07. That overestimate exceeded the Incidental Take Statement based on the 2005 underestimate. The solution is a new Biological Opinion with a higher ITS. Council action is NOT required.
• The current reef-fish longline / turtle problem is a paperwork problem. It has a simple paperwork solution.
• Reef-fish longlining does NOT kill 1,000 turtles per year. The number is maybe 100, including a couple of dozen adults.
• NMFS estimate is 600 takes per year in the eastern Gulf, with no data for the west. That estimate was based on one selected dataset and is not supported by any other available data.
• Reef-fish longlining did NOT cause the decline in loggerhead nesting on Florida beaches. Only some 1% of the missing adult females could have been killed by reef-fish longlining.
• Reef-fish longlining is NOT placing loggerhead turtles in any jeopardy.
• Reef-fish longlining is responsible for about 0.05% of the loggerhead killed by all fisheries combined. Reef-fish longlining kills many fewer loggerhead than the propellers of recreational boats operating around Florida.

There is more.  The documents is linked in the left column of our front page and they are eye opening.  The Gulf Council claims to base their action on supposed requirements of the Endangered Species Act but the mandates they claim to be following simply do not exist.  They claim to be using the best science available, but they are obviously using poor data and applying it in a very suspicious manner.

But, you may ask, what about the fact that the figures show that lonliners take almost 1000 turtles per year and kill a good number of those?  The truth is, the data is so ridiculously incomplete that no sane or fairminded person could possibly accept it as a basis to even form an opinion on, let alone shut down an important segment of an entire fishery that is otherwise healthy and has been deemed to not be stressed or overfished.

The NMFS and the Conservation Groups will tell you that....

In an 18-month period from June 2006 to December 2007, longline fishing boats caught more than 900 sea turtles, 799 of which were identified as loggerheads, which are protected under the Endangered Species Act. More than 300 of the turtles were dead,

(Naples Daily News)

Or they will tell you...

In the past 18 months, about 1,000 loggerhead turtles have perished after getting hooked by bottom longline fishing in the Gulf of Mexico, according to government data supplied by Oceana, a nonprofit group focused on healthy oceans.

(Beaumont Enterprise)

This is exactly the kind of information that the well meaning but misinformed people who are submitting electronic signatures by the thousands from the "Defenders of Wildlife" and other websites are going by. 

The disparity between the two articles should be a red flag right there.  However, it is worse than that.

The truth is the figures they have came from a limited number of observed sets over an 18 month period.  For the last six months of 2006 they observed a grand total of 27 grouper sets.  In those 27 sets they observed 17 turtle interactions or "takes".  Of these, 7 came on one boat during one remarkable and anomalous trip. Of the 7 taken on that trip, the observer reports that 4 were "dead/unresponsive" when discarded, one was alive and the state of the other two was "unknown".  Unknown?  How's that?  .Quoting Dr. Kenchington again:

While there seems no reason to doubt that the observer correctly recorded what happened on that trip, it appears to have been a highly unusual, if not unique, event and in no way representative of the normal experience in reef-fish longlining. Unfortunately, with such small sample sizes as the available observer data provides, a single outlier like that seven-turtle trip can seriously perturb statistical estimates. 

In 2007, the figures indicate 178 observed sets.  According to the figures from 2006, this should have logically resulted in the taking of somewhere areound 115 turtles, if the figures from 2006 are anywhere near a statistically accurate reflection of the fishery.  The truth is, in 2007 over the course of 178 observed sets the observers observed ONE turtle being taken.  ONE.  Back to Dr. Kenchington:

That low take rate of 1 per 178 sets contrasts very strongly with the 1 per 4 sets of the previous year. Such extreme fluctuations are to be expected when monitoring a rare event, like a turtle interaction with bottom longline gear, using small sample sizes. They should, nevertheless, be a warning of the uncertainty in any estimates generated from these data.

It is painfully obvious from any scrutiny of the figures being used that the data set is far too small to come to the sort of conclusion that should be required before an entire fishery segment is summarily shut down, putting hundreds of fishermen immediately out of work and having a major adverse influence on the lives of  thousands of hard working Americans.  However, with only this data to go on, the Gulf Council has indeed voted to shut down the bottom longline fishery in the Gulf of Mexico. 

This is a fishery that primarily targets red grouper, a species that is healthy, not "overfished" or "currently undergoing overfishing" according to the NMFS's own data,  What that means is that without some issue such as this artificially manufactured one, the Gulf Council has no grounds for closing this fishery and should be promoting it as one of the few healthy fisheries in the U.S.A. right now.

If the Gulf Council is not set on an agenda to close down this fishery at any cost and in the face of all evidence that it is simply not needed...then what exactly is their point?  It is obviously not saving the turtles.