Every Fish Counts. How the Gulf Council and the National Marine Fisheries Service Ignore Bycatch to Allow Overfishing

Every Fish Counts How the Gulf Council and the National Marine Fisheries Service Ignore Bycatch to Allow Overfishing

Every Fish Counts: How the Gulf Council and The National Marine Fisheries Service Ignore Bycatch to Allow Overfishing Copyright July 2005, Gulf Restoration Network The Gulf Restoration Network is a diverse network of individuals and local, regional, and national groups committed to uniting and empowering people to protect and restore the resources of the Gulf of Mexico region for future generations. Founded in 1994, we have members in each of the five Gulf states. The GRN Fisheries Program is working on the following issues of concern: overfishing, essential fish habitat, full implementation of the Sustainable Fisheries Act, and public education on the importance of sustainable fisheries management. The GRN would like to thank the Regional Marine Conservation Project, the Elizabeth Ordway Dunn Foundation, and the Curtis and Edith Munson Foundation for making this work possible. On the web at http://healthygulf.org.

Every Fish Counts How the Gulf Council and the National Marine Fisheries Service Ignore Bycatch to Allow Overfishing Gulf Restoration Network, July 2005 Table of Contents: Executive Summary...2 Background on Bycatch...3 Major Bycatch Issues in the Gulf...5 General factors...5 Specific factors...7 Recommendations...9 Bycatch recommendations...9 Council reform recommendations...9 Appendix: Selected Fishing Gear Types Used in the Gulf...10 Fish traps...10 Gill nets...10 Longlines...10 Trawls...11 Hook and Line...12 Rod and reel...12 Handlines...12 Bandit gear...12 Spearguns...12 1

Executive Summary Our Fisheries The Gulf of Mexico is a national treasure and a home to productive fisheries. But our fisheries are in trouble; they ve been overfished and mismanaged. The Problem Bycatch is any wildlife caught accidentally when other species are targeted. Identifying and then reducing bycatch is critical to obtain sustainable management of fisheries. Past efforts to reduce bycatch in the Gulf of Mexico have focused primarily on sea turtle conservation but also on juvenile red snapper bycatch. Both sea turtles and juvenile red snapper are caught and often killed in shrimp trawls; thus, bycatch reduction efforts have mainly targeted shrimp trawling. These efforts led to the development of Turtle Excluder Devices (TEDs), which were highly contentious among fisheries managers and shrimp trawlers. Similarly, Bycatch Reduction Devices (BRDs), which can help exclude red snapper from shrimp trawl nets, have been required in the western Gulf since 1998 and are now required throughout federal Gulf waters. Unfortunately, they have not worked as well as originally hoped. Today, the Gulf of Mexico Fishery Management Council (Gulf Council) continues to focus primarily on the bycatch associated with shrimping, ignoring the fact that bycatch exists in all fisheries, both commercial and recreational. Equally problematic is the Gulf Council s unwillingness to include bycatch estimates when compiling annual catch levels for reef fish. If bycatch is excluded from the total mortality estimates for a fishery, the decisions made for its management will be based on an underestimate. As a result, overfishing will continue and fish stocks will not be rebuilt. Unloading and distributing a catch of yellowtail snapper. Source: NOAA The Solution The Gulf Council and the National Marine Fisheries Service (NMFS) must act immediately to develop comprehensive bycatch estimates and implement effective bycatch minimization strategies. Given the Gulf Council s history of neglecting this urgent management need, a reform of the Council system must occur. 2

Every Fish Counts How the Gulf Council and the National Marine Fisheries Service Ignore Bycatch to Allow Overfishing The Resource The Gulf of Mexico is a national treasure. Its coral reefs, miles of seagrasses, and substantial wetlands half of the United States total wetland resources make the Gulf region legendary for productive fisheries. Commercial and recreational fishing are significant economic engines, generating nearly $687 million in commercial landings and $5.6 billion in recreational expenditures per year. From shrimp trawlers to recreational charter boats, fishing is a way of life in the Gulf. But our fisheries are in trouble; they ve been overfished and mismanaged. A number of reef fish species have been found to be overfished, including vermilion snapper, red grouper, and our hallmark red snapper. Estimates put red snapper population levels at just 7 percent of historic levels, with no effective plan to rebuild the population. Background Why Bycatch Is Important Bycatch is any wildlife caught accidentally when other species are targeted. In most instances, bycatch is thrown back into the water, dead or dying. The Food and Agricultural Organization of the United Nations estimates that 25 percent of the world s fish catch some 44 billion pounds of fish and thousands of other ocean animals such as marine mammals and seabirds are annually captured as bycatch. The level of bycatch can significantly affect the health of a fish species. The Law: A National Standard for Bycatch In 1976 the Fishery Conservation and Management Act (FCMA) created eight regional fishery management councils, one of which was the Gulf Council, to advise NMFS on management issues in local fisheries. The Gulf Council consists of members nominated by the governors of Gulf states, as well as representatives of state and federal agencies involved with fisheries. The Gulf Council monitors and makes recommendations for management of fisheries in the federal waters of the Gulf (3 miles from the coast of Louisiana, Mississippi, and Alabama; about 9 miles from the coast of Texas and Florida). A diver checks the performance of a fish trap used to catch reef fish. Source: NOAA. GULF GEAR: Fish Traps Traps used to capture certain fin fish, such as snapper and grouper, can also unnecessarily kill other fish. A 1995 study conducted in the Gulf of Mexico by the National Marine Fisheries Service demonstrated that about 34 percent of the fish caught in fish traps are kept. The remaining 66 percent are bycatch. The use of fish traps will be prohibited in the Gulf of Mexico after February 7, 2007. 3

In 1996 Congress reauthorized the FCMA by passing the Sustainable Fisheries Act (SFA), which addresses bycatch by requiring the Gulf Council to meet the following goals: Establish a standardized reporting method to assess the amount and type of bycatch in managed fisheries Adopt conservation measures that minimize bycatch through avoidance Minimize the mortality of bycatch that cannot be avoided Status of Implementation The Sustainable Fisheries Act was passed nine years ago, but wasteful bycatch is not a thing of the past. The many regional councils and NMFS have not systematically considered how to accurately report bycatch or how to reduce bycatch. NMFS has rejected several bycatch plans submitted for approval by the Gulf Council. In February 2002, the environmental organization Oceana petitioned NMFS to meet the requirements of the law. In response to a potential lawsuit, NMFS released a National Bycatch Strategy. However, to this date, no standardized bycatch reporting methodology or reduction plan is in place in the Gulf of Mexico. Table 1. Fishery Management Plans, written by the Gulf Council and approved by NMFS, are opportunities to obtain comprehensive bycatch estimates and implement avoidance strategies. Overfished? Overfishing? Amendment (Amd.) in progress? Bycatch plan? Target completion Red snapper Yes Yes Yes (Amd. 26: Individual Fishing Quotas [IFQs]). Yes (New Regulatory Amd.) No Jan 2006 Red grouper No Yes Yes (New Regulatory Amd.) No Unknown Vermilion snapper Yes Yes No No Greater Amberjack Yes No No No Gag grouper No No No No Nassau grouper Yes Yes Yes (Amd. 18b) No Unknown Goliath grouper Yes No Yes (Amd. 18b) No Unknown Shrimp No No Yes (Amd. 13 & Amd. 14) Yes Amd. 13: May 2005 Amd. 14: March 2006 Aquaculture N/A N/A Yes N/A Jan 2006 Reef fish collective N/A N/A Yes (Amd. 18a) Yes (Amd. 18b) Yes (Amd. 28: IFQs) N/A Sept 2005 Unknown (Projected) 2007 4

Major Bycatch Issues in the Gulf of Mexico Overview The current status of reef fish in the Gulf of Mexico clearly indicates the failure of our fisheries management to address bycatch concerns. According to the NMFS Report to Congress for 2003 (released in May 2004), many popular Gulf fish, such as red snapper, vermilion snapper, and red grouper, are overfished and/or experiencing overfishing. (See table 1, page 4.) A primary factor in this significant depletion is the enormous amount of bycatch that is unaccounted for in annual total catch data. Anecdotal information indicates that bycatch from directed and related fisheries more than doubles the directed allowable catch of some reef species. In short, because its management decisions are focused on landings instead of total mortality (landings plus bycatch), the Gulf Council has failed to meet the conservation goals of the SFA. A number of significant issues related to the Gulf of Mexico need to be addressed in order to produce an effective bycatch management and minimization plan. To date, the Gulf Council and NMFS have not dealt with such matters adequately. Major Existing General Factors: 1. Data Collection The SFA requires that a standardized bycatch reporting methodology be established for all federally managed fisheries. Though there have been several discussions about reporting bycatch in the Gulf of Mexico, as well as an attempt to designate existing programs as the appropriate methodology, no plan has been established. Further, the ability to track fishing efforts and catch in both commercial and recreational sectors has been limited. These are important pieces of information for determining the ecological impacts of fishing and managing fisheries effectively. While commercial trip ticket programs (detailed statements of catch generated by fishermen) exist for some species, other fisheries, such as shrimp, have no such requirement. Information for the recreational sector is very limited. There is no permit requirement in federal waters. State license requirements vary, and there are many exemptions to them (for an example, see Florida s exemptions at http://marinefisheries.org/license.htm#rec). As a result, a reliable count of the recreational fishing universe is nearly impossible. The one program in effect, the Marine Recreational Fisheries Statistics Survey (MRFSS), uses random dockside interviews and phone surveys to construct estimates of catch and bycatch. Only a comprehensive data collection system will provide reliable information that can be used to develop more effective management. Gill nets on a reel. Source: NOAA. GULF GEAR: Gill Nets Gill nets are also often called entangling nets because they are developed to snag fish, capturing them. Gill nets are usually set on the ocean bottom, using lead weights to hold them upright, like a wall. While the nets are intended to target certain species, anything swimming in the path of a gill net will probably be ensnared. Therefore, these nets are associated with a high bycatch rate that is often dependant on the time they are allowed to remain in the water. 5

2. Observers Although the SFA and the Marine Mammal Protection Act (MMPA) give NMFS the authority to place observers on commercial fishing vessels, NFMS has thus far failed to implement a comprehensive program in the Gulf. These two Acts require the government to collect data on activities that affect marine resources. A consistent, unbiased method of data collection, such as observers, is necessary to help document impacts to the ecology, particularly on fish and other wildlife resources. Observer programs are designed to provide knowledgeable, impartial reporting. Observers monitor and record catch data about commercial fishing activity from U.S. vessels while the vessels are at sea, thus providing real-time information. The data supplements research and aids in the management of U.S. marine resources. Observers collect information on a number of matters, including the species composition of the catch, the weights of the fish, interactions with protected species, and bycatch. Observers provide critical data for effective fish management. By allowing for unbiased, outside confirmation of catch, bycatch, and effort, using observers on as many vessels as possible would support any information already collected through trip tickets, permits, and log books. Such a program should not be limited to traditional commercial vessels, but should be instituted for charter and headboat vessels as well, since they also interact with a great number of natural resources and are essentially commercial vessels (that is, they are devoted to the commerce of recreation, since the owners collect funds for fishing). The use of observer programs has been sparse in the Gulf of Mexico. However, a rule to institute observer coverage has been approved within the most recent red snapper rebuilding plan. The concept is also included in Shrimp Management Plan Amendment 13, which now awaits final approval by NMFS. 3. Bycatch Quotas Although many U.S. fisheries implement bycatch quotas and use them to manage species successfully, neither the Gulf Council nor NMFS has chosen to use this tool to manage Gulf fisheries. Each of the following methods could be used to establish quotas: 1. Determine vulnerable species and acceptable levels of take, using the best available scientific information. Quotas of these species can then be set based on either a) the entire fishery, which would close when the quota for any of the species is met, or b) individual vessels, which would be barred from fishing after reaching quotas. 2. Determine an overall amount of bycatch that reflects an acceptable and sustainable level of take, using the best available knowledge of average bycatch composition. This level can be set as either a) a fishery-wide quota, the reaching of which would close the fishery, or b) an individual vessel quota, the reaching of which would disqualify a particular vessel from fishing. Bycatch quotas provide the ability to manage fisheries using real-time data rather than estimations. Better GULF GEAR: Longlines Longlines are fishing gear composed of lengthy horizontal cables, of up to about 5 miles, with smaller offshoot lines (also called leaders) that hang vertically from the main. Some longline gear is designed to touch the bottom in order to catch bottomdwelling species like grouper. Other longlines, known as pelagic longlines, remain suspended in the water column to catch pelagic species such as sharks. Preparing longlines. Source: NOAA 6

information about the amount and composition of bycatch in a particular fishery will help in the management of bycatch in other fisheries. 4. Seasonal or Fixed Closed Areas There are many unprotected locations in the Gulf that are believed to be spawning sites and important habitat areas for many of the species caught as bycatch. Similar to hunting-free areas in wildlife refuges that have been used effectively to rebuild waterfowl populations, increasing the size of existing protected areas or closing other important areas that are currently fished could significantly reduce bycatch, protect important habitats, and help rebuild the populations of various species. Heavily fished sites with high amounts of bycatch should be prime candidates for area closures. (Pinpointing such sites requires significant data collection. See factor #1 above.) 5. Comprehensive (Ecosystem-Based) Management Both the Gulf Council and NMFS have recognized publicly that a species-by-species approach to fish management is less successful than management based on entire ecosystem connections and functions. A target catch in one fishery is bycatch in another. Predator-prey relationships and endangered species are also important. Ignoring ecological interactions causes unnecessary mortality and waste in a specific fishery as well as often generating unexpected problems in other fisheries. A comprehensive approach to fisheries management specifically, for bycatch minimization is necessary. 6. Funding Obtaining reasonable funding through the federal budget has always been a challenge for fisheries management, but it has become more difficult in recent years. NMFS invokes budget deficiencies regularly as justification for why the Agency has been unable to produce stock assessments, require observers, provide vessel monitoring systems and so on. NMFS s financial arguments do hold some credence, since observer programs will need to be implemented to obtain truly credible bycatch data, and such programs are expensive. Many fishermen in the Gulf are unable and unwilling to assume the financial burden for observers. However, there are a number of alternative sources of funding that might be used for these important programs, such as money from the Saltonstall-Kennedy Fund, (federal funding for research and development projects to benefit the U.S. fishing industry) federal lending programs, and tax incentives. The Gulf Council and NMFS should explore such options rather than make excuses for not moving forward. Major Existing Specific Factors: 1. Shrimp Trawl Bycatch Initial steps to reduce shrimp trawl bycatch, aimed in particular at the exclusion of juvenile red snapper, were implemented with 1998 s western Gulf bycatch reduction device requirement (BRD). In 2004, that requirement was extended to the rest of the Gulf region to reduce red snapper and some other finfish bycatch. Unfortunately, BRDs have not been as successful as once hoped. In fact, recent projections show BRD effectiveness at 11.7%, far below the original projections. The only requirement besides using BRDs is using Turtle Excluder Devices (TEDs) to help reduce the number of turtles killed in shrimp trawls. In 2002, after many years of discussion and debate, NMFS approved a permit requirement for most shrimp vessels fishing in the federal waters of the Gulf. This permit can be revoked as a penalty for violations of fishery regulations, removing offenders from the fleet. While all these measures have moved towards better regulation of the shrimp fishery, general bycatch has remained largely unaddressed, though new amendments are in progress that could help with the problem. 2. Red and Vermilion Snapper Bycatch Red and vermilion snapper are both economically significant species. Vermilion is often sold as red snapper, due to their similarities. They are often found and caught together. However, the seasons for these fish are not consistent, so each is often a bycatch of the other. Plans to rebuild both species were recently developed by the Gulf Council. The vermilion plan (Amendment 23) was submitted to NMFS for approval in February 2005 and finalized in June 2005. The red snapper plan was completed by the Council in May 2004 and finalized by NMFS in June 2005. Though decisions about each probably affect each other, these species were not discussed in context with each other in either plan. Since a single-species management approach to fisheries regulation has for the most part failed in the past, the Gulf Council and NMFS should try new collective methods. At a minimum, discussions and plans for red 7

and vermilion snapper should include each other, as well as take into account interactions with other Gulf of Mexico fisheries such as shrimp. 3. Goliath and Nassau Grouper Bycatch Catch of Nassau grouper was prohibited in the U.S. Atlantic in 1990, the U.S. Caribbean in 1991, and the Gulf of Mexico in 1997. A moratorium on killing Goliath groupers was implemented in the Atlantic in 1990, the Gulf of Mexico in 1990, and the federal U.S. Caribbean in 1993. These regulations remain effective today for both species (though protection for Goliath grouper is challenged regularly by commercial and recreational representatives). Both Goliath and Nassau groupers were also formally acknowledged as candidate species under the United States Endangered Species Act (ESA) in 1991. Despite these protections, these fish are still caught as bycatch in other fisheries. Further, because the prohibition for Goliath is no take, not no catch, recently a catch-and-release fishery for Goliath has developed and is widely advertised as good sportfishing. Of course some Goliath die in the process of being caught and eventually released. The complete closure of a directed fishery is arguably the most stringent regulatory measure available to help a troubled species, but in many cases, if the protected species is caught with other unprotected species, bycatch is still a problem that goes unaddressed. No other protections to deal with fish caught and possibly killed as bycatch have been enacted for Goliath or Nassau, though both species can be found in locations with other sought-after, legal-to-catch reef fish, and are caught as bycatch during the pursuit of legal fish. 4. Gag, Black, and Red Grouper Bycatch (the lone limited success story) Weeks Bay National Estuarine Reserve. Commercial shrimpers separating shrimp from bycatch. Source: NOAA. GULF GEAR: Trawls Trawls have been described as the most widespread form of disturbance to marine systems that are below depths affected by storms. The degree to which bottom trawls disturb various habitats is influenced by the design of the gear, the weight of various parts of the gear, and the amount of time the trawl is deployed. Mobile gear, such as trawls and dredges, is the most widely studied gear type as well as the type thought most detrimental to the benthic environment. Gag, black and red grouper are often found and caught as a collective unit (fishermen may target all three on any given trip) and should be managed as such for optimal effectiveness. Until June 2004, red, black, and gag groupers were mainly managed individually. Major controversies raged over establishing protected areas to help protect spawning sites of gag, black, and red grouper. Various limitations on red grouper have also caused significant controversies. Ultimately, threats of lawsuits from industry trumped good science, and regulations established after many years of debates and delays were reduced from their original forms. However, in 2004, in an effort to limit bycatch of red grouper in other reef fisheries (grouper especially), new regulations were instituted that prevent fishing on the entire shallow water grouper complex once the quota for red grouper is reached to prevent bycatch of this species. This is a significant step in the right direction for reef fish management. 8

Recommendations Bycatch Recommendations Revisions to bycatch regulations must include the following guidelines: 1. All managed fisheries must develop bycatch estimates. A sense of how many fish are being caught as bycatch is critical. These estimates can be produced using different programs: onboard observers, electronic vessel monitoring systems (VMS), charter boat log books and electronic log books, and port surveys. NMFS must fully fund and implement the most effective of these programs to provide a complete picture. 2. Bycatch estimates must take into consideration species that are thrown overboard because they are too small or are out of season (regulatory discards), as well as those that are thrown overboard because they have no value (economic discards). Whatever the reason fish are thrown overboard, the end result is the same a significant number die. Complete bycatch estimates must include both types of discards. 3. Bycatch estimates must include all commercial and recreational types of fishing gear. The historic focus on shrimp trawl bycatch has excluded most other gear types, unfairly shifting the regulatory burden to only one aspect of the problem. Since all gear types produce some levels of bycatch, NMFS needs bycatch estimates for all of them. Council-Reform Recommendations Bycatch in the fisheries of the Gulf of Mexico is a longstanding concern. The continuing failure of the Gulf Council to incorporate the mandates set out in the SFA points to the need for wider reform if this body is ever to manage the Gulf s fisheries in a responsible, cautious manner. The Gulf Council must be changed to reflect the following recommendations. 1. Strengthen the use of science in fisheries management to ensure that the best possible information forms the basis for management decisions. 2. Broaden the representation on fishery management councils to include various interested persons as well as recreational and commercial fishing representatives. This will improve the decision-making process. 3. Significantly reduce financial conflicts of interest in the fishery-management process to ensure that shortterm economic considerations do not compromise the conservation needs of a fishery. 4. Provide training for all new council members to give them a better understanding and the tools necessary to make informed management decisions. 5. Establish a national cooperative research program to increase our knowledge of the health of our fish populations and minimize the impact of fishing on ocean life. 4. All efforts to estimate bycatch must be published in peer-reviewed academic journals. The scientific process of peer review will allow for the most accurate and up-to-date information for managing our fisheries in the Gulf of Mexico. 5. Once established, bycatch estimates for managed fisheries must be fully incorporated into management decisions, including calculations of yearly total allowable catches. A primary reason that many of the popular reef fish in the Gulf of Mexico are depleted is that bycatch is unaccounted for in annual allowable catch totals. Reef fish. Source: NOAA. 9

Appendix: Expanded Discussion of Selected Fishing Gear Types Used in the Gulf of Mexico A variety of fishing gear types are employed in the Gulf of Mexico to target certain fish. Some are very selective, catching mainly the intended target species, while others have higher rates of bycatch associated with them, based on their configuration and function. The gears following are those most often associated with the potential for significant bycatch: Fish Traps: Traps used to capture certain fin fish, such as snapper and grouper, can also unnecessarily kill other fish. A 1995 study conducted in the Gulf of Mexico by NMFS demonstrated that about 34 percent of the fish caught in fish traps are kept. The remaining 66 percent are bycatch. One problem associated with fin-fish traps is that they can capture too many juvenile fish. This decreases the number of fish that ultimately contribute to the population. Recognizing the threats fish traps pose to sustainable reef-fish fisheries, the South Atlantic Fishery Management Council (with approval from NMFS) and the Florida Fish and Wildlife Conservation Commission (formerly the Florida Marine Fisheries Commission) have both banned the use of wire-mesh fish traps since at least the early 1990 s. In 1997, the Gulf Council set in motion a ten-year phase-out plan for fish traps. This plan calls for no reduction in the number of fish traps being used in the Gulf until 2007, when they are to be completely banned from further use within the Council s jurisdiction: the Exclusive Economic Zone, which is from where state waters end (3 miles off Alabama, Mississippi, and Louisiana; 9 miles off western Florida and Texas) to 200 miles offshore. Gill Nets: Gill nets are also often called entangling nets because they are developed to snag fish, capturing them. Gill nets are usually set on the ocean bottom, using lead weights to hold them upright, like a wall. While the nets are intended to target certain species, anything swimming in the path of a gill net will probably be ensnared. Therefore, these nets are associated with a high bycatch that is often dependant on the time they are allowed to remain in the water. Longer periods of time unattended increase the likelihood that any unwanted catch will die. Also, if the nets are lost or abandoned, tides can sweep them across the ocean floor, harming bottom habitat and collecting an enormous amount of ocean wildlife, which is known as ghost fishing. Some bottom disturbance is probable during both setting and retrieving. A constitutional prohibition on most entangling nets in Florida state waters has existed since 1995. Gill nets are less popular in the Gulf of Mexico than other gears, though there remains a gill net fishery for Florida pompano in federal Gulf waters. However, because Florida pompano run in schools, gill nets for targeting these fish are usually set to catch the school and then are immediately pulled, minimizing potential bycatch. Some signs of progress: A diver, riding a shrimp trawl, watches a turtle go free. Source: NOAA. Longlines: Longlines are fishing gear composed of lengthy horizontal cables, of up to about 5 miles, with smaller offshoot lines (also called leaders) that hang vertically from the main. Some longline gear is designed to touch the bottom in order to catch bottom-dwelling species like grouper. Other longlines, known as pelagic longlines, remain suspended in the water column to catch pelagic species such as sharks. 10

Bottom longlines are used in the Gulf of Mexico to target a number of species, red grouper in particular. This gear uses an average of 1,000 baited hooks in a variety of sizes, ranging from 13 to 14 Ott. They are generally spaced so that there are 250 to 300 hooks per mile of cable, depending on the size of the boat. Longlines have recently come under scrutiny due to several suspected adverse effects on the environment and marine life, such as damage to habitat, large catches, and too much bycatch and its associated mortality. The first problem involves line retrieval. To reel in a longline, the heavy cable is most often pulled across the bottom for a long time. The cable does not often penetrate the bottom more than 50mm, but it can adversely affect vertical habitats such as corals. As longlines scrape the bottom before lifting, hooks drag on corals, sponges, and other gorgonians that are commonly found in snapper and grouper habitat. The line can also dislodge other small organisms and invertebrates and make them susceptible to predators. The second problem involves the efficiency of the catch. Longlines are often dubbed the most efficient gear available for catching certain fin-fish species. However, efficiency here refers to the volume of catch, rather than its composition. A number of fish and other marine wildlife caught on longlines are not targeted species. Due to the great length of the cable and the number of hooks, longlines are not as selective in their catch as some other gears. Any fish or other creature can be attracted by the bait on the leaders. It takes time to set, soak and retrieve the extensive gear, so unwanted catch, like undersized/juvenile fish or unintended species, are often dying or dead by the time they are noticed and removed from the hooks. Longlines can extract hundreds of fish from the water in a single setting and retrieval. various parts of the gear, and the amount of time the trawl is deployed. Mobile gear such as trawls and dredges are the most widely studied gear type as well as the gear type thought most detrimental to the benthic environment. Gulf of Mexico shrimp trawls come into contact with a wide variety of marine resources. These trawls drag across the ocean bottom, scooping up any wildlife in their paths. Because this gear is so indiscriminate in its catch, it has a very high potential for bycatch. On average, shrimp trawling in the Gulf of Mexico nets about one pound of shrimp for every four pounds of other ocean wildlife. The Gulf Council and NMFS have worked with the shrimp industry over the years to help reduce bycatch. In the mid 1990 s, Gulf of Mexico shrimpers were required to place turtle excluder devices (TEDs) in nets to help reduce the number of sea turtles caught and killed. Since 1998, bycatch reduction devices (BRDs) were required in the western Gulf, from the Mexico border to Cape San Blas, Florida. In 2004 this requirement was extended to all federal Gulf waters. Unfortunately, some of these methods have not worked as well as once expected, and there is still significant bycatch from shrimp trawls. New attempts to reduce bycatch from shrimp trawls without greatly hurting the shrimp industry are in progress. The third problem involves a lack of specificity. Longlines have an enormous potential to entangle wildlife. Several species of protected sea turtles and whales have been killed by longlines. Ultimately, the various concerns indicate the potential for significant harm to marine wildlife by longline gear. Trawls: Trawls have been described as the most widespread form of disturbance to marine systems that are below depths affected by storms. The degree to which bottom trawls disturb various habitats is influenced by the design of the gear, the weight of Florida longliners fish for shark, snapper, and grouper. Source: NOAA. 11

The following gear types tend to be associated with lower levels of bycatch, because they are constantly attended and/or provide better opportunities for release and rehabilitation of incidental catch. Hook and Line: A number of gear-types can actually fall into the classification of hook and line, including bandit, hand line, and rod and reel. These methods can be and are used by both recreational and commercial sectors in various estuarine, nearshore, and marine habitats to catch a variety of species. They can also be used over reef habitats or trolled for pelagic species. Primarily in the Gulf of Mexico, they are used in hardbottom habitats. In terms of environmental impacts, discarded line (monofilament) is possibly more harmful than the actual fishing. Discarded line can become entangled on coral, fish, seabirds, marine mammals, and turtles, often proving fatal. All gears in the hook and line category have similar configurations and functions, though with distinct differences. Rod and Reel: Probably the most recognized fishing-gear type, a rod and reel is a pole with line running its length and a hook on the end. The line is lowered into the water using a spool-like device and remains near or on the bottom (often held there by a weight or sinker ). Usually such gear is constantly attended, though sometimes fishing poles are placed in slots on boats and dragged through the water or trolled to catch fish. However, someone ultimately needs to reel in the catch. Because rods and reels catch one fish at a time and are powered only by human strength, they provide a good opportunity for any unwanted catch to be immediately released. Therefore, while there is still some bycatch since those fishing with rods and reels cannot see their targets and may catch unintended species, there is usually less mortality as a result of the bycatch. Hand Line: Hand lines are similar to rods and reels, but they do not involve fishing poles. The gear is simply a line with a hook on the end that the user sets out and pulls in manually. Most hand lines are retrieved at minimal speeds, preventing the catch from being greatly harmed as it rises through the water. This is also somewhat species dependent, since some fish are less sensitive than others. As with a rod and reel, there is usually a good opportunity for any bycatch to be immediately released. Bandit gear: Bandit gear is similar to rods and reels with two notable modifications: 1) the line is reeled in electronically, and 2) more than one hook is often present on each line. Anywhere from 2 to 8 hooks are standard per bandit rig. Because bandit gear uses electric power to retrieve the catch more quickly from the water and because it catches more than one fish at a time, it might have higher bycatch and mortality rates than a rod and reel or hand line. However, most bandit rigs are constantly attended, so unwanted catch still has a good chance to be properly rehabilitated and returned to the water with limited harm. Spearguns: Spearguns are hand-held devices used while scuba diving or free diving without an artificial air source. A speargun is a gun-like mechanism that shoots a pointed spear at the intended target. Because individuals are able to see their targets, spearfishing involves minimal bycatch. Essentially, only errors in species identification or size judgment result in an unintended catch, but any accidental spearing usually results in the death of the bycatch. 12

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