CCA Louisiana and our partners from the Louisiana Charter Boat Association submitted the following comments to the Louisiana Wildlife and Fisheries Commission in response to their adoption of a Notice of Intent to create a ¼ mile buffer zone across the Louisiana coast, where industrialized menhaden reduction harvest would be restricted. We believe that ¼ mile is grossly inadequate to provide appropriate protection for our shallow surf zones and the critical marine species that are found there.
You may submit your comments by 5pm on Thursday, December 2 by emailing them to Mr. Jason Adriance at firstname.lastname@example.org
Dear Chairwoman Smitko, Commissioners and Mr. Adriance,
Following the Louisiana Wildlife and Fisheries Commission (LWFC) adoption of the Notice of Intent (NOI) to add coastal buffer zones to Gulf menhaden harvest regulations, the Coastal Conservation Association of Louisiana and the Louisiana Charter Boat Association submit the following comments and request.
At the October LWFC meeting Mr. Adriance stated before the commission that this ¼ mile buffer was proposed during the most recent legislative session and not met with an agreeable outcome. To be clear, the original author, Representative Joe Orgeron, proposed a ½ mile buffer which was supported by a strong majority of Louisiana House of Representatives members and was reflective of a spirit of compromise from the 1-mile buffer supported by a vast number of stakeholders. Those stakeholders stated such in written testimony at the House Natural Resources Committee, as well as in previous meetings of the LWFC. The ¼ mile buffer was a proposal by the menhaden industry and is not reflective of a spirit of compromise and is not supported by any other stakeholders.
In testimony, some LWFC members stated that this ¼ mile buffer would resolve user conflicts. However, they failed to provide any information on how the ¼ mile would achieve such an objective. We would like the LWFC or LDWF to provide support for how a ¼ mile will resolve user conflicts across the coast.
Additionally, the NOI states the buffer would be coastwide, then lists exceptions that extend well beyond ¼ mile from the coastline. While we appreciate the appropriate protections provided in those extended areas, we would ask the LWFC or LDWF to explain why the surf zones and shorelines in the areas of Elmers Island, Grand Isle or Grand Terre Island are more important than protecting the entire surf zone and coast of Louisiana at similar distances from shore.
But more importantly, as we have testified many times, we believe that this is a resource issue. LDWF acknowledges there are multiple fishery species of concern in Louisiana waters. Many of those species utilize Gulf menhaden as part of their life cycle, yet there have been no studies (to our knowledge) that consider the interaction among and between species or how the removal of hundreds of millions of pounds of menhaden impacts those other species. Even worse, there doesn’t appear to be any interest in understanding those interactions. A move towards ecosystem-based management is important to understanding those relationships and identifying ways to improve the management of numerous species important to commercial and recreational interests. Until that objective is achieved, we need action to protect Louisiana’s entire coastal ecosystem from this industrialized style of reduction harvest, and a ¼ mile buffer is grossly inadequate.
We believe that the comments and questions noted above warrant this issue being brought before the LWFC again prior to final enactment of any NOI creating a coastwide buffer. The sparse attendance at the October meeting and low comment volume on such an important agenda item should have been expected the month following one of the most devastating hurricanes in recent history, as most of the stakeholders were busy trying to put their lives back together. Many of those stakeholders are still facing incredible challenges with their homes, families, and businesses, and are still not able to provide comments at this time. If the LWFC seeks input from stakeholders, this agenda item should be offered again at another Commission meeting where those who feel strongly about this subject have a chance to voice their thoughts and participate in the process.
Thank you for the opportunity to provide comments on this NOI and we look forward to seeing this topic discussed at an upcoming LWFC meeting.