Comment from Robert Bosque, Robert A Bosque, Jr DMD PC

Document ID: NOAA-NOS-2009-0002-0008
Document Type: Public Submission
Agency: National Oceanic And Atmospheric Administration
Received Date: March 26 2009, at 11:04 AM Eastern Daylight Time
Date Posted: April 28 2009, at 12:00 AM Eastern Standard Time
Comment Start Date: March 4 2009, at 12:00 AM Eastern Standard Time
Comment Due Date: May 4 2009, at 11:59 PM Eastern Standard Time
Tracking Number: 80931314
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I attended the public hearing in Richmond Hill concerning the proposed spear fishing ban at Gray's Reef. I appreciate the the opportunity I had to make comments at the hearing and to comment here. I applaud NOAA's efforts in protecting our natural resources and their concern for the environment. I strongly object to the proposed ban on spear fishing at Gray's Reef. The reasons stated to close Gray's Reef by NOAA personnel were that the economic impact was negligible, that spear fishing harvests the largest and most prolific species of fish and that law enforcement cannot effectively police the reef for illegal powerhead use. I agree that the economic impact of banning spear fishing at gray's Reef would be negligible. There are very few people that spear fish in the state and federal waters off the Georgia coast due to the capriciousness of the weather, rough sea conditions for much of the year, strong currents and poor visibility. In addition many of the spear fishing areas such as the snapper banks are difficult to safely reach for many boaters and fishermen. Gray's Reef is the closest area to the Georgia coast for people to dive and spear fish. Banning spear fishing at Gray's Reef would deny these citizens the ablity to enjoy this sport. Even as the coastal population of Georgia increases, due to the difficulty of diving at Gray's reef and off shore Georgia, there would be little biological pressure on the reef from spear fishermen. The rational that spear fishing harvests the largest and most prolific species, although true in tropical clear water environs, is not applicable to the offshore waters of Georgia. Due to the poor visiblity and the migratory nature of many of the target species such as grouper and snapper it is difficult to spear large fish. I know this first hand from dozens of spear fishing trips I have made off Georgia. Finally the excuse that law enforcement cannot effectively police the ban on powerheads is ludicrous. It is an arbitrary silly excuse. Law enforcement is certainly capable of enforcing the powerhead ban,it has done so successfully in Florida. It is easy to detect powerheaded fish.There also has been no concrete evidence that powerheads are being used at Gray's. NOAA should abandon this proposal for the reasons stated but also because there is no scientific data to support any of the reasons NOAA has stated to close Gray's Reef to spear fishing. At the very least impact studies in controled areas of the reef should be implemented. In conclusion, if the worry is for the environmental protection of the reef then hook and line fishing should also be banned. Fishing tackel and fishing garbage have a far greater impact on the sea bottom than the activities of divers. Do not ban spear fishing ay Gray's Reef. Bob Bosque

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