GENERIC RESPONSE #4 



The preferred alternative (Alternative b) proposed in the DEIS 

 would have required that NOAA establish a permitting system and develop 

 criteria specifying under what conditions commercial collecting permits 

 would be granted. It would also have required the undertaking of extensive 

 monitoring of fish stocks to determine when adequate population levels 

 of target species existed and at what point and to what degree taking 

 would be appropriate. A number of reviewers opposed collection on ecological 

 or philosophical grounds. In response to concerns and arguments presented 

 in the DEIS review, NOAA has reconsidered the preferred alternative for 

 tropical specimen collecting and now proposes instead to prohibit collection 

 of such specimens except by permit for scientific and educational purposes. 



Several reviewers felt that administration and enforcement of a permit 

 system for effective regulation of commercial tropical specimen collecting 

 could not be developed. Subsequent consultations with existing commercial 

 permitting authorities emphasized the difficulties involved. It is not 

 likely that permittees could be monitored to assure that their actions would 

 be consistent with the conditions of the permit without an elaborate sur- 

 veillance system with specified check points for ingress and egress at the 

 sanctuary boundaries. As an example, it would be virtually impossible to 

 determine whether a permittee took only 100 neon gobies over the period of 

 two months. 



Establishment of a limited permitting system to allow taking of tropical 

 specimens for research and scientific purposes could be accomplished without 

 administrative and enforcement difficulties. It is anticipated that most 

 research within the sanctuary would be non-consumptive (i.e., observational) 

 and would not require a permit. Limiting the taking of specimens to research 

 and educational purposes only will result in significantly fewer permits than 

 would a system which included commercial taking. Furthermore, the Office of 

 Coastal Zone Management has already developed an administrative process 

 currently employed for the Key Largo Marine Sanctuary that is designed to 

 handle limited permits for these purposes. 



There are many available easily accessible and suitable areas for 

 tropical specimen collectors to capture tropical fish and invertebrates in 

 south Florida; including shallow inshore areas, inshore coral heads, 

 mid-channel reefs (in the middle of Hawk's Channel), and the entire outer reef. 

 Prohibiting collecting in the Looe Key area would cause limited economic 

 loss to present commercial collectors. When the accessibility of alternative 

 sites, the small size of the proposed sanctuary, and the minimal economic 

 impact, however, are weighed against the administrative cost and burden of 

 establishing a commercial permitting system, commercial permitting does 

 not appear justifiable. From a conservation standpoint, a sanctuary prohibition 

 would protect and enhance the tropical specimen populations at Looe Key, 

 help prevent the depletion of ecologically important species, add to the 

 aesthetics of the sanctuary, and help maintain and enhance the long term 



E-7 



