The Onsite Survey of Looe Key indicates that local fishermen 

 depend on the 5 square nautical mile sanctuary proposal area for approxi- 

 mately one-third of their catch and the area beyond the 5 square nautical 

 mile boundary for approximately two-thirds of their catch. Therefore 

 posing restrictions on commercial fishing within a 10 sq nmi area would 

 likely cause considerable economic hardship on local long-term commercial 

 fishermen and yet not provide that great an increase in the degree of 

 protection of the reef systems. 



III. Environmental Consequences of Proposed Regulatory Alternatives 



A. Alternatives Concerning Coral Collecting. 



1 . Status Quo: Unregulated taking, of coral under all boundary 

 alternatives. 



The taking of coral in Looe Key is presently unregulated. State 

 regulations do not apply in waters beyond the territorial sea. BLM/Interior 

 regulations previously controlling the harvesting of corals are no longer 

 enforceable in the Looe Key Reef area (see above). The FMP for Coral 

 and Coral Reef Resources is still in the draft stage and the environmental 

 impact statement has not yet been completed. The final plan will not 

 likely be implemented before January, 1981 (GMFMC). 



Direct observations (Davidson, 1979) indicate that souvenir coral 

 collecting is an ongoing practice today, and probably the most serious 

 drain of the reef's coral resources. The absence of certain species in 

 areas of the reef that provide accessible, suitable habitat provides 

 circumstantial evidence of the harvesting of these attractive growth 

 forms. There is a strong probability that small finger-like growth 

 forms, such as Madracis , Porites and Oculina species and especially the 

 beautiful flower coral Eusmilia fastigiata, which occur on the Deep 

 Reef but not on the more accessible Fore Reef, have been exterminated on 

 the Fore Reef by collectors. A larger type of flower coral, Mussa angulosa , 

 is also abundant on the Deep Reef, but rather rare on the Fore Reef. It 

 does occur somewhat more frequently in the Patch Reef zone, which may 

 reflect a difference in visitor-related collecting pressure. One naturally 

 rare species, the pillar coral Dendrogyra cylindrus , has almost been 

 exterminated by collectors in the entire Florida reef tract, including 

 Looe Key. Without regulatory protection of existing coral assemblages, 

 remaining populations of these scarce corals in the more accessible 

 areas of the reef could be eliminated. Collecting pressures could then 

 shift to other, less desirable species and to those populations which 

 persist on the Deep Reef and less frequented Patch Reefs. 



A significant degree of commercial collecting does not occur here any 

 longer (Causey, personal communication, 1979). The long term consequences 

 of depletion and removal of entire species populations has been insufficiently 

 studied, but is considered by most scientists to be detrimental to the reef 

 ecosystem. The current draft of the FMP for Coral and Coral Reef Resources 

 proposes to approve for harvest by permit limited quantities of certain 



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