GENERIC RESPONSE #2 



Several reviewers voiced the opinion that adequate protection will 

 be afforded Looe Key by the Fishery Management Council pursuant to the 

 Fishery Conservation and Management Act (FCMA) and that sanctuary desig- 

 nation would, therefore, be duplicative and unneccesary. Although 

 the FCMA provides environmental protection, its principal focus is the 

 management of selected commercial and recreational fisheries. Conservation 

 efforts under this statute are by necessity directed toward individual 

 species rather than ecosystems. Accordingly, both in general and in the 

 case of Looe Key the two programs are complementary, not duplicative. 



In accordance with the FCMA, the Regional Fishery Management 

 Councils (FMC) develop Fishery Management Plans (FMP), that are 

 implemented by the Department of Commerce. These FMP's provide for 

 protection of selected fishery resources but in general do not 

 focus on site-specific ecosystem management. FMP's do not necessarily 

 consider elements of the ecosystem which are not harvested nor do they 

 address the entire range of threats to which an area like Looe Key can 

 be subject. Title III of the Marine Protection Research and Sanctuaries 

 Act, on the other hand, authorizes conservation of special or threatened 

 ecosystems per se . Because of the differing focuses of the two statutes 

 the efforts of the FMP's and the Marine Sanctuaries Program should, 

 through cooperative efforts, complement each other. 



In particular, major differences between the Councils' joint Coral 

 and Coral Reef Resources FMP and the NOAA Looe Key marine sanctuary 

 proposal include: (a) the size of the specific area to be protected; 

 (b) the range of organisms toward which management attention is directed; 

 and (c) the emphasis on comprehensive management planning, including 

 interpretive programs and design and implementation of long-term site 

 specific research. 



First, with regard to size, the Habitat Area of Particular Concern 

 (HAPC) proposed in the draft Coral and Coral Reef Resources FMP includes 

 a one sq nm area which will allow the protection of the actual spur and 

 groove system from physical damage. However, the long-term biological 

 productivity of a system is by no means assured by such protection 

 efforts and NOAA believes that the FMP proposed protection of a 1 sq nm 

 area will not provide that assurance. Comprehensive management emphasis 

 on monitoring, visitor uses, research and public education aimed at 

 assessing the effectiveness of protective measures and health of the 

 total system will form the basis for ensuring future viability of this 

 section of the reef tract. For a discussion of the rationale for the 

 proposed sanctuary 5 sq nm boundary, please see Generic Response #3 and 

 Chapter IV (Environmental Consequences of the Proposed Action). 



It should, however, be noted that knowledgable scientists have 

 questioned the likelihood that even the sanctuary program with its emphasis 

 on the latter facets of management can effectively protect this section of 

 the reef tract (Generic Response #2). The basis for this concern is the 

 small size of the proposed sanctuary. In the marine environment adequate 



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