Robert C. Hight, Director
California Dept. of Fish and Game
1416 Ninth Street, 12th Floor
Sacramento, CA 95814
FAX 916.653.7387

Re: Order to Restrict Gillnet Fisheries to Protect Sea Otters and Seabirds

Dear Mr. Hight:

The Marine Mammal Center and its 35,000 members support the order issued September 12, 2000 prohibiting the use of gill or trammel nets in water depths less than 60 fathoms.

While the order was based on information on the effect of this fishery on common murres and southern sea otters, this order also protects other marine mammals that inhabit shallow waters along the central and northern California coast and are vulnerable to human-caused mortality.

Observer statistics indicate the extensive impact of this gillnet fishery on marine mammals. For the brief period January 1, 2000 through June 30, 2000, the NOAA Fisheries Southwest Fisheries Center Monterey Bay Set Gillnet Observer Program observed 27% (44 of 164 days) of fishing trips in the Monterey Bay gillnet fishery and recorded the mortality of 24 pinnipeds, 3 cetaceans and 581 common murres. These numbers translate to three times as many when extrapolating these statistics to all of the trips within that period.

The NOAA observer program gillnet take statistics include two harbor seal pups tracked by The Marine Mammal Center. Our ongoing study of Pacific harbor seal behavior shows that newly weaned harbor seals tagged with time-depth recorders (TDR's) were diving at an average of about 6 fathoms with maximum depths at about 66 fathoms.". Therefore this order should protect this age class of harbor seals as well.

Because fishing practices and the distribution of potentially entangled species can change dramatically over time and prior data can not be used to determine whether this order is sufficiently protective against extensive gillnet entanglement, we also encourage consistent shipboard monitoring of the gillnet fisheries as well as other sound research methods to determine species’ status (including monitoring of beachcast marine mammals and sea birds, aerial surveys to determine species’ distribution, and information on temporal and geographic patterns of fishing efforts).

In summary, as a direct result of the use of gill nets, not only are threatened and endangered species affected, but also other marine mammals who live in the northern and central California nearshore marine environment. This temporary order needs to be extended and consistent monitoring undertaken to determine the impact of this order on protecting sensitive species given variances in fishing practices and distribution of sensitive species over time.

Please advise The Marine Mammal Center of further hearings or solicitation of additional comments.

Sincerely,
B.J. Griffin
Executive Director

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