TGCC Response to Flower Gardens Management Plan Review
Date: October 31, 2006
The Flower Garden Banks National Marine Sanctuary (FGBNMS) is presently under taking a review of its Management Plan and has had three public meetings (Scoping Meetings) seeking public input. A member of TGCC has attended each meeting (Webster, Corpus Christi & New Orleans). This document lists the items TGCC has identified as important to its dive community and listed its stance on them. While TGCC plans to respond to the FGBNMS with the basic content of this document, you also are asked to comment to the FGBNMS staff on those issues you feel are most important to your club members.
It is important that each club whose members do, or want to dive the FGBNMS in the future, take the time to make their thoughts about this marine area to the FGBNMS staff. The best opportunity is now that the management plan review process has become open to your input. The primary source of data on the concerns of the FGBNMS is the “Flower Garden Banks State of the Sanctuary Report”. This was available at each scoping meeting, and can be found on-line at http://flowergarden.noaa.gov on the first page, under the title Management Plan Review. It’s the 1.4 MB PDF file.
Public comment by E-mail to the FGBNMS must be received by November 10, 2006. You are encouraged to submit comments on behalf of yourself and your club. The E-mail address for this input is fgbmanagementplan@noaa.gov.
Statement or Concern 1. – The FGBNMS is composed of three banks – East Flower Garden Bank, West Flower Garden Bank and Stetson Bank. It also includes the High Island A389A platform in its boundaries.
TGCC Position 1. - At a minimum the FGBNMS needs to maintain all it present diving environments – Coral reef (Flower Garden Banks), Fire Coral & sponge reef (Stetson Bank) and Platform diving (Complete platform that starts at the waters surface and continues down to at least sport diving depths (0 to 130 feet).
Statement or Concern 2. – User or vested interest representatives on the FGBNMS Advisory Council include Recreational Diving, Diving Operations, Oil & Gas Production, Recreational Fishing, Commercial Fishing, Research, Education and Conservation. Non-voting seats include MMS, US Coast Guard and NOAA Fisheries.
TGCC Position 2. - TGCC would expect the FGBNMS to be a multi-user sanctuary. Divers, photographers, researchers, fish counters, sport fisherman (probably not fishing on the coral caps of the FGBNMS) should be able to use the sanctuary amicably.
Statement or Concern 3. – Increasing numbers of visitors are expected. Coral reef areas in other parts of the world have experienced degradation associated with intense visitor use.
TGCC Position 3. - FGBNMS concern over “Increasing Visitor Use” is probably over-exaggerated. However, it can easily be controlled by monitoring or registering its users and adding additional banks to enhance the sanctuary dissipates its users over a larger area. TGCC feels that Sonnier Bank and Geyer Bank should be considered as possible additions to the FGBNMS. Inclusion of these banks would be based upon the FGBNMS concept of minimal area added to the sanctuary to protect that bank’s environment. A web site, self registering system should be considered to control and monitor the vessel traffic and sanctuary use.
Statement or Concern 4. – User conflicts will intensify as numbers of users increase.
TGCC Position 4. - “User Conflicts” should not be a problem if the FGBNMS is properly working a User registering program and expanding the sanctuary to spread user access over a reasonable size area of the sanctuary.
Statement or Concern 5. – The question arises as to whether spear fishing should be allowed at the FGBNMS.
TGCC Position 5. - Spear fishing is presently not allowed in the FGBNMS. We understand that this wisdom is currently being questioned. For safety reasons and the effect that spear fishing might have on the larger fish that come within diver range, TGCC supports the position that Spear Fishing should not be allowed at the FGBNMS. TGCC feels that platforms outside the sanctuary boundary, and probably closer in to shore adequately supports the Spear Fishing portion of the diving public. TGCC doesn’t see a coral reef environment as the place to spear fish. TGCC understands that the divers who were active in the 1980’s and 1990’s in seeking sanctuary status for the Flower Garden Banks and Stetson felt that spear fishing should not be allowed. Some of those were spear fisherman. TGCC still supports that position.
Statement or Concern 6. – Areas near the current Flower Garden Banks are linked environmentally with marine life on the Gardens. Fish, turtle and mantas move around specific areas on/or adjacent to the Banks.
TGCC Position 6. - If this is the case, TGCC recommends that these additional banks (Mac Neil, Rankin and Bright) be added to the FGBNMS. Inclusion of these banks would be based upon the concept of protecting the bank and the areas linking them with the Flower Garden Banks.
Statement or Concern 7. – Wildlife interactions with divers and swimmers are of concern for the FGBNMS.
TGCC Position 7. - TGCC feels the present rules of not making contact or initiating contact adequately handles this problem. This does however depend on the adequacy of the briefings that the dive boats give and the supervision of the dive masters. Contact with researches may actually be more of a problem. Instructions covering this issue should be part of any registration program the FGBNMS establishes.
Statement or Concern 8. – Underwater sound is also perceived as a problem by the FGBNMS.
TGCC Position 8. - Normal boat sounds and divers seem to have minimal impact on the marine life. And with the mooring system, marine animals that have a problem with certain sounds can simply relocate to another area of the bank. Oil & Gas exploratory and seismic work may be another story. TGCC feels that as more data becomes available the FGBNMS may want to coordinate with the MMS in controlling such noise producing activities.
Statement or Concern 9. – Artificial light may also be having an adverse effect on marine life.
TGCC Position 9. - If this is a problem the FGBNMS needs determine the major threshold it occurs at and take steps to control it. For example, TGCC can understand where lights used for IMAX filming, or surface powered video lights could affect marine life. Weaker lights, such as diver’s lights, underwater strobes or underwater video lights are probably not a problem. No club has ever reported a problem on a dive trip with using lights on night dives. The mooring system would also help to minimize any detrimental effect from lighting because it limits divers to a very small portion of the reef and that allows the marine life that is sensitive to light to easily go to another area. Night diving at the FGBNMS is also extremely limited. It’s normally once a night, from around 8:30 till 10:30 PM – when a boat is on location and sea conditions allow, and the divers feel up to it. Believe me, the fish have our night diving behavior down pat. Maybe if night diving increased at the FGBNMS by a factor of 10,000, then this might be a problem. TGCC finds it hard to believe it’s a major problem at the FGBNMS. If a specific problem exists, one would think it could be corrected by instructions contained in its vessel registration program.
Statement or Concern 10. – It has been suggested that divers may act as coral disease vectors … by moving pathogens on diving equipment from one site to another.
TGCC Position 10. - Divers accidentally bring disease vectors from other areas could be happening. Most likely, the biggest culprit here would be researchers who study diseases, and thus go from one highly contaminated area to another. Especially if they are collecting samples. TGCC encourages its members to properly clean their gear.
Date: October 31, 2006
The Flower Garden Banks National Marine Sanctuary (FGBNMS) is presently under taking a review of its Management Plan and has had three public meetings (Scoping Meetings) seeking public input. A member of TGCC has attended each meeting (Webster, Corpus Christi & New Orleans). This document lists the items TGCC has identified as important to its dive community and listed its stance on them. While TGCC plans to respond to the FGBNMS with the basic content of this document, you also are asked to comment to the FGBNMS staff on those issues you feel are most important to your club members.
It is important that each club whose members do, or want to dive the FGBNMS in the future, take the time to make their thoughts about this marine area to the FGBNMS staff. The best opportunity is now that the management plan review process has become open to your input. The primary source of data on the concerns of the FGBNMS is the “Flower Garden Banks State of the Sanctuary Report”. This was available at each scoping meeting, and can be found on-line at http://flowergarden.noaa.gov on the first page, under the title Management Plan Review. It’s the 1.4 MB PDF file.
Public comment by E-mail to the FGBNMS must be received by November 10, 2006. You are encouraged to submit comments on behalf of yourself and your club. The E-mail address for this input is fgbmanagementplan@noaa.gov.
Statement or Concern 1. – The FGBNMS is composed of three banks – East Flower Garden Bank, West Flower Garden Bank and Stetson Bank. It also includes the High Island A389A platform in its boundaries.
TGCC Position 1. - At a minimum the FGBNMS needs to maintain all it present diving environments – Coral reef (Flower Garden Banks), Fire Coral & sponge reef (Stetson Bank) and Platform diving (Complete platform that starts at the waters surface and continues down to at least sport diving depths (0 to 130 feet).
Statement or Concern 2. – User or vested interest representatives on the FGBNMS Advisory Council include Recreational Diving, Diving Operations, Oil & Gas Production, Recreational Fishing, Commercial Fishing, Research, Education and Conservation. Non-voting seats include MMS, US Coast Guard and NOAA Fisheries.
TGCC Position 2. - TGCC would expect the FGBNMS to be a multi-user sanctuary. Divers, photographers, researchers, fish counters, sport fisherman (probably not fishing on the coral caps of the FGBNMS) should be able to use the sanctuary amicably.
Statement or Concern 3. – Increasing numbers of visitors are expected. Coral reef areas in other parts of the world have experienced degradation associated with intense visitor use.
TGCC Position 3. - FGBNMS concern over “Increasing Visitor Use” is probably over-exaggerated. However, it can easily be controlled by monitoring or registering its users and adding additional banks to enhance the sanctuary dissipates its users over a larger area. TGCC feels that Sonnier Bank and Geyer Bank should be considered as possible additions to the FGBNMS. Inclusion of these banks would be based upon the FGBNMS concept of minimal area added to the sanctuary to protect that bank’s environment. A web site, self registering system should be considered to control and monitor the vessel traffic and sanctuary use.
Statement or Concern 4. – User conflicts will intensify as numbers of users increase.
TGCC Position 4. - “User Conflicts” should not be a problem if the FGBNMS is properly working a User registering program and expanding the sanctuary to spread user access over a reasonable size area of the sanctuary.
Statement or Concern 5. – The question arises as to whether spear fishing should be allowed at the FGBNMS.
TGCC Position 5. - Spear fishing is presently not allowed in the FGBNMS. We understand that this wisdom is currently being questioned. For safety reasons and the effect that spear fishing might have on the larger fish that come within diver range, TGCC supports the position that Spear Fishing should not be allowed at the FGBNMS. TGCC feels that platforms outside the sanctuary boundary, and probably closer in to shore adequately supports the Spear Fishing portion of the diving public. TGCC doesn’t see a coral reef environment as the place to spear fish. TGCC understands that the divers who were active in the 1980’s and 1990’s in seeking sanctuary status for the Flower Garden Banks and Stetson felt that spear fishing should not be allowed. Some of those were spear fisherman. TGCC still supports that position.
Statement or Concern 6. – Areas near the current Flower Garden Banks are linked environmentally with marine life on the Gardens. Fish, turtle and mantas move around specific areas on/or adjacent to the Banks.
TGCC Position 6. - If this is the case, TGCC recommends that these additional banks (Mac Neil, Rankin and Bright) be added to the FGBNMS. Inclusion of these banks would be based upon the concept of protecting the bank and the areas linking them with the Flower Garden Banks.
Statement or Concern 7. – Wildlife interactions with divers and swimmers are of concern for the FGBNMS.
TGCC Position 7. - TGCC feels the present rules of not making contact or initiating contact adequately handles this problem. This does however depend on the adequacy of the briefings that the dive boats give and the supervision of the dive masters. Contact with researches may actually be more of a problem. Instructions covering this issue should be part of any registration program the FGBNMS establishes.
Statement or Concern 8. – Underwater sound is also perceived as a problem by the FGBNMS.
TGCC Position 8. - Normal boat sounds and divers seem to have minimal impact on the marine life. And with the mooring system, marine animals that have a problem with certain sounds can simply relocate to another area of the bank. Oil & Gas exploratory and seismic work may be another story. TGCC feels that as more data becomes available the FGBNMS may want to coordinate with the MMS in controlling such noise producing activities.
Statement or Concern 9. – Artificial light may also be having an adverse effect on marine life.
TGCC Position 9. - If this is a problem the FGBNMS needs determine the major threshold it occurs at and take steps to control it. For example, TGCC can understand where lights used for IMAX filming, or surface powered video lights could affect marine life. Weaker lights, such as diver’s lights, underwater strobes or underwater video lights are probably not a problem. No club has ever reported a problem on a dive trip with using lights on night dives. The mooring system would also help to minimize any detrimental effect from lighting because it limits divers to a very small portion of the reef and that allows the marine life that is sensitive to light to easily go to another area. Night diving at the FGBNMS is also extremely limited. It’s normally once a night, from around 8:30 till 10:30 PM – when a boat is on location and sea conditions allow, and the divers feel up to it. Believe me, the fish have our night diving behavior down pat. Maybe if night diving increased at the FGBNMS by a factor of 10,000, then this might be a problem. TGCC finds it hard to believe it’s a major problem at the FGBNMS. If a specific problem exists, one would think it could be corrected by instructions contained in its vessel registration program.
Statement or Concern 10. – It has been suggested that divers may act as coral disease vectors … by moving pathogens on diving equipment from one site to another.
TGCC Position 10. - Divers accidentally bring disease vectors from other areas could be happening. Most likely, the biggest culprit here would be researchers who study diseases, and thus go from one highly contaminated area to another. Especially if they are collecting samples. TGCC encourages its members to properly clean their gear.