In the most recent version of the Florida Keys National Marine Sanctuary Restoration Blueprint NOAA has proposed restricting shark feeding EXCEPT IN THE CASE OF FEEDING SHARKS AND OTHER FISH TO HARVEST (KILL) THEM. This proposed rule is specifically aimed at preventing divers from feeding sharks to observe and photograph them. In other words, according to this proposed rule, feeding sharks and other fish in order to trick them into being caught on a hook and line AND KILLED is acceptable, while using natural food to allow divers to observe or photograph sharks in the water is not allowed.
This proposed regulation from NOAA (see page 36) is clearly an attempt to extend regulations over shark dive operators, preventing them from conducting their business in federal waters. Florida already prohibits shark (fish) feeding in state waters, having enacted this regulation in the early 2000’s without the scientific basis for doing so. NOAA claims that shark feeding creates “human safety issues,” but science from the world’s most renowned shark experts disagree with this assertion, and DEMA believes this assertion is being promulgated by the Florida Fish and Wildlife Commission without supporting data. When DEMA requested that data from FWC several years ago none was provided.
DEMA adamantly opposes this proposed rule and suggests that everyone in the diving community submit comments in opposition to this proposed regulation. Data and recommendations indicate that a far better approach is for shark dive operators to utilize guidelines for marine life interactions to prevent harm to people and sharks. The actual marine interactive guidelines themselves have long been available from the Global Interactive Marine Experiences Council (GIMEC) and Project AWARE and the World Wildlife Fund. U.S. Federal regulation of this activity is both intrusive and unnecessary.
DEMA has also cited peer-reviewed data that corroborate the economic value of “provisional ecotourism,” feeding natural foods to sharks, giving the opportunity for thousands of divers traveling to the Florida Keys each year to actively and safely engage in observing sharks and gaining a better understanding of these creatures. Research by independent and credible scientists indicates that provisioning ecotourism does NOT create an increased risk for non-divers and swimmers not directly engaged in provisioning ecotourism activities. By prohibiting shark feeding in federal waters for essentially all purposes except harvesting (killing) them, these proposed federal prohibitions will have a detrimental impact on sharks and dive consumers and will adversely impact businesses that serve the recreational diving industry, including dive operators, vessels used to transport customers to diving locations, hotels, restaurants, and transportation services.
DEMA has met with researchers and dive operators to begin the process of building support and is preparing comments in opposition to the proposed rule, but much is left to be done. Industry support is needed to prevent this unnecessary and destructive rule from being enacted. DEMA needs you to submit comments in writing or in person to NOAA to oppose this proposed regulation. Unless the diving community speaks up on this issue, this regulation will be put in place in federal waters in the Florida Keys and will soon find its way to ALL federal waters, effectively ending all shark diving in the United States.
Public Comment Opportunities
Tuesday, Sept. 20 at 6 p.m. in Key Largo, Florida at Coral Shores High School Wednesday, Sept. 21 at 6 p.m in Marathon, Florida at Marathon High School Thursday, Sept. 22 at 6 p.m in Key West, Florida at Key West High School Tuesday, Oct. 18 at 9 a.m. in Marathon, Florida at the Sanctuary Advisory Council MeetingElectronic Comments
Submit all electronic public comments through the Federal eRulemaking Portal, www.regulations.gov. The docket number is NOAA-NOS-2019-0094-1012. Click the “Comment Now!” icon, complete the required fields, and enter or attach your comments.
Mail Comments
Restoration Blueprint Public Comment
Florida Keys National Marine Sanctuary
33 East Quay Road
Key West, FL 33040
Additional information, including how to register for these meetings is available on the Restoration Blueprint website: www.floridakeys.noaa.gov/blueprint.