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permit. An informal consultation may require less time; however, the agencies are not held
to a fixed time schedule. The actual processing/review time depends on the reviewer’s availability to
complete the necessary work.
7.5 Interviews with NOAA Fisheries
The permit application for the proposed project may receive considerable scrutiny as the use of
FADs are the subject of extensive discussion in the United States and around the world. The dramatic
decline of pelagic and highly migratory fish stocks in the past 30 years has caused the U.S. and other
national governments, and many of the major international conservation organizations, to focus on the
level of fishing and the means of fishing for these species, including the use of floating or drifting buoys.
These buoys, released by the dozens or hundreds at a time, allow commercial fishermen (typically net
fishermen) to more effectively catch the species they desire, but also more effectively trap “bycatch” —
fishes that are not the target species — as a result of the broad thigmotropic effect of buoys in the open
ocean. The bycatch (typically juveniles of many species) may be partially responsible for the observed
population declines. Thus placement of such devices in an area known for highly desirable commercially-
exploited fish species may result in additional fishing activity not only by recreational fishermen but also
by commercial fishermen from small businesses to very large international fishing corporations. Because
of the heightened attention that such devices are receiving, Taylor Engineering interviewed NOAA
Fisheries staff to assess their knowledge about buoys anchored in the deep ocean and to elicit their
concerns about such activity.
Interviews with members of NOAA Fisheries Regional Headquarters Habitat Conservation
Division and Sustainable Fisheries Division in St. Petersburg, Florida and Gloucester, Massachusetts
suggested to the interviewer that these offices of NOAA Fisheries has relatively little experience in
reviewing and considering the type of moored buoy project envisioned by Okaloosa County. The
concerns identified in the relatively short (1/2 hr – 1 hour) telephone interviews included the following.
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• What is the expected lifespan of the proposed buoy?
• How often will buoys be replaced?
• If a buoy is lost will the rest of the gear (anchor line and anchor) be retrieved?
• Will each new buoy be placed in the same location as the lost or replaced buoy?
• Will buoys that become separated from their moorings be tracked and picked up by the
project owner? Does the owner have the capacity for this action?
• Will the buoys be installed permanently or placed and removed seasonally?
• Will a research / monitoring program be included as part of the project?
The last question was often repeated, because any information on deep ocean fish communities
would be very valuable both in a regulatory context and as basic scientific information. County support
(not necessarily monetary) and encouragement of a fish monitoring component may become another
means of providing the regulatory agencies some level of comfort that they are meeting their charge to
manage the national resources responsibly.
In addition to the questions above, Taylor Engineering also discussed allowable commercial
fishing activities in the proposed project area (De Soto Canyon). Interestingly, the proposed project area
is closed to commercial long-lining for highly migratory species and the NMFS staff interviewed were
unaware of any migratory species purse seiners operating within the Gulf of Mexico. However, as many
commercial fishermen currently operate within this area of the Gulf with non-restricted gear and would
likely utilize the proposed buoy(s), fisheries staff did indicate concern over the potential increase in both
commercial and recreational fishing activities in the area and the potential impact to species of concern.
This is certainly not an exhaustive list of questions that the agency might consider; the staffs
interviewed indicated that they did not have much experience considering this sort of project and would
likely identify other questions as they consulted with the USACE and reviewed submitted materials.
7.6 Other Interviews
In addition to the interviews with NOAA Fisheries staff, Taylor Engineering also interviewed
Florida Fish and Wildlife Conservation Commission (FWC) staff. While FWC is primarily a State
agency, it is also federally funded and comments on fisheries projects (artificial reefs, etc.) in both State
and Federal waters. Concerns identified by FWC were very similar to those expressed by NOAA and
included the following.
• Line entanglement on the buoy or cable(s)
• Potential effects on threatened or endangered marine mammals (marine turtles, right
whales, etc.)
• Maintenance requirements and frequency
• Increased marine debris potential from “lost” buoys or components (rope, plastics, etc.)
• Navigation concerns resulting from the deployed buoy or lost buoy materials
• The structure is short-term and will likely not provide any long-term habitat/benefit for
marine life
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As previously mentioned, the majority of these concerns result from the agency’s unfamiliarity
with such structures and should be thoroughly addressed at the pre-application meeting.
Interestingly, FWC staff mentioned a research component of the project may be available for
grant funding from the Florida Fish and Wildlife Research Institute (FWRI). The FWRI research
programs focus on obtaining data and information needed by natural resource managers and stakeholders,
specifically monitoring marine resources, wildlife, and habitat (myfwc.com). Regarding the proposed
project, FWRI receives grant funding specifically for sportfish and pelagic research. As such, any
biological monitoring required by federal regulators or proposed by the applicant (or research partners)
may be partially funded by this grant.
Taylor Engineering also interviewed University of Miami (UM) academic staff to discuss
potential fisheries research projects and environmental monitoring programs that may be utilized for
regulatory monitoring compliance. Given the lack of research data on pelagic fisheries stock
enhancements, University staff proposed a fisheries monitoring program to track hatchery-produced and
tagged pelagic species (e.g., mahi-mahi, etc.) to assess the success of stock enhancement within the
region. The monitoring program would track the capture of these animals, initially released within the
proposed project area, over time to better understand the benefits and success of stock enhancements. The
buoy network could also incorporate a single or multiple buoys with environmental monitoring equipment
to track sea surface and sub-surface temperatures, chlorophyll concentrations, currents, etc. and correlate
this information with fisheries data. Notably, the Hawaii FAD system currently performs similar research.
Pelagic fish movements around the islands are tracked utilizing sonic tags and recording instruments on
the buoys. In summary, numerous fisheries monitoring projects are plausible; however, planning such
programs for such a unique project without having an idea of regulatory goals and requirements proves
difficult.
Taylor Engineering also discussed the issue of increased landing potential for bycatch and target
species resulting from the installation of the buoys with UM staff. While the buoy or buoy network will
likely attract fish and therefore increase the effectiveness of the catch, the total catch quota of commercial
fisheries will remain the same. Essentially, the fish catch efficiency will increase, but the total catch is
limited by total landing quotas set by the Federal agencies. However, because the proposed buoys will lie
within a central portion of the northern Gulf of Mexico, the proposed project may result in increased
commercial fishing pressure in the area of interest from Florida, Alabama, and Louisiana fishermen.
Additionally, issues of bycatch primarily result from the fishing methodology. Because commercial
fishing techniques (e.g., long-lines, net seining, etc.), regulated by the federal government, typically result
in increased bycatch as compared to recreational fisherman, the increased commercial-scale capture rates
and related bycatch may impact target species, target species juvenile fish stocks, and other, non-target
fish stocks.
8.0 CONCLUSIONS
Placement of a buoy system in the deeper portions of the Gulf of Mexico is technically feasible.
Available data suggest an order of magnitude $20,000 – $30,000 per buoy constructed and installed cost
and a 3 – 5 year buoy lifespan. Notably, this cost is for a simple buoy system (spar buoy and concrete or
steel anchor) modeled after the Hawaii buoy systems. Construction and installation of a larger-scale buoy
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capable of serving as a mooring structure or data platform will likely increase the cost and installation of
the structure by an order of magnitude. The County should first install a small-scale buoy or small
network (1 – 3 buoys) similar to the Hawaii system and make design modifications to future deployments
based on 1 – 2 years of monitoring data from the original system. Further, because deep-water buoy
systems are prone to failure, the County should consider the purchase of a buoy system (buoy, mooring,
and anchor) designed as a unit. This may provide the greatest amount of confidence in an optimal buoy
lifespan.
Buoy placement would most likely require a USACE individual permit, a process that could take
two or more years with no guarantee of success. Our review of regulatory guidelines and discussion with
regulatory staff revealed no apparent reasons why a buoy system could not be permitted. However, no
other similar permits are available to identify what conditions might be required for such a permit. If
approved, the permit would likely include a County commitment to an ongoing maintenance and
monitoring program and annual budget for the activity. A pre-application meeting with the USACE and
other involved agencies might help clarify some of these unknowns and help the County reach a decision
regarding the project. An environmental and/or biological (fish) monitoring program for the buoy system
could help the agencies recommend the project for approval. Such a program may potentially be funded
through existing sportfish restoration and environmental monitoring grants supported by FWC or other
state or federal agencies. Based on conversations with academic researchers, the buoys present a unique
opportunity to provide currently unavailable fisheries data. Finally, while the proposed project will likely
provide increased recreational sportfishing opportunities for Okaloosa County tourists, the buoys will
likely be utilized by all northern Gulf of Mexico fishermen (recreational and commercial) and may result
in increased commercial and recreational fishing pressure in the area of interest. The County will not be
able to regulate the use of the proposed buoy network and federal fisheries staff did indicate concern over
the potential recreational fishing pressure and commercial-scale capture rates and related bycatch that
may adversely
