Information Needed to Adequately Comment on AQ DEIS
- Request to:
Department of Land & Natural Resources
- Law used:
State of Hawaii UIPA
- Status of this request:
- Request Successful
- Summary of Request
- Aloha Bin and Reginald,
I know you are quite busy, but the information I am requesting is essential if we are to adequately comment on the aquarium trade DEIS by the January 7 deadline.
Per the DEIS at pg. 20, just 3 - 11 of the 14 aquarium collectors seeking permits for the WHRFMA fished in the WHRFMA in 2000 - 2017, not 14 as is represented throughout the document (see, for example, Table 5-2 on pg. 94). Without knowing the actual number of collectors represented in the data sets throughout the document, it is impossible to gauge the potential impact of 14 permits.
The basis for the preferred alternative is based on catch as a % of the population by "the 14 fishers" (see section 18.104.22.168). Because an unknown number of collectors, represented as “14 fishers”, accounted for as much as 78% of the catch reported in DEIS table 5-2, for example, the public has no way of determining what future levels of catch might be under the preferred alternative. In the most generous example, assuming that 11 of the 14 collected fish in the WHRFMA, an additional 3 collectors represents a 25% increase in potential fishing pressure.
Therefore, we are requesting DLNR to provide the actual numbers of the 14 collectors represented in Tables 5-2 and 5-11 which are based on information provided by DLNR.
In addition, in order to accurately gauge the beneficial impacts of the No Action Alternative and other aspects of the DEIS, we are also requesting the total yellow tang densities per 100 sq. meters, for the 3 areas (open, FRA, MPA) in the WHRFMA, as determined by all the the surveys conducted in 2019.