THE TERRAPIN INSTITUTE
June 14, 2006
Mr.
Michael Slattery, Assistant Secretary
Maryland
Department of Natural Resources
Tawes State Office Building
Annapolis, Maryland 21401
TRANSMITTED
VIA FAX – Three Pages
Dear
Mr. Slattery:
Thank you for the opportunity to meet with you on May 31, 2006 and review the draft regulatory proposal for
diamondback terrapin conservation as required by HB 980. The legislation signed by the Governor this
year amends Natural Resources article 4-903 and requires that “THE REGULATIONS ADOPTED UNDER
THIS SECTION SHALL BE CONSISTENT WITH THE RECOMMENDATIONS OF THE MARYLAND
DIAMONDBACK TERRAPIN TASK FORCE ISSUED IN 2001.” The
five measures presented to us on May 31, 2006 are not consistent with the Task Force recommendations and do not
comply with the law as amended.
During our meeting on March 24, 2006, you assured Ed Wilson and me that the revised
terrapin regulations would result in a practical moratorium. We anticipated a comprehensive approach to
terrapin conservation which carefully considers each of the 2001 Task Force
recommendations. Given the delay in
implementing the Task Force recommendations as well as increased harvests, by-catch
mortalities, and habitat loss, we respectfully request the Department to defer
the opening of the commercial terrapin harvest season indefinitely. Until the Department has the population
estimates, science or evidence to validate a sustainable commercial harvest, it
is inappropriate to open the terrapin season as scheduled on August 1, 2006.
Increased by-catch mortality caused by fyke nets and commercial crab pots is contributing to the
decline in terrapin populations. Enclosed
are photographs of fyke nets retrieved April 24, 2006 from the Eastern Neck area and reported to the DNR police.
Eight nets were retrieved in this
incident; each contained an estimated 200 dead terrapins. None of the proposed terrapin conservation regulations
address by-catch mortality nor are there any long-range plans from the
Administration or the commercial fishing industry to mitigate species and
habitat decline.
Conservative and cautious protection of the terrapin
resource will have collateral benefits for the Administration as well as the
commercial fishing industry. The
Terrapin Institute is prepared to draft a comprehensive management package
which is consistent with the recommendations of the 2001 Task Force. To appease the commercial fishing industry
and off-set any economic impact, the Terrapin Institute is prepared to
compensate harvesters and dealers. Thank
you for your consideration.
Sincerely,
Marguerite Whilden
cc: The
Honorable Virginia Clagett, et al
P. O. Box 51, Edgewater, MD 21037 410 370 9171 www.terrapininstitute.org