Ken Kramer, Executive Director of Lone Star Sierra, invited members of Coastal Bend Sierra who have been active in the Sea Turtle Science and Recovery Program at the Padre Island National Seashore to write comments on the Bi-National Kemp’Ridley Recovery Plan. (This first revision since 2002 may be accessed at: 




Re: RIN 0648-XS00 Bi-National Kemp’s Ridley Sea Turtle Recovery Plan June 30, 2010


Sierra Club Comments on the Bi-National Kemp’s Ridley Sea Turtle Recovery Plan

The Sierra Club submits the following comments on the Bi-National Kemp’s Ridley Sea Turtle Recovery Plan with the caveat that the BP oil catastrophe in the Gulf of Mexico may well have incalculably negative impacts on the continued recovery of the world’s most critically endangered sea turtle.

The Sierra Club has long been a proponent of the Kemp’s Ridley Sea Turtle Recovery Program at the Padre Island National Seashore (PAIS), helping to protect against a variety of threats to the Kemp’s ridleys, including shrimping trawler and oil drilling activities (2000; 2002) and proposed military use of the beach (2001). Sierra also participated in helping achieve the annual Texas Parks and Wildlife Department (TPWD) five-mile closure in the Gulf (2000), which is credited with having resulted in a significant reduction in strandings during nesting season. Most recently, the Sierra Club has supported the lowering of the speed limit on Padre Island during nesting season (2010).

Thanks to the efforts of hundreds of volunteers, and especially to the over-thirty-year work and dedication of Dr. Donna Shaver, Chief of Sea Turtle Science and Recovery at PAIS, the Kemp’s ridley has begun to experience an exponential increase in its U.S. nesting population. At least that was true before the BP disaster. Whether it is true in the future cannot be assessed here. This unprecedented oil catastrophe occurred just as nesting season 2010 began.

The BP disaster’s potential effect on the Kemp’s ridley recovery program is especially grave because the female turtles range widely up and down in the waters of the Gulf Coast, instinctively returning to beaches there to lay their eggs—especially on Padre Island, their primary nesting ground in the United States. This migratory pattern places many of the female turtles directly in the path of the worst environmental disaster in our country’s history as they come to nest and return north thereafter. Currently, two of the five Kemp’s ridleys which were equipped with satellite tracking devices this 2010 season are already known to be heading directly into the oil spill.

Ironically, the historical purpose of the recovery program at PAIS has been the protection of the Kemp’s ridley in case of natural or manmade destruction of their primary nesting site in Rancho Nuevo, Mexico. The Recovery Plan does not address contingencies in case of a catastrophe in U.S. waters of the dimension and magnitude currently ravaging the Gulf of Mexico.


While aware that the potential new reality of the Gulf disaster described above may necessarily alter some strategies proposed in the Recovery Plan, the Sierra Club comments as follows on several areas of special concern.


The Sierra Club recognizes that South Texas--specifically North and South Padre Island--is the legitimate historical nesting ground of the Kemp’s ridley sea turtle in the United States and would adamantly oppose any effort to move the effective Kemp’s Ridley Recovery Program, which has been located at PAIS since 1978, to another geographic area along the Texas Coast. Furthermore, the Sierra Club believes that the South Texas nesting population is significant and should be more highly recognized in the Recovery Plan.

The Sierra Club agrees that closures are essential to ensure passage of female turtles across the Gulf with lessened danger from the nets of shrimp trawlers and other trawling vessels. Further, we agree that critical for protection of nesting female turtles in Gulf waters is the increased enforcement of shrimpers’ use of Turtle Excluder Devices (TED) at all times and the expansion of their use to include all trawl fisheries of concern.

The Sierra Club believes that the continued practice of relocation of clutches to assure egg protection from human and animal pillaging or predation is essential. This vital practice of relocation includes movement of eggs from nests found in Texas to the incubation facility at PAIS and to incubation corrals on Padre Island.

The Sierra Club recognizes that vehicular traffic is a potential hazard not only to nesting sea turtles but to people recreating on the beach, and concurs with the recent mandating of a lowered speed limit on Padre Island. Additionally, we believe such a rule is especially prudent during nesting season since nesting turtles are difficult to see and their tracks nearly invisible to the untrained eye even if a vehicle is moving at fifteen-miles-an-hour. Such a speed limit brings PAIS into accord with other national parks in the U.S. and is consistent with previous Sierra Club positions on the deleterious effects of vehicular beach traffic.

The Sierra Club concurs that national and state regulations currently in force to protect Kemp’s ridley sea turtles are inadequate and underfunded. Especially in light of the BP catastrophe in the Gulf of Mexico, we urge these governmental entities to reevaluate and strengthen these regulations. Enforcement of proper TED use by vessels operating off the Texas Coast will now be even more vital than before the BP disaster. As the turtles traverse the Gulf waters along the Texas and Mexico Coast, they will be at increased risk because vessels which will be prohibited from fishing northern and eastern Gulf waters will now join Texas and Mexico fleets in southern and western Gulf waters.

The Sierra Club stands ready to assist in whatever way possible to help mitigate the environmental tragedy still raging in the Gulf. Meanwhile, we offer these comments on the Bi-National Kemp’s Ridley Sea Turtle Recovery Plan.




Ken Kramer Mina Williams Venice Scheurich

Director Vice-Chair Conservation Chair and Secretary

Lone Star Chapter Sierra Club Coastal Bend Sierra Club Coastal Bend Sierra Club


The Sierra Club, at both state and local levels, has long supported the Kemp’s Ridley Sea Turtle Recovery Program at PAIS. The position statement below is Coastal Bend Sierra’s response to the recent PAIS Environmental Assessment (EA) soliciting opinions regarding speed limits on Padre Island, especially during sea turtle nesting season.






P.O. BOX 3512



August 18, 2010

Joe Escoto


Attn: Beach Vehicle EA

Padre Island National Seashore

P.O. Box 181300

Corpus Christi, TX 78480-1300

Dear Superintendent Escoto:

In response to the Beach Vehicle Environmental Assessment, The Coastal Bend Sierra Club supports Alternative Two: A seasonal 15 mph speed limit for the entire beach beginning at the occurrence of the first Kemp’s ridley turtle nest observed within the park or April 15—whichever is earlier—through the end of the Kemp’s ridley nesting season. Following is an explanation of our decision to choose Alternative Two.

The Sierra Club, at both the state and local levels, has long supported the sea turtle restoration program on Padre Island National Seashore. On July 27, 2009, Lone Star Sierra drafted a statement which representatives from Coastal Bend Sierra, who participated in the mediation at the Park regarding vehicular speed limits for the sixty-mile-length of Padre Island, submitted to Dr. Chris Moore, mediator. In that statement, are the following excerpts: "The Lone Star Chapter of the Sierra Club has historically supported the sea turtle restoration program at Padre Island National Seashore and shall continue to do so. . . .We believe that protecting the biodiversity of Padre Island will ultimately benefit both the wildlife and all recreational users" (emphasis added).

We have been persuaded by your arguments of 2-22-10 (cited below) explaining why you set speed limitsd limits limits this past d limits during this past nesting season which were generally compatible with Alternative Two:

the Park’s desire to protect Kemp’s ridley sea turtles during the nesting season without denying access to vehicles driving on the beach;

protection of people at peak visitation periods, and when most staff and volunteers are working on the beach;

application of a 15 mile per hour speed limit that matched the one for Texas state beaches, in Mexico during turtle nesting periods and required of turtle patrollers in Texas;

uniformity with that required of oil and gas operators in the Park; and

conformity with that set for most national seashores where beach driving is allowed

                    during the sea turtle nesting period.


Before choosing Alternative Two, we considered thoughtfully suggestions offered by those wishing to see the other Alternatives implemented. However, once again we were persuaded by your explanation during mediation on 2-22-10 as reported by Dr. Moore in his e-mailed "Draft Meeting Notes" to participants on 3-4-10:


Escoto stated that initially a number of recommendations proposed by the CAC regarding driving on the beach appeared to Park management to be potentially viable, but that each required more research. (See attached Power Point presentation.) Some of these options included distributing notices and posting signs regarding a variable speed limit based either on beach conditions conducive to turtle nesting and/or turtles or nests being found, putting flags on Park vehicles to notify the public when the above conditions existed, and requiring a slower speed limit on the beach when vehicles were closed to people. Before any of these measures could be considered and implemented, the Park needed to consult with the Regional Director, Deputy Regional Director, the Intermountatin Region (IMR) Chief Ranger, the IMR Law Enforcement Specialist, the IMR Compliance Staff, the United States Attorney’s Office and the DOI Solicitor.

Escoto noted that consultations with the federal parties above did not result in their concurrence with speed limit options for driving on the beach, which the Park originally thought would work. While the United States Attorney’s Office and the DOI Solicitor advised that the Park could require a 15 mile per hour speed limit during any given season – the turtle nesting season and peak visitor months - the introduction of any other restrictions on vehicles would require the Park to conduct an Environmental Assessment (EA) prior to implementation. Many of the options, especially variable speed limits on specific days, were considered to be unviable because of difficulties in notifying members of the public about changes, and problems with identifying and marking a vehicle corridor with variables related to high and low tide lines for the length of the beach.

Finally, we believe the words "biodiversity" and "all recreational users" are broad and encompassing and that vehicular speed limits on Padre Island National Seashore must serve the needs and best interests of all Park constituencies. While such rules may result in inconvenience to one particular group during approximately one fourth of the year, nevertheless, we believe Alternative Two best serves the greater good.



Patricia Suter, Chair

Mina Williams, Vice-Chair

Venice Scheurich, Conservation Chair


Submitted by Venice Scheurich and Mina Williams, September 1, 2010


Ridley Turtle Archive Page