WASHINGTON (Saving Seafood) — The following was released by the Fisheries Survival Fund:
Last week, NOAA Fisheries Regional Administrator John Bullard submitted a nine-page letter to the New England Fishery Management Council (NEFMC) critical of recommendations made by the Council’s Habitat Committee on Omnibus Habitat Amendment 2 (OHA2) . OHA2 is a decade-in-the-making overhaul of the habitat closures off the coast of New England, reflecting the best scientific understanding of the Northwest Atlantic seafloor.
Read Administrator Bullard’s letter in full here.
Read the FSF rebuttal to Administrator Bullard’s letter in full here.
The Fisheries Survival Fund (FSF), which represents the majority of the full-time Limited Access scallop fleet, has prepared a point-by-point rebuttal to Administrator Bullard's letter, which was sent to the NEFMC yesterday.
The following are highlights from the FSF rebuttal.
Georges Bank
1. The Agency claimed: that opening "the area would reverse 20 years of habitat protection and recovery in an area that is highly vulnerable to adverse effects of mobile bottom-tending gear”
FSF responded: “Independent and objective analysis … shows that the area to the west, called Georges Shoals and included in Alternative 7, is more vulnerable to adverse impacts than the [previously protected areas].”
2. The Agency claimed: "[it] seems unlikely that maintaining the gear restrictions in the Closed Area II Habitat Closed Area/HAPC alone would be sufficient to improve habitat protection for juvenile cod and other groundfish species on Georges Bank.”
FSF responded: “[No] action on the Northern Edge be viewed in isolation from actions taken in, for instance, the Great South Channel, where significant closures of juvenile cod [habitat] can be expected with the Committee’s preferred alternative. … Large-scale effort reductions across New England fisheries have already improved habitat protection by decreasing area swept. Realized adverse effects across all gear types have declined even more significantly since 1996. … There is, therefore, no doubt that the management process has already improved habitat protection on Georges Bank and that Omnibus Habitat Amendment 2 will further improve such protection based on the totality of the record.
Figure 8 – Comparison of estimated realized adverse effects from the SASI model by gear type and calendar year. All values in km2.
3. The Agency claimed: that Alternative 7 falls “far short of the current Closed Area II Habitat Closure Area in several key metrics, including a lower percent coverage of gravel-cobble…
FSF responded: Although the percentage of gravel-cobble is less in Alternative 7 “the total gravel-cobble area that would be closed to fishing is much higher (approximately 470 square kilometers in Alternative 7 vs. approximately 274 square kilometers in the Northern Edge), because Alternative 7’s proposed closure area is more than twice as large. Such an alternative, which covers more actual square kilometers of a vulnerable substrate, presents a reasonable method of achieving the desired protection in a practicable manner.
4. The Agency claimed: “The Georges Shoal 2 Habitat Management Area has little to no EFH for cod, haddock, pollock, and three skate species.”
FSF responds: This assertion is a misreading of the chart it cites for authority. The Georges Shoal 2 area, in fact, has “moderate” coverage for juvenile cod and “high” coverage for adult cod based It also contains habitat for several other species included in the such as wolffish, juvenile red and white hake, windowpane flounder, winter flounder, adult yellowtail flounder, little skate, winter skate, scallops, and herring eggs. In addition, this NMFS assertion only considered half of Alternative 7. The other half, known as “Essential Fish Habitat South” overlaps coverage for additional species.
5. The Agency claimed:, “The area within Alternative 7 has very little current trawl or scallop dredge activity from which adverse effects are accruing, particularly in the most recent few years.”
FSF responded: “The purpose of this action is not to restrict fishing for the sake of doing so. … Alternatives must be selected based on an analysis and weighing of the metrics for habitat conservation. Otherwise, once an area was closed to fishing, it would never be eligible for reopening—which clearly is not and has never been the Council’s intent.
Great South Channel
The Agency claimed: “Looking at the habitat management alternatives collectively, the combination of preferred habitat management areas being recommended by the Committee results in meaningful reductions in overall habitat protection and would fail to adequately minimize the adverse effects from fishing on EFH in the region.”
FSF responded: Alternative 5 in the Great South Channel would protect a major area of vulnerable substrate and habitat. The alternative covers over 700 square km of vulnerable gravel and cobble substrate. The area covered by this substrate alone is larger than the entire juvenile cod protected area in the Northern Edge.