In comments submitted Friday in response to the long-awaited Omnibus Habitat Amendment 2 and its underlying analysis, CLF strongly criticized the draft Amendment proposed by the New England Fishery Management Council, stating that it does not comply with the law and puts the region’s goal of producing valuable, diverse, and sustainable fisheries even further from reach.
Thousands of CLF members and supporters joined us to urge John Bullard, the regional administrator for NOAA, to reject the Council’s risky, ill-conceived and scientifically unsound proposals. The Council’s proposed Amendment would reduce protected habitat, in some scenarios by as much as 70%, and allow destructive bottom trawling in areas that have served for nearly 20 years as refuges for commercial fish and other protected marine species.
Our experts’ analysis of the Draft Environmental Impact Statement found the document to be deeply flawed, rife with inconsistencies and contradictions, and so lacking in the required analysis on a number of fronts as to be illegal, let alone viable as a decision-making tool.
Central among our concerns is the Council’s preferred alternative that would allow commercial groundfishing in large portions of Cashes Ledge, a highly sensitive ecosystem unique in the North Atlantic for its abundant variety of species and diverse array of habitats, including a massive kelp forest. Cashes Ledge is essential habitat for the threatened cod, as well as haddock, pollock, American plaice and other groundfish species, sea birds, and North Atlantic right whales and other marine mammals, among many other species. Removing the existing protections from Cashes Ledge would be irresponsible given the lack of compelling data to support such actions and inconsistent with the substance, goals, and objectives of the Amendment. Therefore, we have demanded that the Cashes Ledge and Jeffrey’s Bank closed areas remain closed.
Moreover, virtually nothing was proposed to protect spawning and juvenile cod despite an extensive scientific analysis of “hotspots,” and the habitat protections offered for Georges Bank in place of the existing protected areas were all fundamentally inadequate.
The draft Amendment and DEIS, which can be broadly summarized as favoring drastic reductions in habitat protection and limited restrictions on destructive fishing gear in New England, seek to perpetuate the Council’s history of risky management decisions driven by its fishing industry members’ self-interest rather than the best available data and science, or the broader public interest in our ocean.
It would be difficult to overstate the critical importance of successfully tackling Essential Fish Habitat protection in New England at this time. Numerous groundfish stocks, including severely depleted Georges Bank and Gulf of Maine cod and yellowtail flounder, are in a deepening crisis. Ocean acidification and the impacts of climate change on New England’s ocean have never been more evident, and the implications more uncertain. At no time in the management of our oceans has there been a greater need for precaution to mitigate this ecological uncertainty.
After months of hearing public input on proposals affecting the future of Essential Fish Habitat in New England’s ocean, the decision now facing NOAA and the New England Fishery Management Council is deeply complex, but broadly simple: at a time when the pressures on New England’s iconic fish species and the industry that depends on them are greater than ever, act in the interest of long-term sustainability of our fishery resources and the communities they support, or risk all by pursuing short-term profits.
You can continue to show your support for protecting Cashes Ledge and for strong habitat protection throughout New England’s ocean by contacting your senators and representatives. And, if you haven’t already, please sign our letter to NOAA Regional Administrator John Bullard asking him to permanently protect Cashes Ledge. (If you have already signed, please spread the word and ask your friends to sign, too!)