Please Help Protect Alaska's Ocean Ecosystems

Dear Dr. Balsiger,

Recent scientific studies have indicated that Alaskan waters contain a diversity of sensitive habitats and that destructive fishing practices, primarily bottom trawling, cause serious impacts to these habitats. The National Marine Fisheries Service (NMFS) must adopt new management measures contained in the Essential Fish Habitat Environmental Impact Statement (EIS) for the North Pacific that protect essential fish habitat from the impacts of industrial fisheries.

NMFS should adopt a system of marine reserves that fully protects 20 to 30 percent of all marine habitats. Fully protected marine reserves offer an ecosystem-based approach to fisheries management that takes into account the large amount of uncertainty associated with marine ecosystems. Alternative 6 of the EIS, which protects 20 percent of the fishable waters in Alaska, is a good start. I am disappointed, however, that NMFS ignores the wealth of scientific literature on the ecosystem benefits of marine reserves, and has not properly quantified these benefits when evaluating this alternative. This must be rectified in the final EIS.

If the agency does not choose a marine reserves alternative, they must, at a minimum, adopt Alternative 5-B and fully protect “Habitat Areas of Particular Concern.” Alternative 5-B would significantly increase protection for cold-water corals in the Aleutians, protect rockfish habitat along the Gulf of Alaska slope, and protect crab habitat in the Bering Sea from the impacts of bottom trawling. This alternative is responsive to documented impacts on sensitive habitats and implements appropriate management tools - habitat protection areas, gear conversions, and reductions in total allowable catch - while maintaining vibrant fisheries. In addition, agency must also augment Alternative 5-B by fully protecting “Habitat Areas of Particular Concern,” such as seamounts, pinnacles, coral gardens, and submarine canyons.

These precautionary measures must be undertaken to ensure healthy, vibrant ecosystems in Alaska’s seas. Thank you for considering my comments.