January 7, 2015 Mr. John K. Bullard Regional Administrator National Oceanic and Atmospheric Administration 55 Great Republic Drive Gloucester, Massachusetts 01930-2276 RE: OA2 DEIS Comments Dear Regional Administrator Bullard, We the undersigned 92 organizations, businesses, and concerned citizens from coastal communities throughout the Northeast urge you to take your agency’s own advice and protect important marine habitat in New England. In numerous reports, web sites, position papers, and statements from agency leaders, the National Oceanic and Atmospheric Administration (NOAA Fisheries) has stressed the importance of habitat protection as a way to achieve healthy marine ecosystems. If our oceans are ever to recover from decades of overfishing, and withstand to the changes coming their way from a warming planet, habitat protections will be vital. The Omnibus Essential Fish Habitat Amendment 2 Draft Environmental Impact Statement (DEIS) has consequences for anyone who has a stake in healthy marine ecosystems. This includes people who make their living on the water, like commercial fishermen, but also those who spend their recreational time fishing, boating, whale-watching, or enjoying other forms of ecotourism. Coastal businesses and communities that rely on tourism and fishing are concerned about the overall health of our region’s ocean waters, which attract visitors from around the world. Habitat areas that create refuges from bottom trawling and dredging will help keep a diverse mix of marine wildlife in our waters. With a strong system of protections in place, we can all enjoy the benefits of living in coastal communities supported by the abundance of the surrounding ocean. Because we care about a healthy marine ecosystem in the waters off our coast, we support protecting large areas from destructive fishing gear like bottom draggers, and scallop and clam dredges. In the Gulf of Maine, maintaining the current closures is the best choice available, along with the addition of two new areas Down East. On Georges Bank, the alternative with the best protection is a new area that includes important habitat in the Northern Edge, and habitat that protects juvenile groundfish and spawning Atlantic herring. In Southern New England, the largest alternative extends into the Great South Channel, a key corridor for migrating fish and mammals. In addition to the alternatives presented in the DEIS, NOAA Fisheries should improve ocean habitat in New England by: • Developing significantly larger areas with enhanced management for each region that will offer greater protection for all critical life stages. • Protecting areas where fish spawn, using data and analysis conducted by the Closed Area Technical Team. • Protecting remaining areas that continue to support cold water corals in Eastern Maine. • Enhancing habitat research by establishing a network of Dedicated Habitat Research Areas (DHRAs), in all the regions, including reference areas protected from all fishing and other local human disturbance. • Prohibiting midwater trawl gear from the habitat management areas in order to protect fish where they live, not just on the seafloor, and to ensure abundant prey fish on which other marine animals depend. NOAA Fisheries must take the lead on this amendment and make decisions that give New England’s marine ecosystems a chance, not just to recover, but to thrive well into the future. Thank you for your consideration of our request. Sincerely, Fred Akers Sarah Brown Administrator Director Great Egg Harbor River Council Green Alliance Newtonville, New Jersey Portsmouth, New Hampshire Josh Arnold Gary Brummett Executive Director Owner Global Awareness Local Action Connecticut Outfitters Wolfeboro, New Hampshire Wethersfield, Connecticut Terry Backer Timothy Cabral Executive Director Owner Soundkeeper Ordinary Norwalk, Connecticut New Haven, Connecticut Arthur Benner Vicky Carrier President Concerned Citizen and Science Professor Alewives Anonymous, Inc. New Haven, Connecticut Rochester, Massachusetts Carol "Krill" Carson Kimberly Bradley President Ecologist New England Coastal Wildlife Alliance Niantic, Connecticut Middleboro, Massachusetts Kierran Broatch Wayne Castonguay Long Island Sound Fisherman and Freelance Executive Director Writer Ipswich River Watershed Association Milford, Connecticut Ipswich, Massachusetts Suleiman Chater Eileen Fielding Chef/Owner Executive Director Mamoun's Falafel Restaurant Farmington River Watershed Association New Haven, Connecticut Simsbury, Connecticut Elizabeth Ciarlelli Emily Figdor Manager Director Zinc Environment Maine New Haven, Connecticut Portland, Maine Christina Clayton Suzanne Fournier President Coordinator Old Lyme Land Trust Speaking for Animals in NH Old Lyme, Connecticut Milford, New Hampshire Robert Cohn Chris Fox Secretary Executive Director Connecticut Surfcasters Association Inc. Wood Pawcatuck Watershed Association Madison, Connecticut Hope Valley, Rhode Island Claire Criscuolo Shawne Freeman Chef/Owner Chef Claire's Corner Copia Box 63 American Bar & Grill New Haven, Connecticut New Haven, Connecticut Frank Criscuolo Ed Friedman Chef/Owner Chair Basta Trattoria Friends of Merrymeeting Bay New Haven, Connecticut Richmond, Maine Soledad Culville Shana Gallagher Manager Chair B-Natural Café Tufts Climate Action New Haven, Connecticut Somerville, Massachusetts David Dadekian Martin Garrell President Professor of Physics Eat Drink Rhode Island Adelphi University Providence, Rhode Island Garden City, New York Linda Dionne Tim Gaudreau President Owner NH Animal Rights League, Inc. Tim Gaudreau Studios Concord, New Hampshire Portsmouth, New Hampshire Greg Gerritt Flip Huffard Executive Director Concerned citizen and water advocate Friends of the Moshassuck Darien, Connecticut Providence, Rhode Island David James Kristina Gjerde President Senior High Seas Advisor Quinnipiac River Watershed Association Global Marine and Polar Programme, IUCN Meriden, Connecticut Cambridge, Massachusetts Curt Johnson David Glater Executive Director President Save the Sound Greater Boston Chapter, Trout Unlimited New Haven, Connecticut Boston, Massachusetts Dennis Kestil Jim Glowienka Owner Council Chair Horizon Travel Connecticut Council of Trout Unlimited Dover, New Hampshire Middletown, Connecticut EkOngKar Singh Khalsa Darra Goldstein Executive Director Founding Editor, Gastronomica: The Mystic River Watershed Association Journal of Food and Culture Arlington, Massachusetts Williamstown, Massachusetts Heath Klarsteld Stephenie Goll Chef Manager Wheelers Restaurant and Taproom Pacifico Restaurant Woodbridge, Connecticut New Haven, Connecticut Phil Kline Pam Lyons Gromen Senior Oceans Campaigner Executive Director Greenpeace Wild Oceans Washington, DC Waterford, Virginia Arthur H. Kopelman, Ph. D. Richard Harris President Director, Harbor Watch Coastal Research and Education Society of Earthplace, The Nature Discovery Center Long Island Westport, Connecticut Oakdale, New York Jennifer E. Herring Bun Lai President and CEO Chef/Owner The Maritime Aquarium Miya’s Sushi Norwalk, Connecticut New Haven, Connecticut Holly Landgarten Rob Moir, Ph.D. Owner Executive Director Prelude, Inc. Ocean River Institute Portsmouth, New Hampshire Cambridge, Massachusetts Rob LaTronica Arturo Moreno Chef/Owner Chef Wheelers Restaurant and Taproom Tre Scalini Ristorante Woodbridge, Connecticut New Haven, Connecticut Michael Leviton Mary Mushinsky Chef/Owner Connecticut State Representative 85th Lumiere Restaurant District Newton, Massachusetts Wallingford, Connecticut Wendy W. Lull Joe Nochera President President Seacoast Science Center Old Saybrook Land Trust Rye, New Hampshire Old Saybrook, Connecticut Leo Manchini Roland Olah Owner Chef Nini's House of Tapas Martel Bistro & Bar New Haven, Connecticut Fairfield, Connecticut John Marsland Derek Owen President President Blackstone River Watershed Citizens for a Future New Hampshire Council/Friends of the Blackstone Hopkinton, New Hampshire Cumberland, Rhode Island Mike G. Papa Dave McLaughlin President and Owner Executive Director Artscape Organic Lawncare LLC Clean Ocean Access Stamford, Connecticut Newport, Rhode Island Ryan Patrylak Stella Miller President President SECONN Skin Divers Huntington-Oyster Bay Audubon Uncasville, Connecticut Huntington, New York Cymie Payne Margaret Miner Assistant Professor, Law School Executive Director Rutgers University Rivers Alliance of Connecticut New Brunswick, New Jersey Litchfield, Connecticut Howard Pelkey Joan B. Saxe Chef Co-Chair Tarry Lodge Enoteca and Pizzeria Sierra Club Maine New Haven, Connecticut Portland, Maine Mary Pelletier Nick Scasino Director Owner Park Watershed, Inc. Fireside Bar & Grill West Hartford, Connecticut New Haven, Connecticut Debora B. Pignatelli Rep. Stephen J. Shurtleff New Hampshire Governor’s Councilor Minority Leader District 5 NH House of Representatives Concord, New Hampshire Penacook, New Hampshire Judy Preston Caroline Snyder Ecologist Chair Old Saybrook, Connecticut Citizens for Sludge-Free Land North Sandwich, New Hampshire John Pritchard President Ben Steele, Ph.D. Lyme Land Conservation Trust, Inc. Professor, Department of Natural Sciences Lyme, Connecticut Colby Sawyer College New London, New Hampshire Jamie Rhodes President Rob Stevenson, Ph.D. Environmental Council of Rhode Island Director Providence, Rhode Island Parker River Clean Water Association Byfield, Massachusetts Alison Rieser Professor, Graduate Ocean Policy Program Donna Smith-Remick University of Hawaii at Manoa President Honolulu,