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.

The Fisheries Survival Fund, 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 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.

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