Thomas A. Nies, Executive Director

New England Fisheries Management Council

50 Water Street, Mill 2

Newburyport, MA  01950

May 26, 2017

Dear Mr. Nies,

I am writing to the Council’s Habitat Committee to comment on the Draft Omnibus Deep-Sea Coral Amendment alternatives.

In 2014 I attended the Mid-Atlantic Fisheries Management Council’s presentation by Dr Nizinski on deep-sea corals.  In the canyons of the mid-Atlantic region they surveyed for corals below 500 meters.  Deep-water corals live in total darkness.  Absent light, these corals lack the symbiotic algae that produce nutrients to feed shallow water coral.  Instead, deep water corals feed themselves by capturing passing food.

Without algae and due to the cold harsh conditions, deep-sea corals grow very slowly. Two French vessels fishing off West Ireland had two biologists aboard from the University of Glasgow.  They examined 229 trawl hauls and found that five hauls included substantial amounts of coral.  Back in the laboratory, radiocarbon dating of these fragments indicated the deep-sea coral reef was at least 4500 years old.  While only 2 per cent of the trawls (5 out of 229) damaged deep-sea corals, the impacts on the ecosystem of a few mistaken trawls were enormous with damages very long lasting.

Deep-sea coral communities are called biodiversity hotspots. They are considered essential habitats for commercially valuable fish stocks. Only Acadian redfish (ocean perch) have been frequently seen with specific deep-sea corals.  It was, therefore, big news to learn of Dr. Nizinski’s observations of white hake and skate with deep-sea corals.  Finding these two relatively abundant commercially valuable fish with deep-sea corals gives hope for the importance of deep-sea coral communities for less numerous ground fish populations including cod and haddock.  Monkfish are known to dwell seasonally with the deep-sea corals.

The Amendment is full of extensive information on distribution and abundance of commercially valuable fish, I commend you. Nonetheless, we really know very little about ocean floor habitats and fish abundance below 300 meters.  We do know that areas with deep-sea corals provide refuge for many fish, by species to varying degrees, that are caught in shallower waters.

Therefore, I urge that the more precautionary alternatives be taken for the management of these pockets and ribbons of ocean floors between 200 and 600 meters deep.

For the Inshore Gulf of Maine waters, I support the Council preferred alternative to prohibit mobile, bottom-tending gear in the Outer Schoodic Ridge and Mt Desert Rock deep-sea coral zones.

For the Offshore Gulf of Maine waters, I recommend that mobile, bottom-tending gear be prohibited in the Jordon Basin and in Lindenkohl Knoll area.

For the Canyon Areas South of Georges Bank, I recommend for an alternative that protects from mobile, bottom tending gear those areas where deep-sea corals have been observed and are predicted to occur.  Fishing permitted to continue where it has been documented.  This is the freeze-the-current-fishing-footprint scenario.

Once again New England is leading the nation with the first national marine monument, the Northeast Canyons and Seamounts NMM, that permits fishing.  Lobstermen from RI, MA, and NH are permitted to trap with fixed gear.

This is collaborative management where the Secretary of Interior manages in partnership with the Secretary of Commerce.  As stated in the executive order, the leadership must consult with all federal agencies with overlapping jurisdictions including NOAA and the New England Fisheries Management Council.  I recommend that this new partnership be taken into consideration and fostered to give the Council greater voice when making decisions on the Draft Omnibus Deep-Sea Coral Amendment.

After all this area only became a national monument because the canyons and seamounts are quite pristine.  Located in and adjacent to the most heavily fished waters in the world, these ocean habitats are most remarkable phenomena. These deep-sea canyons and seamounts are living proof of best fisheries management practices.

Thank you for the opportunity to comment.

Sincerely yours,

Rob Moir, Ph.D.