Full document / COSOC-W-86-002 - the National Sea Grant Library
Full document / COSOC-W-86-002 - the National Sea Grant Library Full document / COSOC-W-86-002 - the National Sea Grant Library
726 projects, NMFS has been forced to apply its dwindling budgets and resources to only a small portion of its mandated responsibilities. In the Northeast, NMFS habitat programs find Increasingly less time for forage stocks despite their importance to corrmerclal fisheries, less effort corttnltted to habitat supporting species under restoration in their former ranges, and little Interest in species of low fisheries management concern despite their Importance to recreational fishermen or marine ecosystems. Protected species may fare even worse. Concerning the NMFS mandates In wetlands, commercial fisheries, anadromous fish, and the Clean water Act, these artificial constraints are very frustrating. NMFS opportunities to Influence Army Corps of Engineers' decisions in their Section 10 and 404 permit revtews have been reduced by policies in both agencies, and Northeast Region participation in other project planning like hydropower projects has suffered from the budget ax. Despite these concerns that various habitat components and mandates may be neglected, thts shift does reflect budget realities and current administration philosophies. This shift should not be interpreted as an Intentional abrogation of legislative mandates by the Individual habitat offices that are trying to balance budget impacts and resource threats. This trend is not limited to any particular Issue or species In the Northeast, and perhaps not even to just the Northeast. One major limiting factor Is the emphasis on species covered by fisheries management plans prepared under the Magnuson Fishery Conservation and Management Act. In the Northeast, with the preponderance of offshore rather than estuarlne-dependent fisheries, this means more emphasis on lobster, scallops, cod, and haddock than would be seen in the Southeast where the major commercial fisheries are shrimp and menhaden, both estuarlnedependent species. This trend toward emphasis on commercial fisheries is accentuated by the NMFS and fishery council philosophy that stocks In state waters should be managed by interstate commissions rather than federal intervention. Another exaaple is in the art/science of mitigation. Uncertainties associated with efforts to recoup productivity losses Impose a definite drain on coastal and estuarine resources. In essence, mitigation imposes a forced loss of fishery production for at least the months or years between project development and completion of mitigation plans. Conclusions Despite these trends In the philosophies and budgets of habitat programs, NMFS and presumably other federal agencies still continue to emphasize fishery habitat conservation. And continued pressure to support coastal development can be expected in an era of expanding human populations and growing desire to live within sight of breaking waves. But what are the implications to the living resources and habitats, and the programs that have evolved In response to federal and state habitat mandates? First, the recent shift in
management emphasis Is now affecting federal research programs. Emphases on commercial fisheries and major development projects has probably slowed NMFS efforts to reprogram part of its management efforts toward estuarine Issues and growing problems like environmental contamination, excess nutrients, and coastal habitat alteration. Second, NOAA's role as the nation's conscience for marine science has been oompromised by our limited participation In certain estuarine and coastal issues. Third, total NOAA/NHFS strength as perceived by other federal agencies may be declining, as evidence by Department of Interior proposals to Increase their role in anadromous fish programs and the Environmental Protection Agency's creation of an Office of Wetland Protection; both changes could represent the beginning of a challenge to NQAA/NMF5 responsibilities in estuarine and marine resources management. Fourth, MMFS may actually be neglecting legal mandates by limiting Its habitat and resource management programs. For example, NMFS rarely defends the economic value of fisheries and their habitat through the full extent of the Interagency elevation process In their Memorandum of Agreement with the Corps of Engineers under Section 404(q) of the Clean Water Act. That agreement enables NMFS to challenge Corps permit decisions, but NQAA/rXFS rarely exercises Its full, formal challenge. Fifth, several of the duties now neglected by NMFS may actually hurt development plans. One classic example is hydropower applications In the Northeast where 1MFS Is required to provide written comments to applicants for a Federal Energy Regulatory OxiRitsslon license to generate hydroelectric power. Budget cutbacks have forced NMFS not to provide a written oontnent in response to each permit application received. The result Is that applicants encounter an administrative hurdle that delays their programs, and NMFS loses the opportunity to work with developers to Install fish ladders to help re-establish valuable anadromous species to their historic ranges. It's a classic case of both sides losing. Unfortunately, I think this entire issue of decreased progranmattc support for habitat management and research is a missed opportunity for all marine resource users. 727
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726<br />
projects, NMFS has been forced to apply its dwindling budgets and<br />
resources to only a small portion of its mandated<br />
responsibilities. In <strong>the</strong> Nor<strong>the</strong>ast, NMFS habitat programs find<br />
Increasingly less time for forage stocks despite <strong>the</strong>ir importance<br />
to corrmerclal fisheries, less effort corttnltted to habitat<br />
supporting species under restoration in <strong>the</strong>ir former ranges, and<br />
little Interest in species of low fisheries management concern<br />
despite <strong>the</strong>ir Importance to recreational fishermen or marine<br />
ecosystems. Protected species may fare even worse.<br />
Concerning <strong>the</strong> NMFS mandates In wetlands, commercial fisheries,<br />
anadromous fish, and <strong>the</strong> Clean water Act, <strong>the</strong>se artificial<br />
constraints are very frustrating. NMFS opportunities to Influence<br />
Army Corps of Engineers' decisions in <strong>the</strong>ir Section 10 and 404<br />
permit revtews have been reduced by policies in both agencies, and<br />
Nor<strong>the</strong>ast Region participation in o<strong>the</strong>r project planning like<br />
hydropower projects has suffered from <strong>the</strong> budget ax. Despite<br />
<strong>the</strong>se concerns that various habitat components and mandates may be<br />
neglected, thts shift does reflect budget realities and current<br />
administration philosophies. This shift should not be interpreted<br />
as an Intentional abrogation of legislative mandates by <strong>the</strong><br />
Individual habitat offices that are trying to balance budget<br />
impacts and resource threats.<br />
This trend is not limited to any particular Issue or species In<br />
<strong>the</strong> Nor<strong>the</strong>ast, and perhaps not even to just <strong>the</strong> Nor<strong>the</strong>ast. One<br />
major limiting factor Is <strong>the</strong> emphasis on species covered by<br />
fisheries management plans prepared under <strong>the</strong> Magnuson Fishery<br />
Conservation and Management Act. In <strong>the</strong> Nor<strong>the</strong>ast, with <strong>the</strong><br />
preponderance of offshore ra<strong>the</strong>r than estuarlne-dependent<br />
fisheries, this means more emphasis on lobster, scallops, cod, and<br />
haddock than would be seen in <strong>the</strong> Sou<strong>the</strong>ast where <strong>the</strong> major<br />
commercial fisheries are shrimp and menhaden, both estuarlnedependent<br />
species. This trend toward emphasis on commercial<br />
fisheries is accentuated by <strong>the</strong> NMFS and fishery council<br />
philosophy that stocks In state waters should be managed by<br />
interstate commissions ra<strong>the</strong>r than federal intervention. Ano<strong>the</strong>r<br />
exaaple is in <strong>the</strong> art/science of mitigation. Uncertainties<br />
associated with efforts to recoup productivity losses Impose a<br />
definite drain on coastal and estuarine resources. In essence,<br />
mitigation imposes a forced loss of fishery production for at<br />
least <strong>the</strong> months or years between project development and<br />
completion of mitigation plans.<br />
Conclusions<br />
Despite <strong>the</strong>se trends In <strong>the</strong> philosophies and budgets of habitat<br />
programs, NMFS and presumably o<strong>the</strong>r federal agencies still<br />
continue to emphasize fishery habitat conservation. And continued<br />
pressure to support coastal development can be expected in an era<br />
of expanding human populations and growing desire to live within<br />
sight of breaking waves.<br />
But what are <strong>the</strong> implications to <strong>the</strong> living resources and<br />
habitats, and <strong>the</strong> programs that have evolved In response to<br />
federal and state habitat mandates? First, <strong>the</strong> recent shift in