Full document / COSOC-W-86-002 - the National Sea Grant Library

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.
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