James W. Balsiger, Alaska Regional Administrator
National Marine Fisheries Service
P.O. Box 21668
Juneau, AK 99802-1668

RE: Comments on protecting marine habitats from bottom trawling

Dear Dr. Balsiger,

Thank you for considering my comments on this very important matter. Recent scientific studies have indicated that Alaskan waters contain a diversity of sensitive habitats and that destructive fishing practices, especially bottom trawling, cause serious impacts to these habitats. The National Marine Fisheries Service (NMFS) must adopt new management measures contained in the Essential Fish Habitat Environmental Impact Statement (EIS) for the North Pacific that protect essential fish habitat from the impacts of industrial fisheries.

Alaskan waters are among the world's most diverse, productive and complex marine ecosystems. The seafloor of the North Pacific Ocean is adorned with magnificent, yet fragile, communities of deepwater coral and sponge, which recent scientific studies show provide essential habitat to fish, crabs and other marine life. Ongoing loss of this habitat, however, places the health of these remarkable deepwater ocean ecosystems at risk.

Research in Alaska and worldwide has shown that:

• Bottom trawling reduces the diversity of marine species.
• Bottom trawling reduces habitat complexity (the seafloor "architecture" created by corals, sponges and sea whips as well as animals that burrow into the mud or cobble bottom)
• Bottom trawling can completely alter seafloor communities, changing the community structure of species that can inhabit the damaged environment.

NMFS should adopt Alternative 5-B, which provides the most comprehensive approach among the six alternatives for lessening bottom trawl impacts. Alternative 5-B would significantly increase protection for cold-water corals in the Aleutians, protect rockfish habitat along the Gulf of Alaska slope, and protect crab habitat in the Bering Sea from the impacts of bottom trawling. This alternative is responsive to documented impacts on sensitive habitats and implements appropriate management tools - habitat protection areas, gear conversions, and reductions in total allowable catch - while maintaining vibrant fisheries. In addition, you must also augment Alternative 5-B by fully protecting "Habitat Areas of Particular Concern," such as seamounts, pinnacles, coral gardens, and submarine canyons.