The RFA submitted the following public comment regarding the Proposed Hudson Canyon Marine Sanctuary:
July 28, 2022
NOAA Office of National Marine Sanctuaries 1305
East-West Highway, SSMC4
Silver Spring, MD 20910
Re: NOAA-NOS-2022-0053 (“Hudson Canyon Marine Sanctuary proposal”)
Dear Ms. Hogan:
The Recreational Fishing Alliance is grateful for the opportunity to make comments on the proposal to designate the Hudson Canyon as a National Marine Sanctuary.
The Recreational Fishing Alliance (RFA) was founded in 1996 to represent the interests of saltwater anglers and the recreational fishing industry. Since that time, we are proud to have participated in the development of numerous public policy discussions and decisions on behalf of our members and the larger saltwater recreational fishing community at the federal and state levels. This topic is of great interest to all.
The National Marine Sanctuaries Act ( 16 U.S. C. 14 31 et seq) is designed to protect marine environments of “recreational” and “historical” significance. Fishing in the Hudson Canyon is most certainly of historical significance among recreational anglers. However, the designation of the Hudson Canyon as a Marine Sanctuary has raised a number of serious questions among saltwater anglers and charter captains as to whether fishing could one day be banned there.
Recreational anglers care deeply about the marine environment and they will be the first to argue that clean water means healthy marine habitats. The RFA, therefore, respects and supports efforts to restrict any drilling for oil and natural gas in this area. But fishing that is properly managed should have no bearing on preserving the marine environment as proposed here.
The Hudson Canyon is a critical area for fishing for both pelagic and bottom-dwelling species. The area attracts local anglers from New Jersey, New York, and visitors from around the nation and the world. In addition to the thousands of private boat trips made to the area each year it also supports a significant for-hire fleet of boats that either specialize in this fishing or use it to enhance their earning opportunities when inshore fisheries are seasonally closed.
It even has a major impact on tourism as boats and crews come great distances to participate in major offshore fishing tournaments. It is the epicenter of the marlin and tuna fisheries on the East Coast and therefore a major contributor to our coastal economy. In fact, boating and fishing contribute hundreds of millions of dollars to the Mid-Atlantic economy annually.
There is little question that a future fishing ban in the Hudson Canyon would all but eliminate a way of life in this region. NOAA must appreciate the concern that this proposal has caused for the region’s anglers and fishing and marine industries. It is therefore critical that any future Sanctuary designation here must unequivocally preserve access for recreational fishing for private boat owners, for-hire fishing businesses, and all shoreside businesses that depend on their continued access to these unique and historically significant fishing grounds.
The RFA is aware from the proposed NOAA-NOS-2022-0053 and NOAA comments in public hearings that the “intention” of the Sanctuary concept is to preserve recreational fishing as currently managed today. However, as NOAA has also heard in public comments, anglers worry that an intention today does not indicate action to prohibit fishing in the future. We believe, however, that NOAA can act to eliminate this concern should a Sanctuary designation be adopted for the Hudson Canyon. NOAA can reassure the recreational fishing community by taking steps to solidify the proposed intention of keeping the sanctuary open to recreational fishing. These could include:
- Adoption of language in the Sanctuary management plan to clearly state that recreational fishing is welcomed now and in perpetuity within the designated Sanctuary.
- Establish that the “Terms of Designation” (Section 306: “Prohibited Activities”) does not include recreational fishing to ensure that fishing is not banned and will remain under the management of the relevant fisheries councils.
- Set aside seats on the Pre-Designation Advisory Council for recreational fishing appointees.
It is likely that all the stakeholders will agree that this area of the ocean is special and deserves to be treated with the utmost respect. The RFA is also in agreement and we believe preserving this area from industrialization and potentially harmful mineral and energy extractive purposes and any form of pollution is critical to our continued recreational use of these vibrant waters. We simply ask that the historical, cultural,l and economic benefits of recreational fishing be clearly spelled out and preserved should a Marine Sanctuary be established encompassing the Hudson Canyon. The RFA stands ready to work with NOAA and the proponents of the Sanctuary. Do not hesitate to contact me with any questions or concerns.
Robert A. Nixon
Recreational Fishing Alliance