September 6, 2016

Robert P. LaBelle
Federal Co-Lead, Mid-Atlantic Regional Planning Body
BOEM
45600 Woodland Road
Mailstop: VAM-BOEM DIR
Sterling, VA 20166

Dear Dr. LaBelle,

The New York Marine Sciences Consortium is an association of colleges, universities, and degree-granting institutions with expertise and interest in marine and/or coastal sciences. NYMSC is the voice of New York State’s marine sciences academic community and strives to influence public policy, communicate sciences, and increase funding for the marine sciences within New York.

Our membership has had the opportunity to learn about and participate in discussions concerning the Mid-Atlantic Regional Ocean Action Plan. Many of our membership for decades have been involved in research concerning the Mid-Atlantic Bight and Long Island Sound. We are aware of the complex oceanographic processes of the Bight and have also been involved in understanding the anthropogenic impacts that have and are occurring in that important ecosystem — ocean dumping, shore erosion, and fishing pressure.

It is apparent that the conflicts for use of the Mid-Atlantic Bight are increasing and in some cases becoming more contentious. Creation of large wind power areas may interfere with navigation, fisheries, and marine mammal migration. Dredging sand for beach nourishment may redistribute sand so that benthic habitat is destroyed. It may also increase the size of breaking waves on the beach thus increasing erosion potential by deepening the bathymetry in the near-shore areas.

We have several suggestions. We find that the plan is weak in promoting understanding of the oceanographic processes that influence the Mid-Atlantic Bight and also in encouraging translating data into information.

We suggest strengthening the environmental and management linkages between state and federal waters. How states manage coastal waters impacts federal waters and vice versa. This is an opportunity to create common goals and practices. For example, we should have some regional standards for dissolved oxygen in the New York Bight.

The Data Portal is an excellent tool for helping to implement the goals and objectives of the planning process and for facilitating cooperation with the states. However we must emphasize that data alone does not generate understanding. Thoughtful analysis of the accessible data is equally as important as the data itself if the Mid-Atlantic Bight is to be effectively managed and utilized. Maps are useful and effective tools. However, maps are taken as definitive statements of accurate and precise information as we have become accustomed to the excellent charts and maps of the National Oceanic and Atmospheric Administration and the U. S. Geological Survey. The beautiful maps, particularly those delineating natural resources, created as part of the Ocean Action Plan, have not been developed in the same careful way, largely because the information portrayed is much less certain over time and space than that typically delineated by our national mapping agencies. There is little spatial auto-correlation amongst the data for sediment grain size or benthic habitat, for example. There is an implication with the maps that knowledge exists where it doesn’t. This is unacceptable and will hinder the planning process. The uncertainties of these products should be pointed out on the maps themselves.

We are also concerned that eutrophication of coastal waters is not emphasized. This is one of the most significant issues confronting the oceanic environment on a global scale. We understand that in the Mid-Atlantic Bight the states are confronting the problem through nitrogen reduction efforts. However, given the past history of hypoxia in the New York Bight and the continuing problem in the Gulf of Mexico, we believe it deserves more attention — particularly since monitoring of changing ocean acidity is given such high priority in the plan.

The NYMSC, with the above suggestions, enthusiastically embraces the Mid-Atlantic Regional Ocean Action Plan and looks forward to working with various management authorities to assist in its promotion and implementation. NYMSC has a broad spectrum of expertise that can be useful in that regard. We are eager to see the planning process turned into actions so that we may use but protect this important water body.

Sincerely,

Marie de Angelis
Chair, NYMSC
Department of Science
Maritime College
Bronx, NY 10465

Maureen Krause
Past Chair, NYMSC
Department of Biology
Hofstra University
Hempstead, NY 11549

Malcolm Bowman
Director, NYMSC
School of Marine and Atmospheric Sciences
Stony Brook University
Stony Brook, NY 11794-5000

R. Lawrence Swanson
Past Director, NYMSC
School of Marine and Atmospheric Sciences
Stony Brook University
Stony Brook, NY 11794-5000