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THE BILLFISH FOUNDATION CONSERVATION THROUGH RESEARCH,.EDUCATION AND ADVOCACY .5100'N'. Feilaral Hwy., Suitt 200 • Fort Lauderdale, -Florida_ 33308 (954) 0$.13.:0150 •(800),43&8247 • Fax (954) 9A13:33 I 1 Wednesday, May 7, 2014 Gary D. Goeke Chief, Regional Assessment Section Office of Environment (GM23E) Bureau of Ocean Energy Management Gulf of Mexico OCS Region 1201 Elmwood Park Boulevard New Orleans, Louisiana 70123 Dear Mr Goeke, Thank you for the opportunity to comment on the Programmatic Environmental Impact Statement (PEIS) to evaluate the potential environmental impacts from multiple geologic and geophysical (G&G) activities within the area of interest (AOI) in the Mid -Atlantic and South Atlantic Planning Areas. This PEIS will have great impacts not only on marine life within federal waters, but also within state waters adjacent to the AOI. A thorough, program - wide analysis of the environmental impacts is pertinent to potential future site-specific programs. Since it is thought that seismic airguns will be the most extensively used method of G&G activities, impacts directly resulting from these processes must be handled in a way that minimizes the impacts on both marine mammals as well as other marine life. In the current status, TBF does not believe the PEIS assesses the potential environmental impacts in enough depth to make an informed decision for future site-specific projects and should not proceed until this is done. Specifically, The Billfish Foundation (TBF) has grave concerns about the thoroughness of impacted environment evaluation for Highly Migratory Species (HMS) and the Essential Fish Habitat (EFH) within Table 4-25, particularly for billfish. Without proper analysis of EFH for these species within the PEIS, the potential impacts of the G&G activities cannot be fully evaluated. The information for blue marlin, white marlin, sailfish, Spearfish, and swordfish within Table 4-25 does not encompass the large essential fish habitat (EFH) for billfish at all life stages and misrepresents the areas that could potentially be impacted. Additionally, the information provided strongly contradicts the EFH for billfish as determined by the National Marine Fisheries Service (NMFS) and should be re- analyzed for billfish, and for all impacted species for that matter, using the most recent information such as the Essential Fish Habitat Mapper v3.0 as provided by NMFS1. The maps generated by the Essential Fish Habitat Mapper clearly show that the EFH for blue marlin, white marlin, sailfish, and swordfish are far greater than what is stated within Table 4-25 for the AOI in the PEIS and therefore raises great concern to the thoroughness and legitimacy of evaluation within the PEIS all of the impacted environment. 1 http.//www habitat.noaa.gov/protection/efh/habitatmapper html