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Furthermore, the National Marine Fisheries Service " has determined a Programmatic Fish Habitat (EFH) <br />consultation is not an appropriate mechanism and that potential impacts must be evaluated in subsequent, <br />more specific consultations." (PEIS, pg. viii) TBF does not agree with this statement and believes that <br />consultation for EFH is a very important factor and must be performed on both programmatic and site-specific <br />levels. <br />An additional concern of The Billfish Foundation is to how the G&G activities will impact recreational fishing <br />within the AOI. As the importance of recreational fishing within the AO1 is stated within the PEIS, NOAA <br />estimated in 2011 that recreational fishing in the Mid -Atlantic and South -Atlantic regions generated more than <br />$9.8 billion in trip and durable expenditures and supported nearly 79,000 jobs. The importance of these <br />activities cannot be ignored and any future activities should aim to reduce activities that negatively impact the <br />success and number of recreational fishing trips due to their large economic importance. In addition to the <br />potential impacts caused by changes in migratory patterns and normal predator/prey interactions, the direct <br />Impact Producing Factors (IPFs) resulting from the G&G activities such as acoustic sounds, vessel traffic, and <br />vessel exclusion zones will directly impact recreational fishing and must be evaluated more specifically on a <br />programmatic and future site-specific levels. <br />In conclusion, The Billfish Foundation does not believe that the Programmatic Environmental Impact Statement <br />for potential G&G activities within the Mid -Atlantic and South -Atlantic regions fully evaluates the potential <br />environmental impacts. Before moving further, additional programmatic analysis is needed to reduce the <br />potentially negative impacts on important marine ecosystems as well as economically important activities such <br />as recreational fishing. <br />Sincerely, <br />Andrew Cox <br />Science and Policy Specialist, The Billfish Foundation <br />�‘.11;.c <br />