Comment submitted by B. French

Document ID: EPA-HQ-OA-2011-0798-0009
Document Type: Public Submission
Agency: Environmental Protection Agency
Received Date: October 10 2011, at 12:00 AM Eastern Daylight Time
Date Posted: October 14 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: October 5 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: October 26 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80f4fd2a
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Page 4. Goal: Replenish and Protect Living Coastal and Marine Resources ADD Major Action= Collaborate with Mexico and all Central American countries with Atlantic coast lines: 1. to assess populations of marine resources; 2. to determine the optimum sustainable yield of commercially-harvested resources; 3. to regulate commercial activities to prevent harvesting above the OSY; 4. to establish marine protective areas for conserving valuable marine habitats. General Comment Topic: Resource Valuation Throughout the Draft Strategy, there are numerous references to “value”. However, there is no mention as to how standard resource values are to be determined. This is a significant aspect of the restoration process as “value” is the primary justification most commonly cited for engaging a restoration action. Specifically, NOAA’s Decision Analysis Series N0. 5-Economic Valuation of Resources: A Handbook for Coastal Resource Policymakers (1995) has yet to be fully integrated into the management and regulation of marine resource. Since the publication of DAS No. 5, this academic discipline has flourished without much consolidation into a standard method. Ideally, over the course of 16 years resource economists should have identified all of the marine resources by standard typing and nomenclature; and, should have prepared a table of resource valuations for each of the world’s marine areas (e.g., GoM seagrass, oyster beds, spartina marsh, intertidal beaches, barrier island upland habitat, hard-bottom habitat, marine reefs, deep seafloor habitat, etc.). Tables of established resource valuations (routinely updated) are immediately useful to rapid assessment of local damages and initiation of restoration actions. These valuations can become the “environmental offset credits”, which are often topics of negotiation between regulators and the responsible party. Case-in-point: almost 24 months will have elapsed since the date of the MC252 well blow-out b

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Oct 26,2011 11:59 PM ET