Aliance of Communities for Sustainable
Fisheries
P O Box 1309, Carmel Valley, CA 93924 (831) 659-2838
January 4, 2002
Bill Douros, Superintendent
Stephanie Harlan, Chair, Sanctuary Advisory Council
Monterey Bay National Marine Sanctuary
299 Foam Street, Monterey, CA 93940
RE: Comments on the Management Plan Review
for the Monterey Bay National Marine Sanctuary
Please find attached a copy of a series
of recommendations relating to the Sanctuary Programs Review of
its Management Plan. You will note that these recommendations
are similar to those adopted by the City of Monterey and a number
of other agencies. In addition to that, they are nearly identical
with recommendations adopted by the California Association of
Harbor Masters and Port Captains, a fifty-four year old State
professional organization of Harbor Managers which has long worked
collaboratively with the fishing industry. The Alliance remains
supportive of the primary goals of the Sanctuary Program, banning
oil and gas development, preserving good water quality and in
conducting education and research regarding Sanctuary Resources.
In addition to the attached recommendations
and as a result of a full discussion by the Executive Board of
the Alliance, we wish to elaborate on several points.
1. FISHING. We hope that by now the promises made
to the fishing community during the original designation process,
including the background to those promises and the spirit of which
they were made, is well understood by Sanctuary officials. The
Sanctuary Program was supported by our industry because we felt
that shared goals would enable our industry, not disable it. We
do not perceive that the Sanctuary Program is considering establishing
direct fishery regulations, such as limitations on gear usage,
seasons, or bag limits. However, the Sanctuary is empowered both
in its management plan and also in the National Marine Sanctuaries
Act to create special purpose zones within Sanctuary boundaries.
We are certain that the Sanctuary Program is under enormous pressure
from various individuals and NGO's to establish no-fishing zones
(marine reserves) within the Sanctuary boundary. This could be
done by either using the authority of the Sanctuary Program to
influence a state process or by directly using the Sanctuary's
own zoning authority. You should be very clear that this type
of action or advocacy would be considered a breech of the promise
made to the fishing community unless such zones are the result
of cooperative work with the fishing community and supported by
the fishing community. The Sanctuary Program has more to lose
than to gain by using/abusing its zoning authority for indirect
fishery management. The Program has much to gain by developing
a cooperative working relationship with our industry, something
that we very much want to see occur. You have much to lose with
the fishing community if it were forced to use all of its political,
economic, and cultural influences to take to task a Sanctuary
Program that violates an essential trust between it and one of
its primary stakeholders. Knowledge of the promise made to us
is not limited to those within our industry, but is remembered
by many community leaders.
The last point to be made is that we hope that the Sanctuary Program
will be as thorough in protecting our fishing heritage as it is
in protecting the endangered species of the Sanctuary. We truly
are an endangered species, at real risk of being lost to the culture
and heritage of this area.
2. WATER QUALITY. We support the Sanctuary's efforts
to work cooperatively with other agencies and industries to preserve
and/or improve water quality in the Sanctuary waters. The biggest
single threat on a daily basis to Sanctuary resources, however,
remains multiple sources of non-point pollution, which enter the
bay. Polluted watersheds can also effect our salmon fisheries
and other endangered species. We encourage and recommend that
the Sanctuary devote even more time, both through staff and volunteers,
to working with agencies and NGO's in addressing this problem.
We continue to support the ban on oil and gas development as activities
that could harm water quality.
3. HUMAN IMPACTS. It is our opinion that the existing
language of the Management Plan, as well as the National Marine
Sanctuary's Act, which resolves any conflict between users and
protection of resources in favor of protection, ultimately will
lead to the gradual elimination of human uses of Sanctuary waters
and resources. Such language as exists would be appropriate for
a small and highly unique area that deserves ultimate protection
from any impacts. The fishing community would support this type
of application of this principle. However, the Monterey Bay National
Marine Sanctuary is fifty-three hundred square miles of ocean
waters that have long been in the public domain of use. This includes
of course not just fishing but surfing, diving, kayaking--all
forms of use that may create impacts on the environment. If you
go into the detail of any one of these uses you will fairly quickly
see how the use changes, if not impacts, the resources of the
Sanctuary. We believe there is no exception to this. Take surfing
as a hypothetical example: surfers share habitat (kelp forest)
with the endangered sea otter. There could well be impacts to
the sea otter from this human presence. Also, the fins on surfboards
cut kelp so there is a secondary impact to the Sanctuary resource.
Therefore, in the logic of protectionism, perhaps there should
be a ban on surfers from kelp areas. We believe that what is needed
for the Sanctuary Program is new language that articulates as
the goal a balance between the conservation (protection) and human
uses of the Sanctuary resources. No one idea should dominate over
the other. CONTINUED