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