Aliance of Communities for Sustainable Fisheries
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We would hope that any partnership that develops will be with the fishing community, to enable the Sanctuary Program to provide quality comments to the agencies in a way that does not feel like it is breaking its promise to us. There is no doubt but that those agencies would welcome working or coordinating with the Sanctuary Program on that basis.

The Solution
With all this being said, we do recognize that certain types of MPAs may assist the program in realizing its conservation ambitions, as well as assist the science community in their research on issues that affect fishing and other extractive activities. We also recognize that some of the public would like to see some areas set aside as being off-limits to all human activity, as long as it does not negatively affect them.

We are, therefore, still willing to partner with the Sanctuary Program and other stakeholders, to determine if MPAs may be needed, or, to determine that placing an MPA in a given area will not have adverse effects on fishery management, or create an economic hardship or safety issues that we cannot live with. If and when these determinations are made, we will support strong comments from the Sanctuary Program to the CDFG and /or PFMC, advocating for these MPAs.

What is the roadmap to get to this? Although the MPAWG did some good work on the criteria for establishing MPAs, we do not feel that it is enough. To comply with the language of our MBNMS Designation Document, the spirit in which it was written, and the principles of good science, we believe that MPA evaluation must include the following steps:

1. Develop a thorough and science-based condition report must be developed to document the existing conditions of the fishery and habitat.
2. Analyze the information in item1 with the most current understanding of natural multi-year fish population swings.
3. Develop a site specific draft problem statement based on the results of items 1 and 2 above.
4. Apply the criteria analysis developed by the MPAWG, including the socio-economic review discussed above.
5. Work with the fishing community to identify sites that we can support. We would look at all areas in good faith.
6. Has the problem that has been identified been addressed (or can be addressed) by traditional management measures? If so, is it still a problem?
7. If there is a problem that existing management cannot address, is an MPA the answer? What type of an MPA (if any) is the right tool for the problem?
8. Be patient. Identify just one, or a few, MPA sites that can be established as experimental areas and not as final solutions. Provide thorough monitoring and evaluation as to whether or not it is meeting its goals before any new MPAs are placed. This should be able to occur if items 1 through 7 have been done.
9. Accept the possibility that MPAs may cause unintended harm, or imbalance, in our ecosystem. Maintain a flexible, adaptive management attitude; do not commit to the permanency of any particular MPA if there is evidence of negative consequences.
10. Add additional MPAs only if warranted by the results of items 1 – 9.
11. For all of these steps, including the development of the science, the fishing community’s knowledge and advice must be respected and used.

Any MPA that might be created under this guideline would be considered for support and respect by the fishing community.

We understand that other members of the Sanctuary’s MPA Work Group may have more ambitious goals for MPAs. We do, however, hope that every person on the MPA work group can agree that AT MINIMUM, MPAs may be placed within the guidelines stated above. We respect the right of other work group members to continue to advocate for broader uses of MPAs, but again, we do hope that we can have consensus on this minimal statement.

What is Consensus?
We would also like to express concern about the definition of “consensus” that has been provided by the Program. First let us point out that we observed that despite lots of discussion, the MPAWG was never asked to reach consensus regarding MPAs or even the criteria for MPAs. We hope that the MPAWG and the Program will embrace a traditional definition of consensus, wherein all parties must agree on fundamental principles, and if there is not agreement, then the issue is either dead or there is further negotiation. The Sanctuary should NOT use the definition of consensus that it has put forth that if agreement is not reached, then the decision-making is simply elevated to a higher level. This would make a mockery of “stakeholder” participation. (“Stakeholder”, incidentally, is defined in the dictionary as someone who has an economic interest in a position, issue, or resource.) If the decision making were elevated, the next decision would come from the Sanctuary Advisory Council. CONTINUED