Aliance of Communities for Sustainable Fisheries
P O Box 1309, Carmel Valley, CA 93924 (831) 659-2838

May 11, 2004

Ralph Rubio, President
AMBAG
P O Box 809
Marina, CA 93933

Dear President Rubio and Board Members:

Our organization, the Alliance for Communities for Sustainable Fisheries (ACSF), has been organized to represent the economic, social, and cultural interests of the recreational and commercial fishing industry in the geographic region from Port San Luis (Avila Beach) to Pillar Point Harbor in San Mateo County. As the name implies, we are committed to the preservation of sustainable fisheries and link fishing activity with the greater communities that support that industry. Resolutions supporting the efforts of the ACSF have been adopted by the City Councils of Monterey and Morro Bay, by the elected Commissions of the San Mateo County, Moss Landing and Port San Luis Harbor Districts, and the Santa Cruz Port District.

On behalf of the ACSF, we commend the AMBAG Board for taking the time to understand how the SAC is constructed and operates and in making recommendations. We understand that the AMBAG Board is willing to consider proposals from various communities and industries as to how their representatives may be fairly selected to participate on the Sanctuary Advisory Council. We have several comments on this point.

First, regarding the fishing seat on the SAC, this has historically been filled by a commercial fishing person. There have recently been discussions about creating a separate seat for recreational fishing, and we fully support this and hope that this happens. If the seat is filled by a commercial fishing representative, then we propose that our organization, which is specifically designed to include all of the fishing ports within the Sanctuary region, take the lead to consult with the individual commercial fishing associations in each port, Fishermen’s Alliance, the Pacific Coast Federation of Fishermen’s Associations, and any other established groups representing the interests of commercial fishing that might arise, to select a commercial fishing SAC representative. We will seek to do this by consensus of the groups mentioned. If for some reason we are split amongst equally qualified candidates, we would then and only then submit those names to the Sanctuary Superintendent for his final selection. Otherwise, we feel that the choice of our representatives should belong to the fishing community alone.

If the recreational fishing people gain their own seat on the SAC, then we would look to the Coastside Fishing Club, Recreational Fishing Alliance, and United Anglers of California to select a SAC representative. Again, this should be done by consensus with those groups.
If for some reason the Sanctuary does not create a new fishing seat specifically for recreational folks, then the ACSF would consult with all of the recreational and commercial groups mentioned above to select a representative. In all these cases, both a primary and an alternate would be selected.

We would also like to comment on how the three “at large” seats are selected. Considering that the three “at large” representatives currently serving on the SAC are supposed to represent the general public, but they all voted against recommendations made by both Congressman Farr and AMBAG regarding the SAC and other issues, we wonder, who is the public that they represent? We think that these positions either need to be eliminated, having no clear constituency, or they need to be appointed by publicly elected bodies. If this is the case, may we suggest that the Monterey, Santa Cruz, and San Luis Obispo County Boards of Supervisors each select a citizen to serve as their “at large” representative. This would tie these positions more to the elected represented democracy process.

To close, we have offered specific suggestions about our industry. We think that other industries, such as business, tourism, diving, etc., all have readily identifiable major groups representing those interests. We hope that the AMBAG Board will consider these proposals. We would be happy to continue to work with the Board, an AMBAG Committee, and or AMBAG Staff to further refine these proposals. We do believe that time is of the essence in this matter, and that AMBAG should encourage the Sanctuary Program to make these changes, and initiate a fairer selection process soon, so that the final stages of comment on the draft MBNMS Management Plan will have the benefit of these changes.

CONTINUED