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

August 27, 2004

Ralph Rubio, President
AMBAG
P O Box 809
Marina, CA 93933-0809

Dear President Rubio and Board Members,

In light of the AMBAG Board discussion of the Sanctuary Advisory Council representation issues heard on August 11, 2004, we would like to offer a general and several very specific recommendations. We offer these as an organization which has worked closely with the Sanctuary Program. Our members have attended many, many hours of meetings with the Sanctuary Advisory Council, and various subcommittees for the Management Plan Review. Further, we have studied the National Marine Sanctuary Act and the Sanctuary’s Management Plan. We have also worked extensively with all of the other stakeholder SAC Representatives, and are quite familiar with the selection process in place.

General: The main principle to bring the functioning of the SAC into the principles of a represented democracy is that each seat has an identifiable constituency with which the SAC representative can communicate and to which he/she will be accountable. The way to implement this system is to identify all the known organizations and associations within the Sanctuary region who wish to participate in the decision making for a SAC representative and other Sanctuary issues. These organizations would caucus once every three years to select their SAC representatives. It could well be that one or more organizations would volunteer to coordinate with the other organizations for the caucusing process. Once candidates are selected their names will be submitted to the Sanctuary Superintendent for appointment. A stakeholder group would be at liberty to select whomever they wanted as their representative and not necessarily limit their consideration to organization members. Likewise, the Sanctuary could still advertise to the general public for these open stakeholder seats; however, without a clear endorsement from the major organizations, it would be hard to see how individuals would have a clear constituency to communicate with and to be accountable to. We believe that this system could be adopted by the MBNMS without requiring a change in Federal law.

RECOMMENDATION #1:
A seat that does not have a clear constituency should either be eliminated or redefined so it has a constituency. Another option would be to make this constituency-less seat a non-voting member of the SAC.

RECOMMENDATION #2:
Accept that identifying a selection method for some stakeholder seats will be easier than for others. Indeed, Superintendent Douros stated twice to the AMBAG Board that there is no perfect system for this. He is right about that, but this should not deter AMBAG from improving on a system where a federal employee gets to solely make the selections for these SAC seats, sometimes in contrast to the wishes of the organized stakeholder organizations. We recommend that AMBAG Board act upon those seats that it feels confident that a fair process is in place and continue to work on the others. It may be that for certain seats AMBAG will need to apply some leadership in calling and managing a meeting between constituent groups, to get to a reasonable process. The Business and Tourism seats may need this assistance from AMBAG. This will sort itself out.

RECOMMENDATION #3:
For the purpose of advancing discussion, we offer the following recommendations for each specific stakeholder seat on the SAC:

Conservation, Research, and Education – although it has not been discussed by the AMBAG Board, nor has Sanctuary staff offered this as an example, but there are in fact three seats that serve as a model for how SAC seats should be selected. These are the Conservation, Research and Education seats. In each of these cases there is a SAC Working Group constituted from the numerous organizations that are active in that area. Once every three years these organizations caucus and then make their recommendations for the SAC seats from their membership. To the best of our knowledge these have been approved, without exception, by the Sanctuary Superintendent. An example of this is the Conservation seat, whose working group includes organizations such as Save Our Shores, the Ocean Conservancy, Friends of the Sea Otter, the Otter Project, the Sierra Club, and more. These organizations select the best people they can to be their advocates on the SAC, and this is how it should be. The same is true for research and education.

CONTINUED