Alliance of Communities for Sustainable Fisheries
256 Figueroa Street #1, Monterey, CA 93940
www.alliancefisheries.com

This is not the case with the National Marine Sanctuary Program.  This program does not maintain the expertise to manage fisheries in any regard, nor does it have the public decision making process required for the public to feel that a fair and equitable process has been maintained.  With regard to the Sanctuary and fisheries management, we hear that it does not feel that creating MPAs is fisheries management.  However these proposed closures will effect the Nation’s food supply.  They will effect the behavior of fishermen as they transfer their efforts to other locations and could require Council or further State actions to mitigate those consequences.  With regard to the Sanctuaries public decision making process, they are currently reliant on the Sanctuary Advisory Councils.  Because these councils are largely appointed by Sanctuary Management, this has caused the public to wonder whether the SACs represent the public, or the wishes of Sanctuary Management.  This has been hugely controversial in the Monterey Bay region and to a lesser degree in Channel Islands region.  As it stands, it is our opinion that the public is rightfully skeptical of the advice provided by the Sanctuary Advisory Councils.

It should also be noted that the Sanctuary’s proposed language is, prepared under section 922.73  As such it would preclude any future action by the PFMC.  This would mean that the Nation would loose these resources forever.  It also means that the Council would forever loose its ability to modify these MPAs based on emerging sound science.

 There is also considerable irony in this situation in as much as MSA National Standard #1 stipulates that the Nation’s fisheries resources are to be used for the highest food benefit sustainably possible.  How is it that the goals of the National Marine Sanctuary Act outweigh the goals of the Magnuson Stevens Fishery Conservation Act?  We don’t think that they should, nor is a conflict necessary.

I urge NOAA to allow sufficient time for the PFMC to do its work in evaluating this issue and creating any needed regulations that will benefit the existing designation document and the management plan of the Channel Islands National Marine Sanctuary.  There is no urgency in this matter that would require the shoving aside of the PFMC and the substitution of the authority under the National Marine Sanctuary Act.

Thank you for considering these comments.

Kathy Fosmark
Co-Chair
Alliance of Communities for Sustainable Fisheries

C: Vice Admiral Conrad Lautenbacher, USN (ret.)