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

            We have no objection to any activity that evaluates the use of the concept of “marine protected areas” so long as fishing is not regulated except in accordance with current law or is excluded from marine protected area regulations entirely. 

The use of an MPA workgroup would be appropriate to evaluate the utility of MPAs if the workgroup process was fairly constituted and science-based.  Any recommendations that came out of the workgroup would be forwarded to the Pacific Council for their consideration.  However, it is the perception of the fishing community that the MBNMS current workgroup is seriously flawed as a public/science- based process.

            4.         Dredging Action Plan.

            Maintenance of existing harbor areas is an important program for our coastal communities, and not just for fishing vessels.  We do not believe that the NOAA Sanctuary Program should have regulatory authority over dredge permits, but should only provide comment on permits filed with the U.S. Army Corps of Engineers.  This issue should be addressed and the position taken that NOAA cannot prevent a dredging permit from being issued on the basis of marine sanctuary considerations. 

            5.         Introduced Species Action Plan. 

            The Alliance is concerned that the broad nature of this action plan may result in controls on the fishing fleet that would require all vessels to be inspected (and perhaps cleaned) before every trip into Sanctuary waters.  Commercial fishing vessels routinely leave the Sanctuary area to fish elsewhere and vessels based elsewhere enter the Sanctuary to fish.  We are aware of no scientific evidence that this activity has created any environmental problem with respect to non-resident species.  We hope this issue can be clarified to ensure that additional regulations, without any basis and without any evaluation of the pros and cons, are not adopted.

             6.         Marine Sanitation Devices.

            Here again, the intent of the management plan is not entirely clear.  The proposal to lock all sanitation devices on small vessels in sanctuary waters lacks neither a factual basis nor extensive analysis.  We are not sure whether any new regulation is required to address this issue.

            7.         Deserted Vessels.

            The proposal for a regulation with respect to deserted vessels appears to lack clear standards.  Certainly the Coast Guard should be consulted on this question.  The standard for issuing a civil penalty of any size should be spelled out and should only issued for a condition that everyone agrees is grossly negligent and imminently dangerous.