22 October 2002
Mr. Michael Flores, President
California Fish & Game Commission
1416 Ninth Street, 13th Floor
Sacramento, CA 95814
RE: Channel Islands Marine Protected Areas
Dear Mr. Flores and Members of the Commission:
The Pacific Coast Federation of Fishermen’s Associations (PCFFA), representing working men and women in the West Coast commercial fishing fleet, has the following comments regarding the decision on the establishment of marine protected areas (MPAs) around the Channel Islands which will be made at your special 23 October meeting in Santa Barbara. At the outset, it should be pointed out that PCFFA has worked for the establishment of national marine sanctuaries offshore California and participated in the crafting and passage of California’ Marine Life Protection Act, which would establish a network of MPAs in the State’s ocean waters. It is against that background that we offer these comments – to be both constructive and cautionary.
Intent of an MPA(s)
PCFFA fully supports the establishment of protected areas along the California coast and around the Channel Islands in order to: 1) protect marine biodiversity, 2) preserve unique or special habitats, 3) provide some areas of refuge for resident or spawning fish populations, and 4) set aside areas for baseline marine research. PCFFA is concerned, however, that the intended purposes of an MPA have been lost to a degree in the development of the Channel Islands’ alternatives by emphasizing an amount or percentage of area, as opposed to identifying special areas requiring a higher level of protection, or total protection. What we should be attempting to do is protect the “Yosemites,” not necessarily the “west side of the San Joaquin Valley,” even if the west side is a greater percentage of land than Yosemite. We are disappointed therefore that the benefits of MPAs are being lost to satisfy one or another groups desire to lay stake to the greatest area possible to close to fishing around the Channel Islands. MPAs should not be about bragging rights or membership drives, but the careful selection of areas for protection, involving those with scientific and working knowledge, which will do the greatest good for our marine waters and life.
Failings of the Alternatives
The alternatives under consideration fail to establish the type of marine protected areas around the Channel Islands that will best serve our marine life. Specifically the alternatives:
1.fail to adequately consider all factors affecting marine life and habitats in the area and instead focus on one “extractive” activity – fishing;
2. fail to establish the specific monitoring, research, or evaluation needed for marine protected areas and, instead, just close areas to fishing; and
3. fail to contain specific objectives and management measures necessary to determine whether the MPAs are achieving the objectives of the program (the objective is not merely to “feel good”).
Recommendations
In light of some significant failings in the alternatives presented in the document, PCFFA recommends the Commission either: 1) adopt the proposal put forward by Messrs. Miller and Liquornik (similar, but distinct from the “Preferred Alternative”) that provides for a better phase-in program; or 2) simply roll the Channel Islands MPA establishment into the State process that has been established for implementing the Marine Life Protection Act.
Regardless of what alternative is selected, however, PCFFA agrees fully with the Sea Urchin Harvester’s Association that the Commission also:
1.adopt specific goals and objectives for the Channel Islands Marine Protected Areas;
2. establish terms and conditions for monitoring and evaluating the MPAs adopted, including a vessel of opportunity status for collaborative research involving fishermen;
3. require an annual status report to the Commission and a set period for conducting a comprehensive re-evaluation of the Channel Islands Marine Protected Areas;
4. require the monitoring and evaluation design and results to be peer reviewed (including, at the outset, developing adequate essential baseline fishery information) by marine biologists, oceanographers as well as economists.
5. provide for phasing-in of the MPAs to allow for a) community consensus; b) Federal element; and c) network with MPAs established under State process;
6. adopt a policy protocol for interagency integrated management with MOU established defining decision making and data management; and
7. appoint an Implementation Team of stakeholders (including fishery participants) to work with the Department and Commission in undertaking baseline studies (see 4 above) necessary to evaluate the MPAs, designing the analysis needed to determine the environmental, social and economic effects of MPAs, and to assist with periodic status reports.
PCFFA and its members look forward to working with the Commission and the Department in the establishment of scienfically-based MPAs for the Channel Islands and their implementation. Thank you for your consideration of these comments.
Sincerely,
W.F. “Zeke” Grader, Jr.
Executive Director