07/08/2016
And here is another letter opposing the use of the Monument Designation route to enact fishing regulations without an open public process. It would be great if some of you would write similar letters.
July 7, 2016
Christy Goldfuss
Managing Director
White House Council on Environmental Quality
722 Jackson Place, NW
Washington, DC 20503
Dear Director Goldfuss,
California’s 1.7 million anglers support conservation and fishery management programs that are science-driven, transparent, and created with meaningful stakeholder input. These anglers are not only tremendously important to the state’s economy, but also are leading conservationists. Through fishing license sales and the excise tax on sportfishing equipment, anglers in the state contribute tens of millions of dollars annually to fisheries conservation; not to mention their personal commitment, volunteering countless hours for fisheries restoration projects. Anglers are more than willing to make sacrifices to fishing opportunities in order to rebuild fish stocks or protect sensitive habitat. However, we oppose fishery restrictions that are unwarranted and not based on sound fisheries science.
It is with that in mind that we wish to express our serious concerns about the proposed marine monuments outlined in the recent anonymous flyer titled: “The Case for Protecting California’s Seamounts, Ridges, and Banks.” This proposal has been advanced without seeking any input whatsoever from the largest marine user groups, recreational and commercial fishermen. While the proposal states, “[r]ecreational activities would continue throughout the network,” the lack of a public rulemaking process by which monuments are designated creates significant uncertainty about how decisions, such as recreational fishing restrictions, will ultimately be made.
The areas identified in the proposal are indeed special places – they are rich in marine life and support valuable corals, sponges, and structures. You will not get any disagreement from millions of conservation-minded fishermen that these areas are deserving of protection from damaging activities. However, such protection should be developed through an open public process, driven by specific scientific and resource-protection objectives, with all stakeholders at the table.
A public regulatory process, open to all stakeholders and guided by science, already exists through the Magnuson-Stevens Act (MSA) administered by the Pacific Fishery Management Council (Council). Following a public process with participation by all stakeholders, the Council implemented regulations to protect these seamounts as Essential Fish Habitat (EFH). Under these regulations, the seamounts are well protected from harmful fishing practices. All stakeholders had a say in defining the EFH designations and the special protections associated with areas designated as Habitat Areas of Particular Concern.
Because these areas – except for the Cortes and Tanner Banks – are thousands of feet below the surface of the water, they are in no danger of interactions from recreational fishing gear. Because of their great depth, no recreational fishing gear can interact with the bottom structure and organisms, thus recreational fishing has no impact whatsoever on the habitat that proponents of this proposal are seeking to protect.
Recreational anglers do target the fish that reside well above, or pass through the top of the water column above these iconic places; that is why these areas are known to and cherished by the fishermen of California. Under the MSA, commercial and recreational fisheries are conducted in sustainable and controlled ways to manage the total catch and to reduce by-catch to the maximum extent practicable. Those protections are already in place in accordance with laws passed by the Congress and signed into law decades ago. Since then overfishing has been stopped on the Pacific Coast, fish populations are successfully being rebuilt, by-catch has been dramatically reduced, and Essential Fish Habitat has been declared. These MSA protections are already in place, not only for the deep seamounts and ridges but also for the shallow Cortez and Tanner Banks. Given the success of the existing fisheries management process, it is unclear to us why additional fishing regulations outside of the MSA process are appropriate or warranted.
Recreational fishing provides tremendous economic, social and conservation benefits, and can be allowed to continue in these areas while ensuring they remain as iconic, viable, and healthy ecosystems. Consequently, we strongly oppose the inclusion of restrictions on fishing practices that have a demonstrated record of being sustainably managed in any proposal to designate monument status for the iconic seamounts, ridges, and banks off of California. Should this proposal move forward, it should only do so with recognition of our region’s highly successful existing fisheries management system, and should follow an open and transparent public process with a heavy emphasis on outreach to affected stakeholders, in particular fishermen.
Sincerely,
Scott Gudes, Vice President
American Sportfishing Association
Bill Shedd,Chairman
CCA CAL
Dan Wolford, President
Coastside Fishing Club
cc: Senator Barbara Boxer
Senator Dianne Feinstein
Representative Jared Huffman
Representative Mike Thompson
Representative Mark DeSaulnier
Representative Nancy Pelosi
Representative Barbara Lee
Representative Jackie Speier
Representative Eric Swalwell
Representative Mike Honda
Representative Anna Eshoo
Representative Sam Farr
Representative Lois Capps
Representative Julia Brown
Representative Ted Lieu
Representative Alan Lowenthal
Representative Janice Hahn
Representative Lucille Roybal-Allard
Representative Dana Rohrabacher
Representative Darrell Issa
Representative Scott Peters
Representative Susan Davis
