MLPAI Final Statements and Comments

[edsofish]

I have recently sent this to the Commission. Its content may be helpful in formulating your own letters.

All the Best and Good Fishing to all.


To all California Fish and Game Commission Members


Hello, my name is Ed Tavasieff; I am a commercial fisherman who has fished the waters of California for over 40 years. I own a small fish company called California Fresh Fish and hold the position of secretary for the Fishery Enhancement and Research Foundation.

For the past several years I have also held the position of stakeholder for the North Central Coast (NCC) portion of the Marine Life Protection Act Initiative. (MLPAI) I worked closely on several proposals representing local fishing communities comprised of commercial rockfish fishermen, commercial halibut fishermen, private land owners, recreational steelhead fishermen, commercial urchin divers, commercial salmon fishermen, commercial crab fishermen and individuals with strong interests in protecting California’s natural marine resources. I also met Mr. Ben Sleeter, another NCCRSG member, who is a prominent representative of the recreational fishing sector.

Ben and I, were able to bridge significant differences found between commercial and recreational viewpoints and working collaboratively, across all interests, were able to create proposal 2/XA based on the Goals and Objectives of the Act, the guidance from the Science Advisory Team (SAT), the Blue Ribbon Task Force (BRTF), the Dept of Fish and Game (DFG) and the needs of our constituents.

Other stakeholders worked very hard on different proposals but were unable to fully conform to the guidelines set forth by the Act. These other proposals, including the Integrated Preferred Alternative (IPA), do not provide adequate protection, or habitat representation for valid scientific evaluation of the “networking effect” of the Marine Protected Areas being proposed. Only proposal 2/XA meets these requirements with no gaps in 0-30 meter soft bottom habitat and Sandy Beach at the BRTF accepted Mod-High level of protection. If science is to be recognized as the basis for MPA’s, then this element cannot be ignored in the final decision.
Other elements of the Act have also been addressed in the 2/XA proposal that are missing in the IPA and other proposals. One such element is the over use of nonessential MPA’s. Commissioner Richards had asked the question of whether or not the removal of Sea Lion Cove would affect the size and spacing of the IPA proposal. In fact, removing Sea Lion Cove, Saunder’s Reef, Del Mar, Salt Point, Russian River, Duxbury, and the North Farallon Islands MPA’s would not affect size and spacing in the slightest and still conform to the Act. Also, remember, the BRTF guidelines for creating MPA’s were specific stating; Very High, High, and sparing use of Mod-High “levels of protection”, in the “preferred” (18 sq. mile vs. 9 sq. mile) size range would be the standard of acceptance for their evaluation. I mention this because SAT “minimum” guidance only calls for the use of the” (9 sq. mile) MPA’s with appropriate habitat representation and spacing.
The Stewart’s Point MPA developed in Proposal 4 and adopted into the IPA, encompasses 28.52 sq. miles; this area is over half the size of the city and county of San Francisco. (46.7 sq. miles) This extreme approach to MPA design blatantly disregards the needs of local user groups and the communities that depend upon them for their livelihoods. This approach also ignores one of the Goals and Objectives the RSG and BRTF agreed upon when laying out the working framework for the NCCSR. If there were no other alternative then we would all have to agree and move on. However, the alternative found in the 2/XA proposal for this sub region, actually has 100% support by user groups and local communities. I refer to the Black Point cluster. (19.5 sq. miles) The Sea Ranch Association, where this proposed MPA is mainly located, welcomes the Black Point cluster; a rare request.
Goal 5 Objective 1 states; “Minimize negative Socio-economic impacts and optimize positive socio-economic impacts for all users, to the extent possible, and if consistent with the Marine Life Protection Act and its goals and guidelines.”
As I stated, local fishing communities have played a significant role in the creation of proposal 2/XA. These local communities depend on every square foot of area to maintain viable livelihoods. So, every square foot Included in an MPA will have an impact. That said, consider the impact of any proposal and you realize there is significant socio-economic impact to every fishing community from all proposals including 2/XA. The Ecotrust survey provided you with figures that represented a portion of the commercial fleet in the North Central Coast Study Region (NCCSR).
The difference in economic impact between proposal 2/XA and the IPA is 1.5% or $129,282.00; with the IPA claiming the most negative impact. For struggling fishermen this is directly off the bottom line, after expenses. This hurts even when spread among all the participants in the survey. Proposal 2/XA has the least amount of overall socio-economic impact and conforms to Goal 5 Objective 1 and will not unnecessarily impact California citizens who contribute to the economy of this great State as well as provide fresh local seafood.

Commissioner Gustafson made a comment about the “less than claimed” nature of the socio-economic impacts that occurred in the Channel Islands. The fact is, several shops did, in fact, go out of business but most importantly one must realize the population that had previously frequented the Channel Islands sites had since shifted their efforts to the mainland shores. This fact will become evident in your next deliberations in the South Coast Study Region, and you will then understand what I am referring to.
When you tally the effective (Mod-High and above) area differences between proposals 2/XA and the IPA, you realize the differences are numerically small; 3.5 sq. miles of geography at the BRTF allowed Mod-High level of protection. However, one alarming element contained in the IPA is the large difference in area below the BRTF allowed Mod-High “level of protection”; 16.7 sq. miles of area that does not meet the guidelines set forth by the Act or guidance from the BRTF itself, is included in the IPA compared to 4.1 sq. miles in the 2/XA proposal. What this unnecessary area does is unnecessarily exacerbate the total socio-economic impact to local fishing communities without adding any meaningful ecosystem protection. It also complicates enforcement and compliance for everyone and is in direct conflict with the Goals and Guidelines.
I have spoken to you several times, during Commission meetings, about 2/XA and the MLPAI, and have to the best of my abilities attempted to voice the interests and concerns of those who I represent. I am at a loss as to what else I can do or say to provide you with the message from all of us who support the 2/XA proposal and its ecological merits above all other proposals. So, in closing I will leave you with this; we are not asking you to “give” us anything other than a fighting chance to maintain viable livelihoods for commercial and recreational communities that have traditionally utilized the marine resources of California in a manner consistent with the best interests of the resources we pursue. We believe the 2/XA proposal is the best possible solution to give us the fighting chance we need while providing meaningful protection and scientific study opportunities called for by the MLPAI.
Thank You
Ed Tavasieff


NOTE:
The 2/XA proposal should NOT be construed as a fisherman versus politically based environmental group issue. Proposal 2/XA is, a proposal intentionally designed using the “best readily available science”, the guidelines provided to the RSG by the SAT, BRTF, and DFG, the Goals and Objectives of the Act, and Master Plan framework. No other proposal can make this claim, not even the IPA.
That said, the Commission will be making a choice between a science based proposal, 2/XA, or a politically based proposal, the IPA.
In past fisheries management, good management frameworks have been disrupted with political agendas that ultimately cause the management decision to fail in real time outcomes. The resources will always take the negative impact of these decisions and it is time to change this direction and go for science and common sense management.
Understandably, any choice, other than the IPA, will cause debatable consequences regarding the value of the BRTF to the “process”. A choice other than the IPA will also incur some animosity from its members and cause a disturbing effect process wide. However, it is just this kind of event that has caused previous good management plans to fail by choosing politics over science. It is time to recognize science and its importance in successful fisheries management. Even though the science is weak in the process, it is on the road to becoming more informed as data is collected and analyzed through monitoring. The information gathered during monitoring will provide the critical elements for adaptive management and will play a key role in fine tuning the best possible solution for California’s fisheries management. The use of MPA’s, in this magnitude, is new to California but offers tremendous opportunities for the scientific community to further their understanding of our unique and valuable ecosystems. So it is time to let the best proposal that uses the “best readily available science” have a chance to be used in this modern fisheries management event, the MLPAI. 2/XA is the only proposal available to you, the Commission, which realizes and is based on science in the North Central Coast Study Region, as proven in its evaluations.
Let’s do what everyone has asked for, and the Act requires, and make 2/XA the starting point solution for meaningful ecosystem protection and a model for all of California’s ecosystem management.

[zimo]

Well written Ed,
I hope this group understands the negative social and economic consequences of not implementing 2XA. You would think common sense would prevail. Lets hope it does

[Mark Chow]

Thanks Ed,

You letter help me better understand the current arugements for the 2XA model too.

Perhaps, a question I would love to have answered, for instance, would be WHY the Stewarts point IPA proposal from Propsal 4 is more favorable, and why 2XA is NOT in favor...WHAT ARE THE WEAK POINTS the decision makers are looking at...

Actuaually, that is my question ALL ALONG, what are the reasons why and why not.

Again,

Many thanks!!

Mark

[Matt Plut]

Hi Mark,

2/XA does not have a weakness. The real issue is political vs. scientific. The IPA is a feel good choice politically and 2/XA is a superior choice scientifically.

Great letter Ed. The "note" at the end is the icing on the cake.