January 30, 2002
Ed Ueber, Sanctuary Manager
Dear Mr. Ueber:
The Sierra Club – Marin Group, representing its 7,000 Marin County members, offers the following comments on the Gulf of the Farallones National Marine Sanctuary (GFNMS), Cordell Bank National Marine Sanctuary Management (CBNMS) and Monterey Bay National Marine Sanctuary (MBNMS) Joint Management Plan Review.
Move the GFNMS boundary further south to incorporate
the entire Marin coast
The Sierra Club believes
strongly that all three Sanctuaries should be managed separately, and not
collapsed into one large Sanctuary. As noted in the January 7, 2002 letter
from the Bay Area Congressional delegation to the Director of the National
Marine Sanctuary Program, “each sanctuary has its own identity, history,
and unique attributes which should be reflected in its management.”Since
each Sanctuary is unique, the boundaries between them should reflect the
character of each appropriately.Unfortunately,
the current location on the Marin County coastline where the northern MBNMS
boundary meets the southern GFNMS boundary is simply an accident of legislative
expediency.That current GFNMS southern
boundary bears no relationship to any marine ecosystem boundary, nor to
any political boundary, nor to any Coast Guard operational boundary, nor
to the range of the local fishing fleets, nor does it contribute to the
ability of any Marine Sanctuary to manage its resources, nor does it assist
users of the Sanctuaries to easily determine what regulations are in place.The
map of the Sanctuaries indicates the illogic of the current boundary, which
has over 95% of Marin’s coastline in GFNMS, but a tiny piece in MBNMS.The
Marin coastline is clearly part of the Gulf of the Farallones, not Monterey
Bay.The Farallones Islands can clearly
be seen close offshore the Marin coastline; Monterey Bay is a four-hour
drive. The Club strongly concurs with the Resolutions passed by the Supervisors
of Marin County, San Francisco County, and San Mateo Counties which outline
the biological, political, and operational reasons for moving the GFNMS
boundary south so that the entire Marin coastline is included in Gulf of
the Farallones National Marine Sanctuary.
Move the Sanctuaries’ boundaries further west,
away from the Marin coast
The Sierra Club is also concerned that one of the basic intents of the Sanctuaries to protect against offshore drilling may be subverted by new deep water drilling techniques.The areas downslope from the continental shelf just past the seaward western edges of the Sanctuaries, particularly where the Sanctuary boundaries come together, contain increasingly viable oil tracts.An oil spill from a drill rig just past the Sanctuary boundary would foul the Marin coastline and create huge impacts on one of the most rich biotic communities in the world.The Club believes strongly that the western boundaries of the Sanctuaries must be moved further off the Marin coast.
Further reduce the potential for toxic releases
along the Marin coast
The Sierra Club – Marin Group believes that shipping lanes along Marin should be moved further offshore, to protect our coastline from potential oil spills.Additional tugs should be required for ships in shipping lanes near the shoals off southern Marin outside the mouth of the Golden Gate.Although the Sanctuaries off the Marin coast were established to protect us from oil drilling, winters often bring “mystery” oil spills that kill thousand’s of birds.The Sierra Club concurs with the opinion of the Coast Guard that the likely sources for these spills are underwater shipwrecks still containing oil.Funding should be sought for underwater surveys to determine possible sources and remedies for the leaking oil.At the same time underwater ships may be leaking oil, currently operating boats can often be seem in the Sanctuary floating in the center of a sheen of leaked diesel.It is common in mooring areas to see birds preening and ingesting feathers that have become fouled with this oil. The Sanctuaries should expand their enforcement against fuel-leaking vessels.A buy-back program should also be instituted for old two-stroke engines that would lead to an eventual ban on these polluting motors within the Sanctuaries off the Marin coast.Lastly, funding should be sought for a mapping, monitoring, and if required, remediation of the radioactive releases from the Farallones Island Nuclear Waste Site.
The Sanctuaries should play a key role in management
of Marin coastal fisheries
The public’s biggest misperception is that the Sanctuaries protect fisheries, when in fact the National Marine Fisheries Service protect fisheries in federal waters and California’s Department of Fish and Game protects those in state waters.The Sanctuaries protect only marine habitat, nor marine creatures.But the public perception that the habitat and its inhabitants are inseparable is supported by science and should be reflected in management practices.The Sanctuaries should share in fisheries management inside the Sanctuaries off the Marin coast to provide for sustainable fisheries. The Sanctuaries should use conservative management tools capable of dealing with the uncertainties of fish populations.Key among these should be Marine Life Protected Areas where prohibited or restricted take will create nurseries for sustainable fisheries.Bottom trawling, except on designated open sand bottom areas, and all other habitat destroying fishing practices, should be banned inside the Sanctuaries.Fishing practices with large by-catches, such as long-line fishing and gill netting should be banned, as should the Navy’s low frequency sonar, now known to injure and disorient marine mammals.Also banned should be chumming to attract sharks for recreational viewing.
Work towards control of non-point source pollution
from Marin coastal areas
Many studies have shown impacts from non-point source pollution on marine resources.The Pew Oceans Commission report on Marine Pollution notes that Tomales Bay is of the 44 estuaries in the US with high levels of eutrophication, and Tomales Bay has been declared as “impaired” by the US EPA for both sediment and nutrients.The Sierra Club believes strongly that GFNMS must develop programs to support proactive efforts in Marin County to adhere to the Clean Water Act, and step up monitoring and enforcement actions to encourage continuing progress toward solving these problems.
Control introduction of exotics to Marin coastal
areas
Although most other types of discharge fall under the jurisdiction of the Sanctuaries, perhaps the most dangerous is that from ships’ ballast water because it introduces invasive exotic species into out native marine habitats.Both Bolinas Lagoon and Tomales Bay have significant infestations of non-natives.Although ballast water is not the only way these exotics are transported, recent technological advances may make it feasible and safe to eliminate organisms from ballast water prior to its discharge.Those techniques should be required in the Sanctuaries to protect Marin’s coastal resources.
Control boating-associated impacts to Marin’s natural
and cultural resources
Jet ski’s are banned in Marin County waters and in GFNMS, but not in CBNMS, nor in MBNMS.Rules along the Marin coast should be consistent in banning jet skis.Jet ski’s are permitted inside Bodega Bay, just outside GFNMS, but they regularly cross the boundary to wave jump in Sanctuary waters.This is an area of high bird and marine mammal use, where gray whale calves feed and threatened Stellars sea lions haul out.Likewise, boats in Bodega Bay surrounded by leaking diesel must inevitably make use of Sanctuary waters.The Sierra Club believes there should be increased education and enforcement to prevent these activities in Bodega Bay from impacting the Sanctuary just outside.Kayaks have brought human presence to formerly inaccessible parts of the Marin coast, as well as to open water areas where wildlife concentrates. The Sanctuary should determine if no-boat-access buffer areas should be established and enforced to protect sensitive resources.GFNMS should evaluate the day-use and live-aboard moorings in Tomales Bay for compliance with Sanctuary regulations.
Expand Sanctuary outreach and enforcement activities
along the Marin Coast
The Marine Sanctuaries off Marin are chronically under-funded, both in regard to their responsibilities and in comparison to other Marine Sanctuaries.Nevertheless they have done an effective job in education and protection, given their limited resources.Marin County is has the unusual situation of having much of its ocean coastline protected as National or State Parks.That high level of protection and stewardship on the landward side of the Marin coastline should also be reflected on the ocean side.
Sincerely,
Gordon Bennett, Sierra Club – Marin Group Conservation Co-Chair