To all OPAC
Members:
As you know, I have
not been allowed equal time on your agenda to rebut the 4Ports’
letters criticisms of the Mack Reef I proposal so I am providing
my comments to you here. I hope you will read this before
you vote on Tuesday.
First, I want to make
it very clear that the Mack Reef I proposal is NOT Our Ocean’s
proposal. Both letters address both proposals as if they are
the same, which is NOT TRUE.
I will not deal with
every misrepresentation in the letters but will focus on their
recommendations, starting with the letter from Jim
Relaford.
- Economic
Impact
They claim we had no
real information on economic impact, that we only talked to a few
fishermen and that our assumption that there wouldn’t be
significant economic impact was proven false because over 50% of
the entire catch of the crab fleet came from the proposed marine
reserve. And that was “obviously a significant economic
impact which had been lost on the nominators.” In fact, we
spoke to many fishermen and once we learned about the potential
impact to the crab fleet, reduced our no-take area by 75%.
We designed an MPA that would allow crabbing. In addition, I
learned that the crabber who made that statement at the 4Ports
meeting had been asked to participate in our group early on.
After the meeting, I emailed him, asking why he hadn’t
participated. He responded that he didn’t support marine
reserves and so didn’t think he could have been “helpful.”
Those emails are attached.
I’ve since heard from
others that the 50% claim is not true. So who is right—the
crabber and Jim Relaford or the other commercial fishing
experts? That’s the point of the 2-year evaluation—we need
the economic analysis to get to the bottom of this. If in
fact our no-take areas do close down 50% of the crab fleet, we’d
want to know and work with crabbers to adjust the
boundaries.
- Ecological and
Scientific Contribution
Both letters
demonstrate a lack of understanding of the function of Oregon’s
marine reserves. They seem to think that reserves can only
be placed in an area that is significantly damaged or depleted,
which can then be cordoned off till it recovers, at which point
you do away with the reserve. The Brookings letter states,
“There was no species identified that needed monitoring or
protecting or any pressing ecological threat. In short no
scientific or ecological reason was given as a reason for
nominating this particular site.”
We believe we did
provide excellent scientific and ecological reasons for nominating
the Mack Reef I site but we acknowledge that they aren’t the
reasons the 4Ports were looking for.
- Enforceability
Jim Relaford states
that this issue was not addressed, however the Gold Beach letter
contradicts that statement.
- and 5.
Monitoring and Termination of the Marine Reserve
It is true that these
issues were not addressed; the proposal form did not request that
of anyone.
Now the Gold Beach
letter:
Scientific Basis
The Gold Beach letter
also focuses on the necessity of having a problem to solve as the
only justification for a marine reserve. They say it is
counterproductive to commit resources to locations that are not
shown to be in need. They also state that scientific studies
have to be done before a reserve is proposed, ignoring the fact
that sites have to be identified to know where the studies should
take place.
Economic Impact
See our response to
the Brookings letter above.
Enforceability
This letter
acknowledges that we addressed this issue in our proposal
(contrary to the Brookings letter).
Monitoring and Termination
It is true that these
issues were not addressed; the proposal form did not request that
of anyone.
Community Input & Support
They claim that #7 of
OPAC’s coarse review criteria requires that proposals be developed
by collaborative community based groups comprised of entities such
as coastal counties, cities, ports, fishing organizations and
others. If you review your criteria, you will see that this
is not true.
They then go on to say
that our group was “a small hand-picked group of
environmentally-oriented persons.” I have to wonder whose
hand they think picked the group; I knew fewer than half (7
(including myself) to 9). They also say, “no local coastal
community” members. Everyone in the group was coastal;
everyone but one was local. They also say there were “no
general commercial interests.” As you know, we tried to get
4 commercial folks involved in the process and none were
willing. We did get input on the proposal from 15 or so and
tried to talk to half a dozen more. Finally, they accuse us
of excluding community input and a collaborative approach, which
will be addressed under Recommendations.
Recommendations
“No scientific
foundation suggesting a need and empirical evidence suggesting no
need” Again, they misunderstand the function of a marine
reserve. A marine reserve is useful to protect habitat and
biodiversity as well as to restore it.
“Evidence of
significant negative economic impact” This is false.
No evidence of significant negative economic impact—in fact of ANY
economic impact to Gold Beach except to a charter boat operator
who rarely goes south to Cape Sebastian—was noted. Gold
Beach sports boats go north to Rogue Reef which is why we did not
suggest a reserve there.
“No collaborative
community input permitted in the development of the
proposals” This is not true. One of the 4Ports group
members was encouraged to participate in the group but
declined. Of the five members of the Gold Beach 4Ports
group, three were asked to provide input on the proposal and two
did so. Of the five Port Commissioners whose names are on
the letter, two were asked to provide input. Neither
did.
We met with Jim
Relaford before the 4Ports group was created. When we asked
to meet with him a second time, to get feedback on our revisions
based on our earlier meetings, he didn’t want to meet again until
the 4Ports group was organized, which was after the proposal
deadline.
