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So what general public comments do we want to make group?!?

819 Posts
Copied from a thread 2 months ago:

What do you say to this group to defend your right to fish? Here are a few ideas:
  • All fishing sectors have been incrementally constrained for the last 15 years. This has happened generally as well as specific to groundfish. The commercial groundfish trawl sector has been reduced to accessing only 25% of its former fishing grounds. In addition, all commercial groundfishing is restricted to no fishing inside the Rockfish Conservation Area. This RCA is one of the largest MPA’s in the US. It stretches from Canada to Mexico.
  • Recreational groundfishing is for the most part constrained to state waters (inside of 40 fathoms). State waters are all there is left for charters and small boat fishermen.
  • The fishery management agencies are doing a fine job as there is sustainable fishing occurring. Reserves will not help the fishing community.
  • Wave generation parks are coming that will create large de-facto no-fishing reserves. These areas are likely to be closed to all forms of fishing.
  • Marine reserves will likely be the final straw for some fishery dependent communities and businesses.
  • The survival of fishery support infrastructure (boatyards, marinas, marine supplies, ice plants, bait and tackle shops, etc.) will be in doubt if fisheries are constrained much further. If large capital investments are lost they are not likely to return in the near future even if fishing quotas increase.
  • Marine reserves should be created only with stakeholder trade-offs in mind. Fishermen are being asked to give something up. That they get something in return should be a requirement. Artificial mitigation reefs could be one solution. Locating reserves in areas where historically little or no fishing has occurred is another. Mitigation funding should be required for fish studies including barotrauma survival research for example. In other words invest in helping fisheries instead of shutting them down.
  • What is the problem that reserves will address? There is no scientifically demonstrated problem that exists.

819 Posts
Fishery representation at these meetings is important. The more we have the greater the problem for reserve advocates. This is illustrated in this Oregon Shores Coalition (enviro group) email bulletin dated 9/9. Below is part of the bulletin relating to OPAC/marine reserves. I underline for emphasis.


Oregon’s Ocean Policy Advisory Council (OPAC), the appointed group that advises state government on marine issues, is meeting in Pacific City Sept. 24-25. This is an opportunity not only to learn more about ocean issues and listen in on policy debates, but also to voice your opinion on such concerns as marine reserves and wave energy. The meetings are taking place at Pacific Coast Bible Church, 35170 Brooten Rd.

On Monday, Sept. 24, OPAC’s working groups will meet, with the Marine Reserves Working Group meeting 9:30 a.m.-2 p.m., followed by the Wave Energy Working Group meeting 2:30-6 p.m. These meeting don’t afford public comment periods, but do provide an opportunity to learn a great deal about these issues. There will also be a social event at 7 p.m. at the Pelican Brew Pub, 33180 Cape Kiwanda Dr., which might be an opportunity to buttonhole OPAC members.

The full OPAC session will be held Tuesday, Sept. 25, 8:30 a.m.-5 p.m. The draft agenda shows a report on wave energy (by Robin Hartmann, Oregon Shores’ ocean program director, who heads this working group) at 9:30 a.m., and the report by the marine reserves working group at 10:15.

There are two public comment periods. One, at 11:45 a.m., is for general comments on any topic. The other, at 1:30 p.m., is specifically for comments on marine reserves. Robin Hartmann notes that opponents of preserving key habitat areas in the ocean turn out in force at these public sessions, and urges those who care about ocean conservation to make a special effort to attend and speak up in favor of creating marine reserves for long-term protection of species and habitat.

Note that the above times are tentative. To look for updates, go to

8,541 Posts
Discussion Starter #5
It would be good to see some of you at the Meetings.

Here are some more points to bring up;

1) What is the threat, problem, or situation that is triggering the proposal for an MPA?
(The scope of any proposed action must be appropriate to the defined problem)
Describe the affected resource/species.

2) What is the current status of the resource and what is the desired future status (goals and objectives) that will result from the proposed management action? Over what period of time is the resource expected to move from the current status to the desired future status?

3) What are the specific goals and objectives identified for the proposed affected area (including the anticipated time periods over which the goals and objectives will be acheived)?

4)Is the scientific information sufficient to determine need and an appropriate response?
>If not, what research is needed to complete the picture before a decision is made regarding the resource? And as corollaries: what funding is necessary to perform this research? Who should undertake it? Who are the appropriate partners?

5) Which Marine Resource(s) is targeted by the researchor recovery propoasl?
> As corollaries: What are the identified factors for decline? Will it lead to means for recovery? Will it be on-the-ground gathering of empirical evidence or will it be use of models?

6) How does this proposal fit in with harvest management plans and habitat management plans (for upland, nearshore and deepwater areas) related to the target resource?

7) What other alternatives, voluntary or regulatory, will achieve the same goals and objectives (identified in response to question #2 above) with less impact on Coastal Communites?

8) How will progress be monitored and "success" be measured? Who will conduct these monitoring and evaluation activities?

9) How will adaptive management be utilized to modify the goals and objectives of the MPA?

10) Who are the parties that make the decisions? On what basis?

8,541 Posts
Discussion Starter #8
Since there is not going to be a public comment period at the Working Group (WG) Meeting it would be good for you to attend Tuesdays Meeting if you wish to give Comment. The conent of the WGs Meetings will be gone over on Tuesday and it looks like there will be some interesting discussion too.

8,541 Posts
Discussion Starter #10
I am on my way. Hope to see some of of the Dogs there.

22,364 Posts
I could not get away today or tomorrow. However I have written some letters to the powers that be (not that they make a hoot of difference). Thanks for going Walter.

20 Posts
Thanks, Walter and John-

There's an easy way to voice your concern about these no-fishing zone proposals-

Click here to send 5 decision makers an email... all in 1 step...


We all owe it to ourselves to get involved, even if it is only on the letter-writing front.

You benefit when politicians hear from you.

22,364 Posts
Thanks, Walter and John-

There's an easy way to voice your concern about these no-fishing zone proposals-

Click here to send 5 decision makers an email... all in 1 step...


We all owe it to ourselves to get involved, even if it is only on the letter-writing front.

You benefit when politicians hear from you.
Been there Done that Jim. Thanks for the refresher on the action notice we can suscribe to. Easy!

8,541 Posts
Discussion Starter #15
I will say that I was unable to attend the full Meetings on either day. John H was there for the full day on Mon. and most of the day on Tues.

Mon. MRWG 9/24

The meeting was well attended. Kudos to the Pacific City Dorymen for sending great reps and providing DVDS and History of the 107 year Heritage of Doryfishing in Oregon. There were a good # of current and former elected Coastal Officials, commercial and recreational fishermen, local residents and Reserve Proponents.

The main points of the meeting were working on the Nomination Document, MR Policy Reserve Guidance. There was also a report from the Science and Technical Advisory Committee(STAC).

The STAC Report from stated a few things.

- The most important I see is that they reaffirmed their position as "advisory" only. Some of the members saw that there was going to be a possible conflict of interest if they were to be involved in advising and possibly helping with implementation of MRs. They wish to operate independently and separate from OPAC.

- They highlighted the need for commitment of personnel and funding, stakeholder and community involvement, education/outreach and including Wave Energy Farms with MRS.

- Set protocols for how the Group was to be contacted, addressed how members were to portray or represent themselves when giving giving comment.

I apologize in that there was a Public Comment period. I and John gave or comments and broke for lunch.

The next session focussed on the Policy Guidance Draft.

I am sorry that I missed this part but John will be able to fill in the blanks.
As nit picky and petty as it may seem some of the proponents o MRs found issue in the Policy Documents with the definition of an MR.

From the Draft;

A Marine Reserve is an area within Oregon's territorial sea that is permanently protected from all extractive activities, including removal or disturbance of living and non-living marine resources, except as necessary for monitoring or research to evaluate reserve condition, effectiveness or impact of stressors such as climate change.

It appears that some of the MR proponents saw that their activities might be construed as "disturbance" in this form, agrued strongly for the "definition" of disturbance to be further defined. The definition that was "accepted" was that the resource had to be killed to be considered "disturbed".

Tues. 9/25 Full OPAC Meeting

I arrived @9am and missed the first part of the meeting.

The item being addressed was the 1 year time line given to OPAC to submit a Plan to the Gov. in regards to MRs. The main principle was that the Gov wanted a Plan but the OPAC members found it hard to give advice on or endorse a plan whose direction, reasons for and impetus has not stayed the same for more than 1 meeting.

Wave Energy took the next slot.

- There are some serious concerns as to what will happen to these areas before, during and after implementation. The conditions of the leases should be of great concern to all Ocean Users. The Companies could end up owning the land in some circumstances. There is a FERC Meeting in PDX in October. They are seeking to shorten the time frame for the permits.

- The was discussion on what type of Environmental Assessment was to be made by the Comps before they were to put gear in place. These permits are for 30-50 years so the long term affects should not be taken lightly.

- The # and size of the Wave Energy Farms needs to be considered before and as they are being built. All Ocean user will be affected by these Farms either by access or transport.

There will be a workshop in Newport on the Ecological Effects of Wave Energy Farms on Oct. 11-12 in Newport. The first part of the Monday Session is open to the public. Spaces are limited contact Greg Mc Murray for availability; [email protected]

After the break the Topic was the Update on MR Planning;

A report was given on the previous days meeting and what was proposed.
I apologize firsthand for not being able to give a more accurate account for 2 reasons, 1 personal and 1 complexity and flow of conversation. I ask those who were also in attendance to add their comments.

-There was some good discussion and many good points were brought up reagrding these issues. To sum it up best there is a need for a concise, clear and simple message needs to be put out to the Public regarding the MR issue.

- The second reason for my less than stellar account of the procedings had to do more with my personal issue with this whole process. First off I want to endorse OPAC and the MRWG for their efforts on MRs. The OPAC members have made every effort in their power to make this process as fair and transparent as possible. I was not at the last part of the MRWG meeting on Mon and when I heard that almost an hour of the MRWGs time was wasted on the definition of "disturbance". I was disturbed (but not lethally). The members of this Ocean User group were more than happy to go along with Reserves as long as it did not affect them but raised bloody heck when their access to the Ocean might be possibly restricted due to their "disturbance".

During Lunch a presentation on Current Oceanography Observing Systyems.
Using current and developing technologies there seem to be more and better ways to monitor the Ocean Health.

After lunch Public Comment was scheduled.
- Instead the presentation from a privately funded group of "stakeholders" who has been working on a "Consensus Statement on Marine Protection" gave a presentation. The presentation was good but the underlying theme was that MRs and MPAs were the "answer". Most of scientists in this group were supporters of MRs and had much to gain from the implementation of MRs in OR. One in particular was instrumental in the design and implementation of the MLPA in CA. Unfortunately there was no mention of existing management practices or its successes. The only consensus that I could determine from the presentation, that could be derived was that some form of protection was good and that the process to find concensus was difficult at best. When the list of persons in this group was disclosed I was somewhat amazed at the "message". I am positive that Linda Buell, Jim Martin and Frank Warrens did not share many of the views in regards to this group.

From Jim Martins statements in USAToday

"Jim Martin, a former Oregon chief of fisheries now working for a tackle industry group, the Berkley Conservation Institute, is wary of marine reserves, saying they cannot protect fisheries and habitat any better than existing controls. Those include limiting fishing seasons and bag limits, and controlling fishing for one species, such as rockfish, while allowing fishing for others, such as salmon and crab.

We are worried about the governor doing something for essentially a political gesture that may or may not be grounded in good transparent science," Martin said."

While this group may tout a concensus, I would say that it does not not necessarily portray the views of all the members.

It was pointed out by OPAC Members that there was no representation from elected Coastal officials or much representation from commercial and recreational fishermen.
C&P from a MR Proponents Site:


1. Our goal is a healthy ecosystem that provides services and values to humans.

2. Challenges to ocean health include:
a. Global warming;
b. Habitat destruction;
c. Over-exploitation;
d. Invasive species;
e. Pollution, including authorized uses of pesticides and herbicides;
f. Synergistic and cumulative effects, including those due to land-sea connections, such as coastal development, altered water regimes, diking, road building and agricultural and timber practices.

3. The reasons for uncertainty in ocean resource status include:
a. Environmental variability: seasonal and decadal variation, as well as directional change due to global warming, and impacts of these changes on marine life;
b. Uncertainty in abundance of stocks which are either not surveyed or lack sufficient assessment data to adequately determine stock status;
c. Inadequate funding for conducting stock assessments and ecological monitoring;
d. Inadequate evaluation of the efficacy of management measures

4. Marine Protected Areas including marine reserves may be useful tools to accomplish the following:
a. Preserve genetic, age, and spatial structure of populations;
b. Act as reference areas to measure impacts of fishing outside the protected area by inside vs. outside comparisons;
c. Provide refugia to maintain biodiversity;
d. Protect seafloor habitats from human-caused disturbance;
e. Provide relatively intact ecosystems, which are known to be more resistant and resilient to environmental variability

5. The tool (for example, marine reserves or marine protected areas) is not the goal.

6. We support precautionary management principles. Precautionary management involves the application of prudent foresight in ocean resource management, including fisheries management, characterized by:
a. Fisheries that are sustainable and management that considers needs of future generations;
b. Knowledge of undesirable outcomes is identified and measures are in place to avoid them;
c. Avoidance of actions that may not be reversible;
d. Management that gives priority to conserving productive capacity if impacts are uncertain;
e. Fishing capacity is restrained when impacts to resource productivity are highly uncertain;
f. Use of a framework plan that establishes reference levels for the fishery and appropriate actions when reference levels are achieved or exceeded;
g. In addition to the above FAO guidelines, we characterize precautionary management as adaptive and sensitive to needs of communities.
h. Alternatives to present management should be explored which provide more flexibility to achieve resource, habitat, and ecosystem conservation goals ;
i. In addition, precautionary and adaptive management includes evaluation of past and proposed actions.

7. Based on the available evidence, we perceive the state of Oregon and West Coast marine fisheries, ecosystem and fisheries management to be as follows:
a. Status of marine fisheries:
i. Healthy for some species: Dungeness crab and ocean shrimp are
good examples.
ii. Oregon terrestrial and adjacent ocean environments are host to 22 marine species of fish, birds, reptiles, and mammals listed as threatened or endangered under the federal Endangered Species Act. Ten of the listed species include threatened stocks of salmon and steelhead. Of these, 3 stocks of Chinook salmon and 2 stocks of Coho salmon are of particular concern and influence shaping of ocean fishing seasons and limits for salmon. Three bird species (brown pelican, marbled Murrelet, and snowy plover) receive special management attention in the nearshore due to their status. Of the 4 mammals in this group, the northern Stellar sea lion also receives special management attention in Oregon’s nearshore coastal waters.
iii. A mixed score exists for groundfishes. There are more than 90 exploited species of groundfish, of which 32 have been assessed. Overfished groundfish species presently constitute about 8% of exploited groundfish species (22% of assessed species. Specifically:
1. Of 7 over-fished rockfish species, canary rockfish appears not to be responding to management measures, but a new assessment is underway. Based on the most recent rebuilding analysis, yelloweye rockfish is also behind on its rebuilding schedule and optimum yield has been accordingly reduced. Both canary rockfish and
yelloweye rockfish are important nearshore and shelf species of the Oregon coast. Federal rebuilding management policies have signicant impact on fisheries in state waters as well. Boccacio, widow rockfish, and darkblotched rockfish have definitely turned around and are rebuilding.
2. The Dover sole, thornyhead, sablefish complex (including blackgill rockfish) appears to be
healthy, although sablefish is at a low enough level to be managed under the Council’s pre-cautionary 40:10 rule.
3. Lingcod has been rebuilt and several species of flatfish appear to have robust populations.
4. Hake, a major offshore fishery, may have to have harvest reductions due to the lack of recruitment.
5. Little is known about the status of many stocks, especially nearshore species.
iv. Remaining fisheries are of unknown status.

b. Status of marine ecosystem:
i. Uncertain due to:
1. Lack of monitoring:
a. Bycatch, while partially monitored, lacks a long-term plan for prevention other than RCAs;
b. The abundance and distribution of non-target fishes, invertebrates and plants species are not well monitored.
2. Lack of assessments:
a. Few stock assessments have been completed (8 of 42 nearshore species in Oregon assessed);
b. Few biodiversity surveys assessing spatial distribution of both target and non-target species have been conducted;
c. Few comprehensive maps exist for seafloor habitats.
3. Environmental variability and global warming;
4. Unknown long-term effects of pollutants;
5. Dead zones;
6. Invasive species;
7. Lack of protection for low-relief seafloor habitats.

c. Status of fisheries management:
i. Improving due to EFH amendment and changes in Magnuson-Stevens Act;
ii. Improving due to recent ecosystem-based initiatives by the Pacific Fishery Management Council, including a ban on krill fisheries and formation of an Ecosystem-Based Fishery Management Subcommittee of the Scientific and Statistical Committee.
iii. Improving through the use of initiatives to ‘market’ sustainable fisheries using sound ecosystem-based management principles;
iv. In need of improvement due to:
1. Lack of international controls or the application of ecosystem-based scientific methods and precautionary management techniques; 2. Need for more flexibility to manage limited resources;
3. Need for greater implementation of ecosystem-based approaches, including spatial management.

8. In Oregon’s nearshore, the Oregon Ocean Resources Management Plan and the Oregon Territorial Sea Plan, including Goal 19, direct that management should "conserve marine resources and ecological functions for the purpose of providing long-term ecological, economic, and social value and benefits to future generations."

9. Therefore, we support:
a. A healthy ecosystem;
b. Adaptive management with local flexibility, including community-based management;
c. The identification of important ecological areas within Oregon's coastal and marine ecosystem, the identification of threats to those areas, appropriate management measures to conserve those areas, and monitoring and evaluation of those management measures;
d. Use of tools which may include Marine Reserves and Marine Protected Areas:
i. To protect living marine resources and their seafloor habitats;
ii. To protect the genetic, age and spatial structure of species, especially long-lived species known to require older age classes to maintain reproductive capacity;
iii. To protect natural and cultural heritage sites and to maintain biodiversity;
iv. As reference areas to evaluate external management actions;
v. To provide relatively intact ecosystems, which are known to be more resistant and resilient to environmental variability and change.

e. A process for the investigation of marine reserves that includes the following:
i. Encourages the involvement of coastal forums or community councils. Community councils should be small in geographic scope (i.e., port by port) and diverse in representation, including the fishing industry, government agencies, environmental organizations, universities, independent scientists, other interest groups;
ii. Local knowledge about resource abundance and distribution, collected and consolidated using GIS technology. Data should be validated and valued for use in planning processes;
iii. Funding made available for councils and other legal authorities to assess and monitor actions and activities.
(f) An approach which includes and addresses the threats by coastal and upslope impacts to healthy marine ecosystems.

Signed by:

Cheryl Coon, Audubon Society of Portland
Jim Martin, Berkley Conservation Institute
Pete Stauffer, Surfrider Foundation
Frank Warrens
Peter Huhtala, Pacific Marine Conservation Council
Linda Buell, Garibaldi, Oregon
Ben Enticknap, Oceana
Liz Hamilton, Northwest Sportfishing Industry Association
Dr. Mark Hixon, Department of Zoology, Oregon State University
Jim Golden, Golden Marine Consulting
Bob Rees, NW Guides and Anglers Association
Mark Lottis, Five Star Charters, Gold Beach, Oregon
Jeff Feldner, fisherman, Newport, Oregon
Dr. Kirsten Grorud-Colvert
Bob Jacobson, fisherman, Newport, Oregon
Greg Harlow, Association of Northwest Steelheaders
Carolyn Waldron, Oregon Ocean
Laura Anderson, small business owner, Newport, Oregon
Leesa Cobb, Port Orford Ocean Resource Team

Public Comment regarding MRs followed.

I would like to ask all the others in attendance to. Post their Views and Observations

20 Posts
Whenever I buy a fishing license in Oregon, I feel like I need to say,

"I'm not THAT Jim Martin." He used to work for ODFW.

But I agree with his statement in USA Today...

1,662 Posts
Salty Walty ...

As always, an outstanding post of the info - thanks to you, John and others for making the time to attend, and for your report.

Re the below portion of your post - please clarify the dates, or day of the week, (Oct 11-12, 2007 is Thursday-Friday, however, you mention a "Monday Session".)

There will be a workshop in Newport on the Ecological Effects of Wave Energy Farms on Oct. 11-12 in Newport. The first part of the Monday Session is open to the public. Spaces are limited contact Greg Mc Murray for availability; [email protected]

8,541 Posts
Discussion Starter #19
Sorry for the confusion. I will contact Greg and see if I can get it cleared up.
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