Monday, December 24, 2007

Latest Maps for Pt Arena to Salt Point

The following internal proposals come from the NCC stakeholder teams. They are "convergent" proposals in that the group process required that each team to converge their proposal, other teams' proposals, and external proposals to one.

Emerald #C
Jade #D
Turquoise #C

Jade #C

Tuesday, December 18, 2007

Private Stewardship and Preserving the North Coast

Letter from Robert and Kathryn Larson, Hillside Ranch

To whom it may concern re: MLPA:

We are writing to inform you that we feel that the ocean waters from Salt Point State Park north to Black Point should be left open to shore fishing, abalone picking and diving.

This is all private land and limited access anyway. Why close these areas that are well managed by the private landowners? Because of the respect that these land owners have of the land and the sea, these areas are already "game preserves."

Our kids have been lucky enough to have been able to experience the beauty of this unspoiled land and sea. Many young people have had the opportunity to experience catching their first fish or picking or diving for their fist abalone.

We are raising and educating our kids to respect these natural resources and not abuse them. Because this area is a "game preserve" and so well managed, there are a lot of sea life to choose from. For instance we often only take one abalone because that is all we need to feed our family; and then some. The people that are allowed access to this private preserve share these same values as the landowners.

Again we question, why close something that is already managed with respect, love, and limited access. The education and respect that will be lost when youth and others are forced to experience the north coast sea world in areas that are overpopulated with people, polluted, and with limited sea life and access. They may never be able to dive in a safe place or see a large abalone or catch a fish from a small boat safely in public access areas.

We support the landowners in pleading to keep these private lands open and private from Salt Point to Black Point on the Sonoma Coast. Keep these preserves managed and allow these families to continue to educate and pass on their respect of this beautiful land that we live on and love.

Thank you,

Robert and Kathryn Larson
Hillside Ranch

Sunday, December 16, 2007

Ocean Conservancy Argues for More Marine Reserves

Following the first pass to choose Marine Protected Area proposals in Pacifica December 11 and 12, the Ocean Conservancy wrote MLPA Chair Susan Golding to lobby for more protection. For the text of their letter, see

They include two journal articles advocating Marine Reserves that are worth reading:
  • Recreational Fishing and Marine Fish Populations in California (UC Santa Barbara Marine Science Institute)
  • Why Have No-Take Marine Protected Areas? (NOAA and Key West MPA)
Both articles emphasize that no-take reserves are easier to administer because there is no question that anyone inside the reserve is suspect.

MLPA Expands to Southern California and North Coast

On December 6, California Secretary of Resources Mike Chrisman announced that MLPA will be extended south from Monterey to the Mexico border, and north from Pt. Arena to the Oregon border.

In response, Walter Ratcliff wrote the following letter to Chrisman:

December 14, 2007 Mike Chrisman
California Department of Resources
1416 Ninth Street, Suite 1311
Sacramento, CA 95814

Dear Secretary Chrisman; Last Thursday you announced the schedule for the remaining Marine Life Protection Act (MLPA) study regions. This letter is to urge you to stop further implementation until significant issues can be resolved, issues that undermine the Act’s ability to achieve its goals in the North Central Coast (NCC) and future study regions.

I represent the 14 owners of Sail Rock Ranch in Mendocino County. Sail Rock Ranch was started in 1926 by my grandfather, who was a well-known architect and friend of John Muir. It comprises 1000 acres along the coast north of Gualala running a mile along the ocean and a mile inland to the ridgeline, protecting three watersheds: Morrison, Slick Rock, and Signal Port.

We have taken conservation of the nearshore habitat seriously for three generations. And it turns out that this commitment is shared by the managers of other large parcels in NCC sub-region 1: Haven’s Neck Preserve, Sea Ranch, and Richardson Ranches.

The Sail Rock Ranch owners support the MLPA goals. However, we are concerned that the Act will fail for the following reasons:

1. Public access has clearly driven Marine Protected Area (MPA) site selection. The map below overlays MPA proposals (in pink) and public access points (yellow triangles). Note the close fit.

Nearshore marine habitats in the proposed MPAs have been protected effectively for decades by private landowners under existing law. Labeling these areas “Marine Reserves” protects what is already protected and leaves open what is already open. The only change is the MPA label. The MLPA scoring method, developed by a few members the Science Advisory Team (SAT), encourages this dysfunctional result.

2. The Act calls for each Marine Reserve to have specific objectives. This is wise considering the potential impact on livelihoods. Yet measurable objectives have been deferred. If maintaining a robust marine ecology adjacent to Sail Rock Ranch from 1926 to 2007 has not produced adequate larval dispersal “downstream,” then what difference will another 80 years make? In other words, if we don’t know where we started and don’t know where we’re going, how will we know whether we’ve arrived? Without measurable objectives, there is no basis to objectively alter the area, spacing or level of protection based on results, or to “sunset” Marine Reserves.

3. Empirical data on which to base siting decisions are absent. For example, at the December 11 Regional Stakeholder Group meeting a thesis project prepared by UCSB students was presented by MLPA staff. Local data about stocks, mortality and movement of species were absent. End points were undefined. Causation was assumed, not demonstrated. If this level of rigor was the exception, one could put it in context. Sadly, it is the norm. Lack of empirically-based theory was a critique of the Central Coast implementation, but the lesson was not learned. It appears that the standard of scientific rigor applied to MLPA does not rise to the level that should be expected by policy-setting agencies.

4. Private land stewards in the North Coast region have partnered with the Department of Fish and Game for many years to protect nearshore habitats. By labeling these areas “Marine Reserves” and not changing the level of protection of accessible shoreline next door, public pressure will make our enforcement efforts more difficult and dangerous. The state of California should seek to partner with, rather than replace, the actions of local land stewards.

5. The Act calls for involvement of stakeholders, which it defines as “coastal tourism businesses and users of marine resources, such as fishers, divers, kayakers, researchers, underwater photographers, and boaters.” Inexplicably, stewards of contiguous land are not included. Although we have a large stake in the status of state land fronting our property, we have been unable to gain representation at the table. It is only through letters, public comment, and negotiation with represented interest groups, that we have been involved. Unfortunately, participants have found it convenient to label land stewards as NIMBYs. As a result, we have few alternatives to be heard.

The members of Sail Rock Ranch support MLPA goals. We have great sorrow that the fruits of our stewardship, and some of the values we’ve enjoyed for so many years, will be taken away for an ill-formed experiment without reasonable likelihood of achieving its goals. We urge you to alter the course of implementation from a political grab for territory toward a science-based approach to improve marine resources for future generations. Thank you for your attention to this matter.

Best regards,
Walter W. Ratcliff
Manager, Sail Rock Highlands LLC
31500 State Highway 1
Gualala, CA 95445

Recreational Fishing Alliance Lawsuit on Channel Island Marine Reserves

As Secretary Chrisman rolls out MLPA to Southern California and North Coast, additional voices are joining to contest the way it is implemented. Recreational Fishing Alliance (RFA) uses the same points we do:
  1. Clearly identify the problem being solved
  2. Include measurable criteria for the benefit
  3. Allow fishing for species that are not of concern
  4. Include a sunset provision for specific MPAs when they reach a target

Thursday, December 6, 2007

Marine Access Protection Act?

This map overlays the Marine Protected Area (MPA) options being considered and public access points. Of the MPA coastline between Stewarts Point and Point Arena shown here, more than 70% fronts privately-held land that has no public access.

These areas have been protected from nearly all human predation for decades. If they are the only ones to be "protected" by the Act, MLPA goals cannot be met in this area. MLPA protects what is already protected and leaves open what is already open.

How can MLPA be more than an exercise in labeling? Is marine protection the primary goal or is access protection?

Tuesday, December 4, 2007

Suggested Metric for Comparing Effects of Predation on Marine Protected Areas

From Ken Jones and John Zeissig of CA Fishing Coalition

At their Nov. 13 meeting the SAT for the North Central Region MLPA introduced a draft option for assessing the level of protection offered by various extractive processes (fishing techniques and methods of take) if allowed within MPAs. In order to provide more flexibility in assessing the impact of the various ranked techniques on MPAs, this draft option expanded a similar rank ordering of level of protection used in the South Central Region from three levels to six levels. Members of the SAT, the Regional Stakeholders Group, and the Blue Ribbon Task Force have all expressed some doubt or confusion over how to apply this ordinal list of levels of protection to the assessment of MPAs. (See “Proposed Revisions to the draft evaluation method report of the MLPA Master Plan Science Advisory Team”, from MLPA Initiative Staff, Nov. 18, 2007.)

One reason for this is that the six levels of protection relate to one another only by the logical operation “greater than”. For example, a ranking of 2 does not mean that the practices included in that category are half as protective as practices ranked in category 4, only that they are less protective by some unspecified amount. Furthermore, different practices ranked in the same category are not necessarily equivalent. In applying the rank ordering to assessing the impact of a particular practice on an MPA there is, therefore, no basis for quantifying the
effect that allowing that practice will have on any particular species or on the ecosystem in general.

In order to properly answer these types of questions it is necessary to quantify the various practices, preferably on a rational scale where the elements consist of integers or are continuous variables. Beyond that, it would be extremely important to have such quantification based on empirical data rather than the somewhat plausible but essentially ad hoc considerations that have lead to the present ranking scale. One way to accomplish this would be to relate some measure of angling effort, such as fishing trips taken or time spent fishing (independent variables), to some measure of fishing success, like number of fish caught, or pounds of fish caught (dependent variables).

The most obvious source of precisely these kinds of data are the data collected by the California Recreational Fishing Survey (CRFS) conducted by the California Department of Fish and Game (DFG). The stated purpose of this effort is: “In response to fishery managers' and constituents' concerns about the use of MRFSS for making management decisions, CDFG and the Pacific States Marine Fisheries Commission (PSMFC) developed the CRFS. The CRFS was created to provide accurate and timely estimates of marine recreational finfish catch and effort. The program was implemented state-wide in January 2004.”

What can we learn by looking at the CRFS database? Let’s take an example and see how it can be applied to the assessment of the impact of some fishing categories on an MPA. Specifically, we want to see how the number of fish caught (dependent variable) varies as a function of whether the fisherman is fishing from the shore or bank, from a private boat or rental skiff, or from a party fishing boat (independent variables).

We can go to the DFG website, and then click on the tab at the top of the page that says “Marine”. On the page that comes up click on “Ocean Sport Fishing”, just below the tabs at the top. Scroll down a little way and click on “California Recreational Fishing Survey (CRFS)”. You will be taken to a page where you can query the database for information by using the categories above.

Note that the numbers obtained are estimates, rounded to the nearest 1000, of the total effort and total catch, generated from large scale sampling of actual effort and catch by a complex mathematical algorithm. Also obtained are estimated proportional standard errors that reflect uncertainties associated with the estimates.

Level of Protection (LOP): Examples Rating Angling Methods

The following information was obtained by asking for the number of fishing trips by anglers fishing in the ocean, for all species, from the bank, beach, or man made structures (all shore modes, MMBB) in the San Francisco District, in the ocean only, for fish inspected during the survey, between the start of the survey in January 2004 and October 2007, the last monthly data available at the time of this analysis:

Number of angler fishing trips (T) = 858,000.

Next we want to ask how many fish of all species were caught on these
858,000 fishing trips.

Number of fish caught (C) = 996,000.

To get an estimate of the efficiency of bank and beach fishing we take the ratio of fish caught per angler fishing trip:

C/T = 996,000 / 858,000 = 1.16 Fish/Trip.

Because the idea of LOP is reciprocally related to the catch per trip (more fish caught per trip results in a lower level of protection) we take the reciprocal of C/T = 1/C/T = T/C as our measure of LOP:

LOP = T/C = 0.86.

In order to relate the LOPs to the entire North Central Region of the MLPA, we need to expand our coverage by including the Wine District of the CRFS. The San Francisco District of the CRFS corresponds fairly well with the southern sub region of the North Central MLPA, but the northern sub region of the North Central MLPA is smaller than the Wine District of the CRFS, which extends from roughly the Tomales Bay area to Cape Mendocino. This will tend to result in underestimates of LOP for anglers, although the distortion should not be very large.

Taking the CRFS estimates from the Wine District for the same criteria that we used in the S.F. District and combining them gives us the following:

C = 996,000 (SF) + 117,000 (Wine) = 1,113,000.

Combining angler trips gives us:

T = 858,000 (SF) + 165,000 (Wine) = 1,023,000.

LOP = 1,023,000/1,113,000 = 0.92

Repeating this procedure for private boat and rental skiff fishing and party boat fishing gives us the following table for the LOP of the fishing methods in our original question. For boat fishing modes, however, the data query added the criterion that the fish were caught within 3 miles of shore to correspond to the seaward boundaries of MPAs.


Fishing Method LOP

Bank & Beach 0.96
Private Boat & Rental 0.48
Party Boat 0.13

We can now say, for example, for an angler fishing trip on a party boat in the North Central Region, from Jan. 2004 through Oct., within 3 mi. of shore, the angler will on the average catch approximately 3.69 times the number of fish that he would have caught had he fished from a private boat, and approximately 7.38 times the number of fish he would have caught had he fished from shore.

Before we can use LOP to assess the effect of some activity on an MPA, we’ll first have to deal with some obvious objections that could limit the generality of the concept. One might jump to the (false) conclusion that C/T = 0 means an infinite LOP. Realistically, fishermen have to be considered to be just one of a variety of predators in the ecosystem, so that eliminating fishing just shifts the balance of predation among species, and may reduce the overall level of predation, but certainly doesn’t eliminate it. For that matter, eliminating all predation will not result in a LOP of zero since some level of mortality will remain in any event. On the other hand, LOP allows a direct comparison between harbor seals and fishermen, for example, if one considers a day’s foraging of a harbor seal to be the equivalent of a day fishing by an angler.

Example Comparing Shore Angler LOP to Harbor Seal LOP

While not as straightforward as comparison of fishing modes using the CRFS data alone, it is nevertheless possible to make comparisons of LOP between different species. The major difficulties in doing this type of comparison arise from the paucity of data pertaining to some species and the fact that the relevant dependent variables are not always the same even when data is available. For the comparison of shore angler LOP to harbor seal LOP the first problem encountered is the measurement of harbor seal prey consumption in lbs./day rather than the fish/trip
metric used in the previous examples.

From the “MPLA Master Plan Science Advisory Team Draft Work Group Responses to Science Questions Posed by the NCCRSG at its August 22-23, 2007 Meeting (revised November 9, 2007)” we have the information that harbor seals consume 10 lbs of prey/day, as well as the information that there are approximately 8,000 harbor seals within the North Central Region during the “peak breeding season”. If we regard a day’s foraging by a harbor seal to be equivalent to a fishing trip by an angler then a seal has an LOP by weight in lbs. of 0.1 (Keeping in mind the uncertainty of this data).

The angler catch in tonnes is available from the CRFS database using the same MMBB criteria we used in our initial example, so we can obtain an estimate from the database that we can convert to lbs./trip for shore anglers, and use that to calculate a LOP by weight of catch. For catch by weight, we obtain the following for Jan. 2004-Oct. 2007:

C = (SF) tonnes 336 + (Wine) tonnes 76 = 472 tonnes

472 tonnes X 2200 = 1,038,400 lbs.

T = 858,000 (SF) + 165000 (Wine) = 102,3000 angler trips

LOP (by weight) = 1,023,000/1,038,400 = 0.99

So, to a first approximation, it appears that it takes about ten shore and pier anglers (0.99 LOP/0.10 LOP = 9.9) to equal the extractive effect of a single harbor seal.

Of course, there are a number of caveats that need to be attended to in using data like this. As mentioned previously, the LOP of anglers is likely to be underestimated by the way this analysis was conducted. Also the estimate of harbor seal population is almost certainly very rough. Comparisons to other pinnipeds were not considered, so the combined effect of all pinnipeds is certain to be much greater than the apparent order of magnitude prey-take advantage of harbor seals over shore anglers. The LOPs of bird and fish-fish predation have not been addressed at all. The estimates of LOP derived from any recreational fishing data in California are surely underestimates of the true efficiency of fishing effort in every category, because the size and take limits imposed by DFG regulations truncate the amount of catch for any species to which they apply (assuming anglers are abiding by the regulations). They also do not include take due to poaching.

Other factors to be considered are the validity of data available from the CRFS database. While most of the numbers seem plausible, there are some entries that do not correspond to what one would expect based on personal experience. Another difficulty, that arises from the way we constructed our examples above, is that it allows us to compare predation/angling methods in terms of their effect on overall numbers or weight of fish caught, but clearly there are differences in the particular species caught depending on the method as well as geographically within the region. This can be examined, but no attempt was made to do so at this time. In addition, there are a number of other cautions to be considered in using the CRFS, or any other data, for that matter. This is certainly not an exhaustive list of all the potential pitfalls involved in doing this kind of analysis, and there probably other data sources that can be usefully employed.

Given the caveats above, the goal is to accomplish something like what follows. Ascertain at least a manageable cluster of important predators and generate estimates of their effects on the ecosystem in terms of take of species of interest. Express these effects in terms of LOPs as outlined in this essay. If this can be accomplished, then it might be possible to get at least a static picture of the relative importance of these predators in the ecosystem. My suspicion, based on the preliminary analysis above, is that shore anglers will rank very low in the
hierarchy of predators (by a factor of at least 2-4 compared to boat fishermen, a factor of 7-10 compared to party boat fishermen, more than an order of magnitude in comparison to seals and sea lions, and unknown additional amounts attributable to birds etc.). The ratios are sufficiently divergent that it can be persuasively argued that allowing shore fishing has a negligible effect on the ecology of an MPA (i.e., a ribbon! proposal or variation thereof). In any event the LOP measurement scheme has considerable advantages over the current ad hoc ranking, which relies on subjective judgments and offers scant hope for an equitable solution.

Science Guidelines for MPAs

The science guidance provided to the RSGs is a subset of what has been published on the subject. There is consensus among marine ecologists that MPAs are not a panacea that can effectively achieve results in all situations.

Some of the areas of disagreement that have kept out of the MLPA process include:
  • The interaction of fisheries management practices with MPAs
  • The few and large versus small and numerous MPA debate
  • Diffuse biodiversity goals versus measurable fisheries objectives
Here are several excellent journal publications that could serve as guidance to RSGs if listened to:

After the Central Coast MLPA process, Hilborn, Walters et al were commissioned by the Cal Fisheries Coalition to do a peer review. This critique is the reason why the scoring methodology is being backed up by running the RSG proposals through two or three models.

The SAT is currently trying to decide which "models" to use to evaluate the RSG proposals. It appears that the Botsford model and Walters model will win out. These models are spreadsheets into which they plug certain local data, though we are unclear about these independent variables.

Botsford's Principles for Design of Marine Reserves include:
  • Adding reserves is equivalent to increasing the size limits in fishing
  • Adding reserves is equivalent to limiting fishing
  • MPAs preserve biodiversity best when inhabitants don't travel far (like abalone and rockfish)
  • If the goal is to protect more active species (like halibut, sharks, deeper water rockfish) the MPA must occupy a long stretch of coast
  • Very little is known about the relationship between variables or behavior of different species. Type 1 and 2 errors will be high.
Dr. Carr writes about when MPAs are and are not appropriate. This is a very readable elaboration of the potential objectives met by MPAs and the uncertainties. He calls for an "increased need for accountability and the explicit statement of performance-oriented conservation goals. Consequently, there is an immediate need to set realistic MPA objectives, expressed as well defined, tractable, and measurable targets."

Lessons Learned from Central Coast

Many participants in the Central Coast iteration of MLPA felt steamrolled by the process and lack confidence in the outcomes. Read their suggestions for improving the process.

  • The State should commit to providing a quality product, including best available science and socio-economic information [rather than expediting a decision based on inadequate information because ‘time did not allow…’]
  • The ecosystem benefits of current fishery regulations should be fully integrated into SAT guidelines from the beginning of discussion, and MPAs should be designed against a backdrop of existing fishery regulations
  • Both the State and NOAA Fisheries have moved to an eco-system based management philosophy, and very strong management measures have been put into place. As was heard at several points during the MLPAI process, overfishing is no longer occurring off the coast of California.
  • SAT guidelines and other SAT products should be subject to full scientific peer review (at least 3, preferably 5 reviewers, including scientists expert in fishery and oceanographic disciplines), with stakeholder input in the selection of the reviewers. This review should occur BEFORE MPA network packages are evaluated.
  • ...ecological theorists dominated the SAT. Scientists with population dynamics and oceanographic expertise were not replaced in-kind, and this imbalance led to a SAT membership that engaged in virtually no skeptical debate about assumptions and other science questions involved in creating the science guidelines.
  • Be clear to identify and separate science assumptions from policy decisions.
  • One problem with the MLPA is that the science assertions made for the value of MPAs are based on MPA work done largely in tropical areas with different species and different fishing cultures.