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