Saturday, February 16, 2008
Tuesday, February 12, 2008
F& G Commission 12 February 2008
Care Ratcliff Carrre’
3rd generation, Sail Rock Ranch, Gualala
If I have to choose a proposal I would prefer External Proposal “A” or Draft Proposal 2 (JD). These two proposals do the least amount of damage to our fragile coast.
Sunday, February 10, 2008
F & G Commission
In order for science to be effective and to work correctly…we must have data, biologically data. The data that we do not have at this time to implement any or all MPA’s in the
Before placement of any MPA studies should be started and completed to backup the need if any for a Marine Protection Area. Studies or observations done 5 years down the road will have no meaning if we do not know what was there upon the implementation of a MPA. Areas that are UNZONED are just as important to areas that are ZONED.
What is the impact on the UNZONED areas caused by the ZONED areas? It will be impossible to know unless a biological study is done before the zoning and law is enacted. Scientist have no idea what will happen….do they? Zoned areas might improve in species and numbers, but to what degree? Will the bleed over from a SMR support the over fishing pressure of the adjacent UNZONED area? Will the UNZONED area be hit so hard by fishing pressure that it will fall below the standards or baseline? And again we do not know what the standards; baseline or minimal sustainability is without a scientific biological study before implantation of these MPA’s. And again, we have insufficient scientific and biological study data!
I urge all involved to stop and think about this for a minute. What type of scientific data do we have to implement this State mandated legislation? NEXT TO NOTHING!!! Therefore placement of all MPA’s, (SMR’s, SMP’s & SMCA’s) are a guess, gamble and shot in the dark without major underwater, above water studies of all spices mentioned for protection in the study region. “Show me the numbers”
Early in the MLPA process (Gualala, 10-16-08) Exec. Director Ken Wiseman stated that “we are going to do this once and do it right.” At the last meeting in Gualala (02-05-08) Exec. Director Wiseman stated “this is not a perfect process.” Now which one is correct? So let’s slow down and do this correctly!
A concerned and caring fisherman, Archer J. Richardson, Stewarts Point, CA.
Friday, February 8, 2008
California Department of Resources
Dear Secretary Chrisman;
Thank you for your January 16 response to my letter concerning the Marine Life Protection Act (MLPA).
While I appreciate that you support all the goals of the MLPA, your letter leads to the conclusion that goal #1 protection of “the natural diversity and abundance of marine life…” will be sacrificed in favor of public access. To avoid this adverse impact, your leadership is needed.
By siting MPAs only adjacent to areas that have been protected nearshore for decades, the current siting proposals ratify the status quo. They put a new label on existing protected nearshore areas while leaving unaffected all the areas that have been unprotected. Please look at the overlap of public access and MPAs. The proposed nearshore MPA sites do not improve upon existing protections.
The Act itself makes no mention of public access. Section 2853(b) goal #3 states that recreational, educational, and study opportunities be managed “in a manner consistent with
protecting biodiversity.” Public access has been written into the MLPA Master Plan by MLPA staff at the request of stakeholders.
What’s at Stake
Over this last weekend there was a particularly low tide (-1.4 feet). Jeanne Adams and I and a photographer took the opportunity to make an informal comparison of biodiversity off Sail Rock Ranch with Moat Creek, a public access point just north of us. The differences were striking. We hope to provide you with the opportunity to see these pictures for yourself in the near future. As a taste, in a two-hour period in front of Sail Rock Ranch (SRR) we found:
§ Abalone growing so thickly they were difficult to avoid walking on. At Moat Creek during a two-hour period the following day (same tide) we found only one.
§ 6 types of starfish too numerous to count, including a bright orange brittle star. At Moat Creek, we found 2 types of starfish and very few.
§ Two nudibranchs. At Moat Creek, we found none.
§ Large green and orange anemones open and feeding. At Moat Creek, we found no anemones in tide pools…only small ones on top of rocks.
§ Clouds of small rockfish fry swimming in formation. At Moat Creek, we found a few isolated fry.
These are a few examples of what is at stake. The nearshore habitats off SRR and Richardson Ranch have been de facto preserves for decades. The important thing I hope you realize is that these differences are not an accident of oceanography. Nor will they magically become more productive hatcheries for the rest of the coast just because they are designated MPAs. What’s important is that other areas—areas that currently have public access—must receive protection equal to the level already afforded SRR and
Your Leadership Is Needed
We are particularly concerned that objectives such as “Protects complex and highly productive rocky reef and kelp habitat including one of the largest stands of bull kelp in the north central coast, and associated species” (proposal 4) are being represented to you as measurable. Because this area is currently at or close to climax, a baseline taken offshore of SRR will not show progress in 5, 10 or 20 years. These objectives lack targets by which progress can be measured (MLPA goal #5). In consequence, your Agency lacks the mechanism to objectively alter the area, spacing or level of protection or to “sunset” an MPA.
There is a clear alternative. By including areas in which progress will be obvious after a short time—for example Moat Creek—the MLPA can demonstrate success. If degraded areas are not included, progress will need to be manufactured.
Why haven’t the very capable participants in the MLPA initiative realized this and self-corrected? There are three reasons public access has taken priority in MLPA deliberations, all of which can be remedied by appropriate leadership: 1) the evaluation criteria do not provide adequate siting guidance, leaving public access as the default siting criteria, 2) objectives are not required to be S.M.A.R.T. and 3) the focus is on the short term activity of setting boundaries, not long-term outcomes.
Implementation Must Be a Criteria for Siting
Exclusively targeting nearshore areas off private lands is problematic for other important reasons which have received little attention in public deliberations:
§ What are the monitoring logistics? Private landowners will be expected to open their fence lines to state contractors. Legal mechanisms and additional state insurance costs have not been made public.
§ What are the enforcement logistics? Tree-lined cliffs and deep coves are difficult for any number of wardens to patrol even on public lands. It is truly incomprehensible that wardens will be tasked with looking across fence lines and transiting private land to check the MPAs beyond.
Obviously public process is constrained by administrative interpretation of the Act. In my observation, MLPA Initiative staff are competent and focused professionals truly committed to siting MPAs. However, the Initiative process is missing the big picture. It’s off the track and needs to be put right. We at Sail Rock Ranch support real progress. We do not support being disproportionately targeted by valuing public access—a goal that is not in the enabling legislation—at the expense of the primary authorized goal of the Act.
We appreciate your personal attention to these important issues.
Walter W. Ratcliff
Manager, Sail Rock Highlands LLC
cc Senator Patricia Wiggins
Assemblyman Patty Berg
John Carlson, Executive Director,
John McCamman, Acting Director, California Department of Fish and Game
Richard B. Rogers, President,
Michael Mantell, Resources Law Group
Ken Wiseman, Executive Director, Marine Life Protection Act Initiative
Dr. Marcos Underwood, President, Haven’s Neck Preserve LLC
Members of Sail Rock Highlands LLC
 The commonly accepted criteria for objectives is: S(pecific) M(easurable) (A)chievable (R)ealistic T(ime bound). MPA objectives, as written, do not meet these criteria.
January 16, 2008
Walter W. Ratcliff, Manager
Sail Rock Highlands LLC
31500 State Highway I
Dear Mr. Ratcliff,
Thank you very much for your letter dated December 14, 2007 regarding the California Marine Life Protection Act Initiative. I appreciate your interest in the process and suggestions for improvements.
I understand from our MLPA staff that you and other members of Sail Rock Ranch have been actively involved in the MLPA Initiative process, by speaking at the MLPA Blue Ribbon Task Force, North Central Coast Regional Stakeholder Group and Master Plan Science Advisory Team meetings. The MLPA Initiative process is one of the most extensive public processes I have ever seen in government, which I had the chance to witness firsthand in Gualala last October. I am pleased to know that you have been able to take advantage of this opportunity.
In response to specific points you raise in your letter:
• You are correct in that public access has been one of various criteria stakeholders have used in developing marine protected area (MPA) proposals; early in the MLPA Initiative process, the desire to maintain existing public access was raised by the public and consideration of that access was subsequently incorporated into the regional goals and objectives for this study region. I recognize and appreciate the impact land stewardship has on the surrounding environment. It is not our desire to discourage private landowners from protecting natural resources on or adjacent to their property.
• The Blue Ribbon Task Force has provisionally adopted goals and objectives for the study region that the science advisory team has indicated are measurable. In addition, the regional stakeholder group has developed objectives for each proposed MPA. Once the California Fish and Game Commission has acted on MPAs in the north central coast, a baseline evaluation will be conducted and then ongoing monitoring will be put in place, specifically to allow the state to determine if the adopted goals and objectives are being met through an adaptive management program.
• The Marine Life Protection Act requires the best readily available science be used to help inform the decision-making process. Over the last three years, two groups of esteemed scientists have worked to identify that science and how it should be applied to the MPA planning process; as with the overall MLPA Initiative process, a transparent public process was used to develop the science guidelines which were adopted by the California Fish and Game Commission.
• Every Californian has a stake in the outcome of this process. To help ensure that all voices are heard, the director of the California Department of Fish and Game and the chair of the task force appointed as broad a constituency representation as possible on the regional stakeholder group; combined with an extensive public outreach and participation strategy, a wide range of voices are being heard at the table, including those of private landowners. We strongly believe in a science-based process that includes the public in the design of
Thank you for your continued, active participation and recommendations for improving the MLPA Initiative process. If you have any questions, please contact Executive Director Ken Wiseman at (916) 653-5674.
Secretary for Resources
cc: John Carlson, Executive Director,
Richard B. Rogers, President, California Fish and Game Commission
John McCamman, Acting Director, California Department of Fish and Game
MLPA Blue Ribbon Task Force members
Ken Wiseman, Executive Director, MLPA Initiative