North Coast Seaweed Rebellion Supports Option ZERO

North Coast Seaweed Rebellion Supports Option ZERO
Once quiet spoken, whispered even, it is now an upwelling.

Please enter into the Official Record North Coast MLPA(i) the following Supporting Statements for OPTION ZERO and CEQA Analysis to be Considered by the CA Fish & Game Commission

1200 mostly local signatures entered into the Article of Record of Public Testimony at the Special Meeting held by Assemblyman Wes Chesbro and the California Legislature's Joint Committee on Fisheries on 01212011 in Eureka.

Option Zero is an opportunity for the North Coast to develop an alternative plan that reflects the knowledge base and commitment to conservation and use of marine resources of North Coast communities and produce a timely, well informed consensus plan to bring back to the Fish & Game Commission and the MLPA(i) process. In this regard it must be noted that the North Coast challenged and changed the process but the science driven outcome had no mechanisms for input of LEK and TEK, or flowchart for adaptation into modeling. If it had, the outcome may very well have been a better design of MPAs on the North Coast.

An Option ZERO CEQA analysis would benefit the North Coast Region by:
1) Allowing time for resolution of Tribal Use Category by the Commission and/or Legislature.
2) Considering resultant significant changes to the marine environment by disruption of the localized sustainable (un)regulated commercial and non-commercial human involvement in the ecosystem (EBM).
3) These include but are not limited to urchin barrens, abalone stocks, hand harvested edible seaweeds, changes to public access, subsistence economics of coastal residents, 'natural diversity' of MPAs compared to the 'regulated and managed ecosystem', the carbon footprint of localized food resources and commercial processing (GHG are covered under CEQA since 2009).
4) CEQA analysis and comparative assessment of resultant MPA Array outcomes based on development of input mechanisms for LEK and TEK and the uniqueness of the NCSR.
5) Considering effort shift and the North Central Coast MPAs which are relevant to the North Coast SR in terms of landings by harbor (including Point Arena) and beyond the dock multiplier effects. Enhancing enforcement, and community buy in of the North Coast MPAs.
6) Considering the benefits under 15064.(e) of current economic improvement grant programs on the North Coast that benefit marine resources
7) DETERMINING THE SIGNIFICANCE OF THE ENVIRONMENTAL EFFECTS CAUSED BY A PROJECT (e) Economic or social changes may be used, however, to determine that a physical change shall be regarded as a significant effect on the environment. (f) The decision as to whether a project may have one or more significant effects shall be based on substantial evidence in the record of the lead agency.

AHRA requests through the Option ZERO CEQA analysis that a determination and assessment of LEK and TEK as submitted into the NCSR process is separate and distinct from that which would be categorized under CEQA in: 15064. (5) Argument, speculation, unsubstantiated opinion or narrative, or evidence that is clearly inaccurate or erroneous, or evidence that is not credible, shall not constitute substantial evidence. Substantial evidence shall include facts, reasonable assumptions predicated upon facts, and expert opinion supported by facts.

There is no requirement in CEQA “that the alternatives selected must satisfy every key objective of the project (emphasis in original).”

Thank you for your consideration of Option ZERO (for one year, even 2 years - one year to gather data and another to cpmpile it), under CEQA analysis as what is best for our communities.

For the Albion Harbor Regional Alliance Tomas DiFiore 707-937-4378


Also submitted were 1000 signatures from Whitethorn/Shelter Cove supporting Option Zero:


Please Enter for the Official Record the Following Supporting Statements for Option Zero For Consideration by the California Fish and Game Commission.
1. The near shore ecosystem on the North Coast is healthy and does not need protecting.
2. Option Zero has wide public support. Shelter Cove’s commercial fishermen were not represented on the RSG. They support Option Zero. The unified array is not unified as some Regional Stakeholders are supporting Option Zero, some Native American Tribes are supporting Option Zero and some public agencies are not fully on board. All of Shelter Cove’s public agency board members signed my 1000 signature petition supporting Option Zero. This petition was handed to Wes Chesbro on Friday January 21st, 2011 in Eureka to be entered into the public record. Other public entities such as Fort Bragg changed the wording on Adam Wagschal’s resolution template to acknowledge large public support for Option Zero.
3. MPAs will kill off our local near shore recreational and commercial fish businesses. Quotas from these fisheries will be transferred to trawlers destroying more habitat and biomass than all of the habitat found inside MPAs. Option Zero allows sustainable hook and line fisheries to carry on supplying the public with inexpensive, organic food using less fuel and employing more Californians than the trawling industry.
4. Fish and Game estimates that currently more abalone are being poached for profit than are being harvested legally. MPAs will not stop this. Any money set aside for funding MPAs needs to be diverted to hiring more wardens for reducing poaching.
5. MPAs cause unnecessary human suffering, especially in areas of poverty and high unemployment. Disadvantaged rural communities, such as Shelter Cove, are easy targets because they have no resources to fight off MPA placement.
6. Provide more time for comparing Option Zero’s environmental and economic impacts along with the other proposals and include Option Zero in the CEQA process.
7. It is necessary to revisit previous EIRs as economic impacts were underreported. Many people and businesses did not provide data for study. This may be problematic for the whole coast. Shelter Cove’s deliveries are way too small for the port. This may be due to commercial fishermen trucking large portions of their catch to wholesalers in Eureka and Fort Bragg and these deliveries being recorded on landing tickets for that port, not Shelter Cove.
8. Size and spacing of SAT guidelines took no account of existing, pending and future fisheries restrictions. The North Coast has the most restrictive fishing regulations on the whole Pacific Coast. These are concentrated in Shelter Cove.
9. Mapping of resources was inaccurate, knowledge of larval dispersal is nonexistent as stated by Dr. Jules Jaffe of Scripps Institute of Oceanography. The National Science Foundation is requesting $106 million for funding his studies on larval dispersal on the California Coast in FY 2011.
10. Shelter Cove harbor allows limited numbers of small recreational and commercial boats to be launched daily with not only limited fishing ability but also they are limited by the distance they can safely travel to access fishing grounds as weather conditions are a challenge year round. There are already too many regulations affecting our port. The Big Flat/Rogers Break closures will be a great loss to our community.

Thank you for your consideration,
Citizen’s Alliance,
Sue Sack,
775 Upper Pacific Drive, Shelter Cove,
Whitethorn, CA 95589


Please enter into the Official Record North Coast MLPA(i) the following concerns:

Request for OPTION ZERO CEQA Analysis to be Considered at the Special meeting of CA Fish & Game Commission of the resultant impacts to the environment due to the Patterns and Practices of MLPA(i) staff and third party facilitators Kearns and West.

At every opportunity RSG and North Coast community members on the SAT and BRTF stated there was not enough time ever (the most constant comment in every Study Region and the process is flawed by (lack of) proper notification of and access to meeting materials in a timely manner.

Time was always against the RSG. Staff dialogue consumed 70% of meeting times.

The biggest question throughout the process on the North Coast has been why the rush. Many answers were given, mostly avoiding any conclusively acceptable explanation. It is AHRA's take that the answer lies somewhere between the MEIR of the Master Plan Framework and any subsequent projects, and significant changes to that document and the resultant required re-evaluation and scoping sessions.

Including but not limited to the following CEQA code sections submitted pertaining to
1.timeliness and
2.Non-Compliance
3.Stating for the record; This is An action or proceeding alleging that a public agency is carrying out or has approved a project that may have a significant effect on the environment without having determined whether the project may have a significant effect on the environment...
15177. SUBSEQUENT PROJECTS WITHIN THE SCOPE OF THE MEIR
15179. LIMITATIONS ON THE USE OF THE MASTER EIR
§ 21157.6. LIMITATION PERIOD ON USE OF ENVIRONMENTAL IMPACT REPORT
§ 21167.4. MANDATE PROCEEDING ALLEGING NONCOMPLIANCE WITH DIVISION;
HEARING REQUEST; DISMISSAL; BRIEFING SCHEDULES AND HEARING DATES
§ 21177. PRESENTATION OF GROUNDS FOR NONCOMPLIANCE; OBJECTIONS TO
APPROVAL OF PROJECT

An Option Zero CEQA Analysis would point to the inherent lack of input mechanisms for LEK and TEK to the process (nearshore data LEK/TEK vs proxy data) (best readily available science vs actual recent accurate LEK TEK and western science) of localized data that everyone including the scientists can agree on which wasn't always the case with the NC SAT. Distances between kelp beds – is an example, Eric Bjorkstedt).

So the rush to complete the process was said to be dependent upon funding, Ken Wiseman stated this many times, the process could not be extended. It seems far more plausible that the Patterns and Practices of the 'open and transparent' process of the MLPA(i) have and will continue to lead to:

1) circumvention of CEQA analysis and public participation
2) gathering of new data but no allowance for input because of legal requirements to
reopen the MPF of the MLPA(i) and submitting a new MEIR.
3) environmental impacts under 15064. DETERMINING THE SIGNIFICANCE OF THE
ENVIRONMENTAL EFFECTS CAUSED BY A PROJECT

Option ZERO CEQA analysis asks for clarification of the terms 'sustainable' long term provision of ecosystem services.

An Option Zero CEQA analysis would look into the relationship of the process and what the result accomplishes. Bluntly said; we've been told one thing, but never the whole picture.

A 5 year 'review' of MPAs was presented to RSG like a desert. The implication being that MPAs could be modified or even deleted and added. Now since the MLPA and MPAs are not about fishing, though they use single species models the goals directive is habitat protection. Habitats like underwater rocks take 25-30 years to notice a significant change and that is from the MLPA science itself.

So what is really going on?

Who's in charge?

On the California Current Ecosystem-Based Management (CCEBM) initiative Steering Committee is Blue Ribbon Task Force member Margaret Caldwell (Senior Law Lecturer at Stanford University). The California Current Ecosystem-Based Management (CCEBM) initiative is Advancing the Science for Ecosystem-Based Management on the U.S. West Coast. From the
January 30-31 2008, Santa Cruz CA:

CCEBM Project 1: Indicators of Fishing Impacts (Kaplan and Levin in press)
For fished species, remove a fixed amount of biomass annually from standing stock. After 25 years, examine changes in ecosystem structure.

The Goal of EBM:
The goal of EBM is to ensure the long-term provision of the ecosystem services that humans want and need. Furthermore, it is now widely recognized that the continued delivery of these services depends on healthy, productive and resilient ecosystems.

Current Applications of US West Coast Atlantis Model
1. Testing ecological indicators
2. Setting federal (Sanctuary and Fishery Council) management in the ecosystem context (including state MPAs)
4) Evaluating effects of Individual Transferable Quotas (ITQs) In the future, we will use Atlantis to evaluate management strategies within Integrated Ecosystem Assessments.

“While there are important scientific advances enabling improved marine management, and important scientific limitations that must be addressed with new research agendas, we should not be discussing science in a “vacuum”. There will be a need for a “procedural map” for how to apply science to EBM in the real world.”
http://ims.ucsc.edu/ccebm

“As a result, a focus on ecosystem services rather than on EBM per se allows us to manage in a way that optimizes the delivery of multiple services, not just within a single sector, but across sectors.

The Atlantis ecosystem model for the California Current authored by Isaac Kaplan

Question to staff: What is the 'procedural map' (EBM) within the context of MPA designation by the MLPAi?

We respectfully request notifications of any changes and decisions for the duration of the process. Thanking your staff for your diligence and timeliness;

for AHRA board members all.

Tomas DiFiore

For more info on Option ZERO visit:
http://albionharbor.org/optionzero.html