Center for Biological Diversity Conservation Law Foundation
Environment America Environment California Friends of the Earth Greenpeace Marine Conservation Institute National Audubon Society
Oceana Ocean Conservancy Ocean Conservation Research
March 1, 2013
Maria Brown, Sanctuary Superintendent
Gulf of Farallones National Marine Sanctuary
991 Marine Drive
San Francisco, CA 94129
RE: Gulf of the Farallones and Cordell Bank National Marine Sanctuaries Expansion;
Dear Superintendent Brown,
On behalf of our organizations and our members, activists and supporters, we are writing to strongly support the expansion of the Gulf of the Farallones (GFNMS) and Cordell Bank (CBNMS) National Marine Sanctuaries as proposed in Federal Register Doc.2012-30581. Expansion of these existing marine sanctuaries has been discussed for over a decade, and supported by numerous Congressional and local political leaders who understand its importance to marine life and the local economy. The expansion has been the subject of several Congressional hearings and markups, and is supported by a wide range of economic interest groups in Northern California, including commercial fishermen. It is now time to make the proposal a reality for this beautiful coast and magnificent ocean ecosystem.
The proposed expansion would extend from Bodega Bay, north to Alder Creek near Point Arena and west to the edge of the continental shelf, adding another 60 miles of coastal waters north of the existing sanctuaries. This would add about 2,770 square miles of ocean to the existing sanctuaries, more than doubling their area. As climate change proceeds on the west coast, scientists have already seen northward movements of important species; the expansion will enhance protection for these migrants.
For part of most years, there is a powerful upwelling of deep, rich water along the coast from north of Point Arena down to Bodega Bay. This unusual upwelling occurs within an even larger coastal system called the California Current which sweeps all the nutrient rich water southwards towards Cordell Bank, the Farallones Islands, Monterey Bay and farther south. The current is large enough to move an average volume of 500,000 cubic meters of water per second which is about 66 times larger than the average flow of the Columbia River.
The deep water nutrients brought up by the coastal upwelling and moved south by the California Current support an incredibly rich food chain that feeds more than one-third of the world’s whale and dolphin species at some point during the year and hundreds of thousands of seabirds living in the largest breeding colonies in the continental US. Some whales, marine mammals and seabirds travel thousands of miles to feed specifically in this area because it is so rich with food.
Among the diverse populations of sea birds and marine mammals, the sanctuaries contain seven threatened and endangered species of marine mammals, including the blue whale, Stellar sea lion, seven species of threatened and endangered seabirds, and five species of sea turtles. Some of the more notable threatened or endangered species in this area are: humpback whales, fin whales, short-tailed albatross, leatherback sea turtle, Chinook salmon, steelhead trout, and many more. The expansion area also has over 240 fish species.
Significantly, the expansion will help sustain local economies. According to NOAA’s Coastal Services Center, counties that border the expansion area had over 15,000 ocean-related jobs that paid $350 million in wages and produced $700 million in GDP from coastal tourism, fishing and other marine activities in 2010. If the boundaries of the GFNMS and CBNMS expand, it would permanently guarantee an area twice the current size where local fishing, tourism and other coastal jobs are protected from various damaging activities.
Threats to the northern coast of California include: oil spills, seismic testing for offshore oil drilling, offshore drilling, certain types of fishing practices, and coastal and vessel pollution. Marine mammals and seabirds are especially sensitive to oil spills and the seismic testing that inevitably accompanies drilling. Seismic testing and oil drilling which could disrupt the migration patterns and populations of a number of endangered marine mammals including the blue whales are a significant possibility in the proposed area without the expansion.
As NOAA prepares the Environmental Impact Statement on the sanctuary expansion proposal, we strongly believe it should assess the impact of bottom trawling and other damaging activities in the existing sanctuaries and expansion area, and analyze alternatives to these practices. Bottom trawling uses large, heavy nets that capture and kill many untargeted species as by catch and damage the corals, sponges and other benthic species. Corals and other bottom dwellers provide three-dimensional habitat which is correlated with high biodiversity and critical to the lifecycle of many species.
We also believe NOAA should examine moving the northern boundary of the expansion area farther north past Pt. Arena-Alder Creek. This would potentially include additional ecologically connected or important areas into the extended sanctuary.
The expansion of the Gulf of the Farallones and Cordell Bank National Marine Sanctuaries to include the area of deep ocean upwelling would safeguard the rich biological diversity of this area, provide critical habitat for economically valuable species and several threatened or endangered ones, and support local economies and jobs. We can hardly think of a more worthy place for sanctuary status in the continental US.
Marine Conservation Institute
Center for Biological Diversity
Conservation Law Foundation
Friends of the Earth
Ocean Conservation Research