ODFW
Nearshore Final Comments
Mon, October 31, 2005
Oregon
Department of Fish and Wildlife
3406 Cherry Avenue N.E.
October 06, 2005
Salem, OR 97303
On
behalf of Surfrider Foundation – Oregon Chapter’s nearly five
hundred members, please include the following public comments
to the official record for Oregon Department of Fish and Wildlife’s
Nearshore Marine Resource Management Strategy. Surfrider Foundation
membership is comprised of fishermen, sailors, paddlers, divers,
surfers and beachgoers – people who spend a significant amount
of time on the coast and in the ocean. The Surfrider Foundation
is a non-profit environmental organization dedicated to the protection
and enjoyment of the world's oceans, waves and beaches for all
people, through conservation, activism, research and education.
Represented by over 40,000 members and 60 local chapters in the
U.S., the Surfrider Foundation also has affiliations in Australia,
Japan, France, and Brazil. Surfrider Foundation believes that
healthy coastal communities are sustained by a healthy ocean.
Those
of us who spend time on the coast may do so for different reasons,
but we all value its importance and cherish our ability to enjoy
it — this is our coastal legacy. Our special coastal and ocean
places are of critical importance to not only diverse fish and
wildlife populations, but also to the people who enjoy and depend
upon them. Oregon’s special places attract thousands of surfers,
divers, beachgoers and recreational fishermen annually. However,
growing demands on these sensitive coastal and ocean places threaten
the health of our marine ecosystem and the fabric of our coastal
legacy.
Approximately
one-third of Surfrider Foundation members count themselves as
fishermen or anglers. This classification is especially true in
Oregon. As these comments demonstrate, the same habitat that propagates
a healthy fishery is the same coveted by surfers for wave quality
and other recreation activities and the recreation-associated
economy. Oregon’s nearshore health is critically dependent to
these groups for recreation purposes and their occupations.
Endorsement
Surfrider
Foundation endorses the Nearshore document’s philosophy, this
planning process, and especially this step towards Ecosystem-Based
Management (EBM). We recognize this draft document as a critical
step in developing a clear strategy to manage Oregon’s extraordinary
nearshore marine resources. We truly support and appreciate the
time and effort that ODFW staff has put into this project.
Furthermore,
Surfrider Foundation pledges to assist this process in whatever
capacity its members can provide.
Summary
The
Surfrider Foundation endorses ODFW’s Nearshore document, its philosophy,
and planning process. We thank the Agency and Staff for its foresight
and diligence.
In
an optimum world:
·
We could surf or swim
after it rains without the fear of getting sick. We should remember
that fish, birds, and mammals live in the polluted nearshore water,
and a polluted environment does not produce a healthy commercial
fishery.
·
Sand would flow freely
from streams to form surf breaks and beaches, and not be captured
by dams, blocked by groins, or walled up behind seawalls and riprap.
The same sand that makes for good surf breaks and an enjoyable
beach, also functions as spawning
habitat for forage fish — a major category of prey for salmon.
Pacific herring, sand lance, and surf smelt all utilize shoreline
habitats for their reproductive activities.
·
The same reefs, kelp forests,
headlands, and offshore rocks that provide good surfing areas
are also recognized as essential habitat areas and are protected
in order to provide all Oregonians with recreational and
economic opportunities including fish harvesting and tourism.
Surfrider
Foundation believes that that the needs, habitat, and ecosystems
of marine species must be acknowledged and preserved in order
to effectively manage Oregon’s current marine resources. Habitat
elements such as water quality, sandy beaches, and nearshore reefs
into an Ecosystem Based Management system. Federal Commissions
have concluded that this approach is superior, and needs to be
implemented before catastrophic collapses are realized. Our nearshore
resources are as important to scientists, fishermen, recreationists,
and coastal communities as they are to fish species. We urge the
Department to make ecosystem management a strategic priority,
instead of relying on the antiquated, and ineffectual method of
reported catch, and perceived supply.
Ecosystem-Based
Management Recommendations
To
ensure that continued threats to our ocean and marine species
don’t continuously push the operational, acceptable, and sustainable
threshold, ODFW should use this opportunity to specifically implement
Ecosystem-Based Management (EBM). This management style should
be implemented in Oregon because:
§
It is recommended by the Pew Oceans Commission and
the US Commission on Ocean Policy, Pacific States Marine Fisheries
Commission, National Fisheries Conservation Center, many conservation
groups, agencies, leading scientists, and states.
- Washington
and California are using this management style, offering many
partnership opportunities.
- EBM
creation is a very fundable strategy, also offering many partnership
opportunities.
- EBM
is called for in Oregon Statewide Planning Goal 19.
- It
will promote collaboration between and within agencies to better
manage their respective jurisdictions toward the common goal.
- It
will recognize that harvestable species cannot exist without
their habitat, including broad sandy beaches, nearshore reefs
and water quality.
- To
effectively manage these harvestable species, their habitat,
food sources and non-harvest species must be equally managed.
- EBM
had tangential effects of preserving recreational and tourist
areas, propagating an existing economy.
Surfrider
Foundation Recommendations:
§
ODFW should shift current staff’s efforts towards
managing habitats and ecosystems.
§
ODFW should create a Nearshore Management Strategy
Advisory Council consisting of stakeholders and all relevant agencies
to assure communication and complete management.
§
Shift focus from inventory-style management to create
a plan with DSL, OPRD, and DEQ to protect nearshore reefs, kelp
forests, beaches, water quality, headlands and offshore rocks
and their submarine habitat to create an environment that promotes
harvest species and their juveniles.
§
Don’t categorically exclude Marine Protected Areas
(MPAs) or Essential Fish Habitat (EFH) in the nearshore. MPAs
are not the sole province of OPAC, and EFH should become a recommendation
for research and development in the nearshore to determine which
areas/habitats contribute to our fisheries and recommend preservation
measures.
§
Species are the barometer for human actions. ODFW
should be encouraging and actively suggesting species and habitat/ecosystem
needs to other agencies and providing, facilitating and expediting
the changes to maintain and retain the ecosystem.
§
Include a plan for loss/alteration
of habitat, habitat preservation and reclamation. Habitat includes
those mentioned in the Nearshore document:
§
High intertidal zone
§
Sandy Beach
§
Rocky Subtidal
§
Shallow Rocky Reef with Kelp Beds (less than 25
m depth)
§
Shallow Rocky Reef without Kelp Beds (less than
25 m depth)
§
Soft Bottom Subtidal
§
The Nearshore Advisory Committee should be formed
immediately to provide advice on and assistance with implementing
the Nearshore Strategy, and conducting regular reviews and updates.
Nearshore Committee should have representation from all groups
and perspectives, and not emphasize on fish harvest groups. All
relevant agencies should have voting members including:
DEQ EPA DLCD; DSL; ODA; OPRD; ODF; ODFW; ODOT; OIMB; South
Slough; DHS; NOAA Fisheries; Surfrider Foundation , Oregon Shores,
Elakah Alliance, Oceana, PMFC, Audubon, PMCC, POORT
§
There are three important
components to Ecosystem-Based Management: species-habitat association,
agency collaboration, and solutions. ODFW staff has accomplished
the first two elements, and should complete this document with
the third. Staff has done a great job of identifying the species
that use each habitat classification, and the agencies that need
to be involved in habitat management decisions. However, staff
should be encouraged to recommend solutions to the species and
habitat threats; especially those threats identified during the
extensive public process.
§
Specifically, staff should
include a collaboration plan for protecting and managing each
identified habitat classification including: High intertidal zone
§
Sandy Beach
§
Rocky Subtidal
§
Shallow Rocky Reef with
Kelp Beds (less than 25 m depth)
§
Shallow Rocky Reef without
Kelp Beds (less than 25 m depth)
§
Soft Bottom Subtidal
§
The recommended solutions
should be classified into two categories: those within and outside
ODFW’s jurisdiction. The recommendations outside ODFW jurisdiction
should then be collaboration goals for the agencies to determine
within the Advisory Council
§
The Nearshore Advisory
Committee should be formed immediately to provide advice on and
assistance with implementing the Nearshore Strategy, and conducting
regular reviews and updates. The Nearshore Committee should have
representation from all groups and perspectives, and not emphasize
on fish harvest groups. All relevant agencies should have voting
members.
DEQ EPA DLCD; DSL; ODA; OPRD ODF; ODFW; ODOT; OIMB; DHS NOAA
Fisheries Surfrider Foundation , Oregon Shores, ELakah Alliance,
Oceana, PMFC, Audubon,
Commission
Reports
Two
separate blue ribbon commissions, the Pew Oceans Commission and
the U.S. Commission on Ocean Policy undertook the first comprehensive
look at U.S. ocean policy in more than three decades - a period
that included vast growth in the nation's population, and a frightening
increase in stresses on the coastal and ocean habitat. Both commissions
undertook multi-year studies addressing issues ranging from the
stewardship of marine resources, and pollution prevention, to
enhancing and supporting marine science, commerce, and transportation.
Both
ocean reports make it abundantly clear that an incomplete understanding
of the
ecosystem
is no excuse for inaction (like the “precautionary approach suggested
in Oregon Statewide Planning Goal 19). It is imperative that we
make use of the best
scientific
information available, and managers must account for ecosystem
interaction
to
the best of their ability in order to sustainability manage resources
for the longterm.
Pew
Commission
On
June 4, 2004 the Pew Oceans Commission released its report finding
that America's marine systems --our oceans, coasts, and the web
of life they support -- are on the verge of collapse. This report
from 18 leaders in science, fishing, business, conservation, and
policy details how marine management has slipped through the cracks
of the dozens of agencies charged with caring for the sea's health.
The result is that overfishing, coastal development, pollution,
and other wasteful practices are threatening fish and fisherman
alike. The report's conclusion is something that Oregon State
has long known: healthy oceans are vitally important to our economy
and environment. Both of these reports identify ecosystem management
as the most effective way to ensure long-term fisheries.
U.S
Commission on Ocean Policy
The
U.S Commission on Ocean Policy’s final report, An Ocean Blueprint
for the 21st Century, was released in September of
2004. It found that pollution, over-fishing, increased coastal
development, altered sediment flow and dramatic declines in water
quality have significantly affected the health and safety of our
oceans, waves and beaches. Many of these recommendations include
the need for ecosystem and/or habitat management, and they
include:
Recommendation
11-2. The regional ocean councils, working with state coastal
management programs and other governmental and nongovernmental
entities, should assess regional needs and set goals and priorities
for ocean and coastal habitat conservation and restoration efforts
that are consistent with state and local goals. The National Ocean
Council should develop national goals that are consistent with
regional, state, and local goals, and should ensure coordination
among all related federal implementation activities.
Recommendation
12-1. The National Ocean Council should develop a national strategy
for managing sediment on a regional basis. The strategy should
incorporate ecosystem-based principles, balancing ecological and
economic considerations.
Recommendation
14-2. The U.S. Environmental Protection Agency (EPA), working
with states, should increase technical and financial assistance
to help communities improve the permitting, design, installation,
operation, and maintenance of septic systems and other on-site
treatment facilities. State and local governments, with assistance
from EPA, should adopt and enforce more effective building
codes and zoning ordinances for septic systems and should improve
public education about the benefits of regular maintenance.
Recommendation
14-3. The U.S. Environmental Protection Agency (EPA) and the
U.S. Department of Agriculture (USDA) should support research
on the removal of nutrients from animal wastes that may pollute
water bodies and on the impact of pharmaceuticals and other contaminants
on water quality. EPA and USDA should also develop improved best
management practices that retain nutrients and pathogens from
animal waste on agricultural lands. Where necessary to meet water
quality standards, states should issue regulatory controls on
concentrated animal feeding operations in addition to those required
by EPA.
Recommendation
14-8. The National Ocean Council (NOC), working with states,
should establish reduction of nonpoint source pollution in
coastal watersheds as a national goal, with a particular
focus on impaired watersheds. The NOC should then set specific,
measurable objectives to meet human health- and ecosystem-based
water quality standards. The NOC should ensure that all federal
nonpoint source pollution programs are coordinated to attain
those objectives.
Recommendation
16-7. The U.S. Environmental Protection Agency (EPA) should conduct
a thorough assessment, including field inspections, to verify
the availability and accessibility of functioning pumpout facilities
in existing no-discharge zones and prior to the approval of any
new no-discharge zones. The U.S. Fish and Wildlife Service
and EPA, working with states, should coordinate their efforts
to increase the availability of adequate, accessible, and operational
pumpout facilities, particularly in no discharge zones.
Recommendation
19-21. The National Marine Fisheries Service (NMFS) should change
the designation of essential fish habitat from a species-by-species
to a multispecies approach and, ultimately, to an ecosystem-based
approach. The approach should draw upon existing efforts to
identify important habitats and locate optimum-sized areas to
protect vulnerable life-history stages of commercially and
recreationally important species. NMFS should work with other
management entities to protect essential fish habitat when such
areas fall outside their jurisdiction.
Recommendation
12-1. The National Ocean Council should develop a national strategy
for managing sediment on a regional basis. The strategy should
incorporate ecosystem-based principles, balancing ecological and
economic considerations.
Collaboration
Opportunities and Recommendations
It’s
no secret that there are many jurisdictional hurdles to successful
marine resource management. One of these is the number of management
agencies, their respective geographic jurisdictions, purviews,
and missions. To create a situation where wildlife thrives, water
quality is preserved, habitat conditions are protected, assuring
a strong tourism and harvest economy, Surfrider Foundation – Oregon
Chapter suggests a cross-jurisdictional, multi-agency approach
to create a plan that would implement long-term solutions with
associated short-term milestones. Fundamental to this approach
would be a “bottom-up” theory, where the stakeholders not only
help create the plan, but assist in the milestone completion as
well.
Numerous
“threats” to our ocean were identified at the first round of meetings.
Many of these were out of the Department’s purview, including
coastal development, pollution, habitat loss, and oil/gas exploration.
There are State and Federal agencies which concentrate on these
topics. The Surfrider Foundation suggests the ODFW coordinate
with the relevant agencies to address these threats on a state-wide
and local level. The more decision-makers and public citizens
that learn of these threats and of potential local solutions to
them, the faster and more comprehensive the solutions will become.
ODFW has jurisdiction to manage marine species and their habitat.
These species cross many jurisdictional boundaries during their
lives. It is therefore appropriate for ODFW to be the unifying
agency to orchestrate the other relevant agencies to accomplish
its goal. The following are provided as examples within areas
of Surfrider’s concern; water quality, and nearshore reefs, and
beaches.
Water
Quality
Water
quality was consistently identified as a threat during this Nearshore’s
public meeting period. ODFW should use the Advisory council to
collaborate with Oregon DEQ, regional EPA, Oregon DHS (beach monitoring
program), coastal watershed councils, Surfrider Foundation, and
DLCD to identify innovative methods of assuring our nearshore
habitat is not threatened by this ubiquitous problem.
Recommendations:
§
To address the pollution and coastal development
threat, DLCD could relate fishery health to point and non-pointsource
pollution, and provide incentives for communities to incorporate
pollution-reducing technologies into their Comprehensive Plans.
These technologies could also be integrated into State Park campgrounds
and other state projects.
§
DHS and DEQ could use stream and ocean pollution
test results to identify high pollution locations. The local communities
could receive assistance to identify and submit grants to retrofit
failing sewer facilities.
§
ODFW, ODF, BLM, and other forest management agencies
could identify important salmon spawning areas and concentrate
on streams for natural rearing.
§
Current coastal water-testing programs could be
continued, and expanded. ODFW could assist with local community
acceptance by posting results of theses tests at local beaches,
docks, fish markets, and in local newspapers, especially in fishing-dependant
communities.
§
ODFW should acknowledge the detrimental effects
of water quality on wildlife and request assistance from coastal
watershed communities to help curb the problem.
§
The Nearshore
Advisory Council should be assembled (and include groups such
as watershed councils and local governments) to address runoff
and nearshore water quality issues, recognizing that water quality
is not only important for human health, but also a critical indicator
for ecosystem health
§
ODFW should
recommend to DLCD that coastal communities address land-sea connectedness
and impacts within their comprehensive planning processes.
§
These collaborative opportunities abound, but they
must be identified, and given serious effort to be effective.
Surfrider Foundation would be willing to be an Advisory Council
member for the Nearshore Strategy, and to compile more of these
opportunities.
Nearshore
Reefs
Nearshore
reefs provide highly desirable surf breaks. They are also areas
of high biodiversity. They are especially important to juveniles
and rockfish. It’s logical to assume that the more healthy rocky
areas there, the better the rockfish will fare, and the more juveniles
can escape predation and dye-off, the more fish there will be
in our ocean. In essence, the healthier, and more prevalent our
nearshore environment, the better our harvest species will be.
These reefs should be identified and protected from any disturbance
or damage such as coastal development, water quality imbalances,
improper harvest or seafloor disturbance. DSL has jurisdiction
over the nearshore sea bottom. Surfrider Foundation recommends
that ODFW collaborate with DSL, OPRD, DLCD, and user groups such
as divers, sport fishermen, and Surfrider Foundation, to determine
the location of these reefs and identify protection measures.
Nearshore reefs can be identified by current inventories from
OSU’s LIDAR project, user groups, and agency information.
Recommendations:
- OPRD
and DLCD could collaborate to strengthen coastal development
and shoreline hardening (another identified threat in the public
process) in areas near these reefs.
- DSL
could create seafloor buffers around these reefs that are not
to be disturbed.
- To
strengthen the wildlife refuge areas, ODFW should advocate for
the offshore rocks, currently enjoying a National Wildlife Refuge
classification could have a respective classification given
to the portion of the rock(s) below the ocean surface.
- ODFW
should coordinate with OPRD, OSU and DSL to identify reefs adjacent
to and near headlands (which are often under OPRD control or
ownership) and offer protection solutions.
• US CORPS
should dentify and address impacts to sediment flow from our rivers
and up and down our coastlines that is critical to maintaining
important coastal marine habitats (i.e., “sand shed” management)
so that our nearshore reefs aren’t unnaturally covered with sand.
Beaches
Beaches are
often perceived as separate habitats, but in reality are small
parts of much larger coastal ecosystems. These systems include
watersheds, wetlands, and nearshore marine environments. Beaches
are dynamic in nature and change on multiple temporal and spatial
scales. These changes are therefore difficult to predict with
certainty.
Sand should flow freely to form surf breaks and beaches,
and not be captured by dams, blocked by groins, or walled up behind
seawalls and riprap. The same sand that makes for good surf breaks
and an enjoyable beach also functions as spawning habitat for
forage fish — a major category of prey for salmon. Pacific herring,
sand lance, and surf smelt all utilize shoreline habitats for
their reproductive activities.
In
acknowledgement of the important role that beaches play as ecosystems,
the Surfrider Foundation initiated the Beach is Alive campaign
in 2002. Sandy beaches function as dynamic ecosystems, providing
habitat for numerous species of plants and animals that are of
critical importance to land/sea connections. As the U.S. embraces
the new paradigm of 'ecosystem-based' management, the Surfrider
Foundation believes that beaches must be treated as an integral
link to marine and terrestrial systems. Accordingly, Surfrider
has established three main goals of the Beach is Alive project:
·
To educate
managers and the public on the important ecological functions
that beaches provide
·
To improve
monitoring and inventorying of the ecological health of beaches
·
To restore
habitats critical to the trophic linkages the beaches support
Shoreline
habitats in Oregon are crucial to the health of Pacific Northwest
marine ecosystems. Sandy beaches, rocky shores, and eelgrass beds
sustain a diverse assemblage of life. Numerous species of fish,
shellfish and seabirds in the region utilize these habitats for
feeding, resting, or reproductive activities during different
stages of their life.
Oregon's shoreline has particular importance to local salmon populations.
Notable in the Pacific Northwest because of their commercial and
cultural importance — as well as their protected status under
the Endangered Species Act — salmon species depend on the nearshore
environment both directly and indirectly. After migrating out
from freshwater streams, juvenile salmon are known to reside in
sand, gravel, and eelgrass habitats. These shoreline habitats
provide sanctuary from predators during early life-stage development,
and offer an abundance of food sources including invertebrates
and fish larvae.
The shoreline also functions as spawning habitat for forage fish
— a major category of prey for salmon. Pacific herring, sand lance,
and surf smelt all utilize shoreline habitats for their reproductive
activities. Pacific herring lay their eggs on nearshore vegetation
such as eelgrass, while sand lance and surf smelt deposit their
eggs high in the intertidal zone of sandy beaches.
The reproductive success of these small schooling fishes is particularly
relevant, given their importance to predators in Oregon's marine
environment. Pacific herring, sand lance, and surf smelt all function
as major food sources within the region's food web. In addition
to sustaining salmon populations, forage fish constitute a significant
portion of the diet of rockfish and cod. Forage fish are also
an important prey item for marine mammals such as seals and sea
lions, and for numerous species of seabirds. Finally, forage fish
indirectly support the feeding of resident orca populations through
sustaining the prey base they depend on for survival.
Unfortunately,
nearshore habitats in the Pacific Northwest are increasingly being
affected by human development. Shoreline armoring promotes the
loss of intertidal habitat and prevents the erosion of bluffs
that provide new sources of beach sediment. Docks, jetties, and
piers that extend seaward from shore also are damaging to nearshore
ecology. These overwater structures inhibit the growth of nearshore
vegetation and disrupt important physical and biological processes.
Finally, development in coastal uplands can cause run-off of pollution
and create future justifications for shoreline armoring.
The
beach is like an iceberg, in that the vast majority of a beach’s
volume lies beneath the
surface
of the waves. We walk, surf, and build upon a sandy accumulation
that represents only the very tip of this iceberg. Coastal geologists
know this as a “littoral cell,” a semi-closed system of shifting
sediment driven by topography and by currents. Longshore currents
drive sediments down current in a phenomenon known as “littoral
drift.” Most of the West Coast has a very high rate of littoral
drift.
Beach
sand starts in the mountains and in the bluffs adjacent to the
beach. When a river’s flow is blocked with a dam, or divert it
with a development, a beach’s upstream sand supply is diminished.
When a seawall is built, the beach’s ground supply is diminished.
Renourishment, shoreline armoring, and relic dams are cumulative
problems. Individual projects can occur at the municipal level
where they are poorly regulated, or poorly managed. The sum total
of these activities can quickly lead to a situation where a state
finds that 35% of its naturally occurring shoreline has been armored
and 50% of its natural rivers have been dammed. Logically, we
can then expect a proportionate decrease in species abundance
for those species dependent upon the shallow intertidal.
The
results of seawall construction are well documented. The immediate
impact of these hardened structures is a dramatic alteration of
the beach profile. Waves that once dissipated evenly along a gradual
slope now rebound with a concentrated dissipation of energy at
the base of the seawall. This causes increased erosion and scouring
of the sand at the base, suspending these sediments, and eliminating
the shallow water. Shallow water is host to two habitats that
act as refuge to juvenile fishes, the “baby pool” of ankle deep
waters too shallow for predators and “the forest” of nearshore
vegetation.
Juvenile
salmon face a similar challenge as they migrate from the river
to the sea in the Pacific Northwest. The nearshore environment
provides a critical transition point for juvenile salmon after
they emerge from their stream of birth and prepare to set out
for the open ocean. It is here that the young fish acclimate to
the higher salinity levels of the ocean, seek refuge from predators,
and increase in body size to improve their chances of surviving
out at sea. Chinook are the most estuarine-dependent of the salmonids,
spending up to 160 days in the nearshore environment prior to
their seaward migration.
Eelgrasses
are “the forest” in which salmonids hide during this juvenile
migration.
Shoreline
modifications that increase erosional forces and prevent sediment
input deny juvenile salmonids safe refuge from predators. Loss
of vegetation increases what we would term “infant mortality.”
All
the important forage fishes, i.e. herring, grunion, sand lance
and surf smelt, depend on nearshore habitats for spawning and
rearing. Protection of nearshore habitats utilized as spawning
and rearing areas for forage fishes will be needed if salmon recovery
is to be successful.
Recommendations:
- Surfrider
Foundation recommends that nearshore habitats should be prioritized
for protection,
- Following
these, the nearshroe reefs, and important beach habitat, nearshore
Essential Fish Habitat should all be combined into a network
of nearshore protected areas.
- Collaborate
with OPRD and DSL to strengthen policies protecting nearshore
and beach habitat areas from threats such as development (roads,
seawalls, houses, improper infrastructure), and determine areas
of high priority for purchase.
- Collaborate
with OSU to determine nearshore “forests” and beaches used for
forage fish and other trophic linkages.
• Identify
and address impacts to sediment flow from our rivers and up and
down our coastlines that is critical to maintaining important
coastal marine habitats (i.e., “sand shed” management)
§
To preserve nearshore processes and protect forage
fish, ODFW should advocate to OPRD and DLCD for actions to promote
long term beach preservation for the benefit of the public. Coastal
areas that are free of development should be protected via proactive
means that do not interrupt coastal processes. ODFW should provide
comments on proposed seawalls to preserve beach areas and advocate
for landward retreat of structures from dynamic shorelines. Where
landward retreat is not feasible, beach nourishment projects may
be considered, on a case by case basis, as viable alternatives
for short-term beach preservation.
- ODFW
should collaborate with OPRD and DLCD to establish beach setbacks
based on current and historical erosional trends.
- ODFW
should notify ODF that restoration of natural sediment transport
processes in coastal watersheds is important to their managed
fish species, and create a protection plan for those areas.
- To
address the coastal development threat, DLCD could relate fishery
health to beach properties, and provide incentives for communities
to incorporate development-reducing (and specifically seawall
or nearshore development) programs into their Comprehensive
Plans.
- ODFW
and ODF, BLM, and other forest management agencies could identify
important salmon spawning areas and concentrate on streams for
natural rearing.
- ODFW
should acknowledge the detrimental effects of beach depletion
on wildlife and request assistance from coastal watershed communities
to help curb the problem.
- The
Nearshore Advisory Council should be assembled (and include
groups such as watershed councils and local governments) to
address beach nourishment issues.
- ODFW
should recommend to DLCD that coastal communities address land-sea
connectedness and impacts within their comprehensive planning
processes.
Advisory
Council
The
Nearshore Advisory Committee should be formed immediately to provide
advice on and assistance with implementing the Nearshore Strategy,
and conducting regular reviews and updates. Nearshore Committee
should have representation from all groups and perspectives, and
not emphasize on fish harvest groups. All relevant agencies should
have voting members including:
DEQ EPA DLCD; DSL; ODA; OPRD; ODF; ODFW; ODOT; OIMB; South
Slough; DHS; NOAA Fisheries; Surfrider Foundation , Oregon Shores,
ELakah Alliance, Oceana, PMFC, Audubon, PMCC, POORT
- ODFW
to gather recommendations from the Advisory Council of where
to partner, and where other groups and agencies could be involved
in ODFW's strategy.
- The
Advisory Council should address issues such as fishery mismanagement,
water quality, the threats identified in the Nearshore’s public
process, not to address specific projects.
- ODFW,
other agencies, and the public should be aware that the assembly
of regional management bodies is a national trend. There are
other examples of marine and coastal bodies that could be mirrored.
By using other established models, Oregon would not be “reinventing
the wheel”. These models include:
- Regional
observation system – http://www.ccalmr.ogi.edu/nanoos/ as recommended
in Pew and USCOP. Integrated to designate 11 regional associations
funding and assemble an observation system. Seven goals, protecting
ecosystems, mitigating natural hazards, ensuring public health.
OR and WA NW association of networked ocean observation systems.
Goal is to create a National Weather Service, but for ocean.
ID all of federal, private, nonprofit, tribal, observing activities,
and centralize.
- California
Ocean Protection Council http://resources.ca.gov/copc/
- The
council is tasked with the following responsibilities:
- Coordinate
activities of ocean-related state agencies to improve the
effectiveness of state efforts to protect ocean resources
within existing fiscal limitations.
- Establish
policies to coordinate the collection and sharing of scientific
data related to coast and ocean resources between agencies.
- Identify
and recommend to the Legislature changes in law.
- Identify
and recommend changes in federal law and policy to the Governor
and Legislature.
ODFW
Should Conduct A Nearshore EFH Inventory
Many
human activities, such as ocean dumping of solid and chemical
waste, dredging and drilling, damming our rivers, developing sensitive
shorelines and mismanaging commercial harvests, disturb ecological
and geological processes. As surfers, we covet nearshore reefs,
rocky points and headlands, rivermouths, and other formations
that create good surf. These places usually are also highly productive
nearshore environments and nurseries. It’s evident to us that
the wealth of sea life seen while surfing a reef demonstrates
the correlation between intact habitat and species richness. We
believe that management agencies would be remiss to neglect this
correlation by managing our marine resources on a solely economic
level rather than acknowledging the habitat needs of the community
of nearshore organisms both individually and as a whole, and incorporating
these needs into the overall management strategy. This ecosystem-based
management includes clean water, refuge from predation and overharvest,
protection of prey items, and identification and preservation
of both seafloor and water column habitats.
Many
people create a false dichotomy between the environment and the
economy or the
environment
and the health of coastal communities. If we really want to have
healthy fisheries and healthy coastal communities we must have
healthy marine ecosystems to provide the bounty on which both
of those depend. Our challenge is to focus on the long-term goals
of protecting the health and the resilience and the diversity
of the ecosystems that are allowing us to have beautiful, viable
coastal communities and good, healthy fisheries. Oregon’s coastal
economy has been shifting from a commodities/resource-base to
a tourism majority. As this shift progresses, it is important
to acknowledge that the nearshore habitat areas that draw these
visitors will become an economically quantifiable resource, that
is essential to the entire coastal region, not just fishery-specific
industries.
Recommendations:
§
Funding for habitat mapping, and monitoring and
evaluation, which too often falls by the wayside in the face of
difficult budget circumstances, must be a priority. Monitoring
and research for ecosystem-based fishery management, however,
will be qualitatively different than current work. It will involve
understanding interactions and cumulative effects, including those
from non-fishing activities.
§
Apply Adaptive Management: scientifically-based
monitoring and evaluation of public policy and management actions
is a vital part of being responsible stewards of Oregon’s living
marine resources. Effective management depends on our ability
to understand the results and consequences of our actions and
to change course accordingly.
ODFW
To Use EBM Examples
The
purpose of this Nearshore Plan is to "promote actions that
will conserve ecological functions and nearshore marine resources
to provide long term ecological, economic, and social benefits
for current and future generations". However, it utilizes
a single-species based traditional management approach. Due to
past failures of single-species management approaches, there should
be more emphasis placed on more holistic area-based (marine zoning,
marine reserves/protected areas) approaches to marine resource
management.
The
Nearshore document’s process for determining the strategy species
list does not use an ecosystem-based approach for nearshore species
and habitat protection. Specifically, the nearshore team "removed
from the list those species whose conservation needs it was determined
would best be met through management affecting habitats or communities
of organisms" (page 42). Surfrider Foundation recommends
to instead study these habitat-species linkages to relieve pressure
on harvesters and management.
Additionally, the Nearshore document does not address MPAs or
Marine Reserves because it did not want to preempt the role of
OPAC. However, OPAC has already provided the recommendation that
the state move forward with establishing a system of Marine Protected
Areas and gathering relevant scientific data needed to inform
reserve design and effectiveness. As the lead agency responsible
for sustainable management of most of the biological resources
in Oregon's territorial sea, Surfrider Foundation believes that
it is ODFW's duty to specify how the state plans to implement,
or recommend to OPAC this nearshore management strategy.
Recommendations:
§
Don’t categorically exclude Marine Protected Areas
(MPAs) or Essential Fish Habitat (EFH) in the nearshore with this
document. MPAs are not the sole province of OPAC (in fact, ODFW
has the jurisdiction and ability to create MPAs), and EFH should
become a recommendation for research and development in the nearshore
to determine which areas/habitats contribute to our fisheries
and recommend preservation measures.
§
ODFW should consider the establishment of marine
parks as expansion of coastal state parks of outstanding natural
qualities to enhance protection of ecological, historic and cultural
values into marine environment
§
ODFW should study the potential of marine protected
areas and reserves to restore fisheries and conserve key ecosystem
habitats
§
ODFW should initiate pilot projects in targeted
communities to demonstrate success with specific EBM principles.
(Port Orford would be a worthy candidate.)
Ecosystem-Based
Management is a new term, but an old concept. Its basic premise
is that by creating a healthy and safe environment for our wildlife,
we won’t have to manage them so closely. If species are naturally
abundant, we won’t have to worry about short-term meteorological
or ocean condition shifts, and the harvest seasons won’t have
to be so carefully managed (or cut short mid-season). The past
few decades have shown us that we cannot manage our environment
in the same piece-meal fashion and expect it to be robust. Resource
use is an ebb and flow, and the prevailing management strategy
should be strong enough to withstand these natural occurrences,
so we're always not at a threshold. This Ecosystem-based philosophy
is the right way, the moral way, and the foresighted one. There’s
no need to “reinvent the wheel”. ODFW should use other states,
agencies, organizations and management agencies EBM structure
for insight. Examples of these are from:
Oregon
has determined that its marine waters should receive similar protections
to its terrestrial areas. Oregon’s Nearshore Marine Resource Management
Strategy should explicitly support implementation of Statewide
Planning Goal 19. In essence, Statewide Planning Goal 19 and its
implementation requirements provide a framework for establishing
an ecosystem-based management approach to sustaining a healthy
ocean in Oregon.
§
Statewide Planning Goal 19, Ocean Resources, was
set forth to “conserve marine resources and ecological functions
for the purpose of providing long-term ecological, economic, and
social value and benefits to future generations.”
§
In order to carry out this goal, the use of ocean
resources is defined by specific implementation requirements including
the intent to:
§
“maintain and, where appropriate, restore the long-term
benefits derived from renewable marine resources”; and
§
protect renewable marine resources (living marine
organisms), biological diversity, important marine habitat,
and areas important to fisheries.
The following are excerpts from the scientific consensus statement: McLeod,
K. L., J. Lubchenco, S. R. Palumbi, and A. A. Rosenberg. 2005.
Scientific Consensus Statement on Marine Ecosystem-Based Management.
Signed by 217 academic scientists and policy experts with relevant
expertise and published by the Communication Partnership for Science
and the Sea at http://compassonline.org/?q=EBM
WHAT
IS ECOSYSTEM-BASED MANAGEMENT FOR THE OCEANS?
Ecosystem-based
management is an integrated approach to management that considers
the entire ecosystem, including humans. The goal of ecosystem-based
management is to maintain an ecosystem in a healthy, productive
and resilient condition so that it can provide the services humans
want and need. Ecosystem-based management differs from current
approaches that usually focus on a single species, sector, activity
or concern; it considers the cumulative impacts of different sectors.
Specifically, ecosystem-based management:
•
emphasizes the protection of ecosystem structure, functioning,
and key processes;
•
is place-based in focusing on a specific ecosystem and the range
of activities affecting it;
•
explicitly accounts for the interconnectedness within systems,
recognizing the importance of interactions between many target
species or key services and other non-target species;
•
acknowledges interconnectedness among systems, such as between
air, land and sea; and
•
integrates ecological, social, economic, and institutional perspectives,
recognizing their strong
WHAT
IS ECOSYSTEM-BASED MANAGEMENT FOR THE OCEANS?
Ecosystem-based
management is an integrated approach to management that considers
the entire ecosystem, including humans. The goal of ecosystem-based
management is to maintain an ecosystem in a healthy, productive
and resilient condition so that it can provide the services humans
want and need. Ecosystem-based management differs from current
approaches that usually focus on a single species, sector, activity
or concern; it considers the cumulative impacts of different sectors.
Specifically, ecosystem-based management:
•
emphasizes the protection of ecosystem structure, functioning,
and key processes;
•
is place-based in focusing on a specific ecosystem and the range
of activities affecting it;
•
explicitly accounts for the interconnectedness within systems,
recognizing the importance of interactions between many target
species or key services and other non-target species;
•
acknowledges interconnectedness among systems, such as between
air, land and sea; and
•
integrates ecological, social, economic, and institutional perspectives,
recognizing their strong
HOW
DOES ‘ECOSYSTEM-BASED MANAGEMENT’ (EBM) DIFFER FROM ‘ECOSYSTEM-BASED
FISHERY MANAGEMENT’ (EBFM)?
Document-specific
Comments
Section
V: Species and Habitat Inventory
Pg
29 – marine birds and shorebirds should be addressed in Species
and Habitat Inventory as many depend on nearshore habitats for
foraging, etc.
Pg
39 – Nourishment (dredge and fill) should be included as a
potential source of “loss/ alteration of habitat”
P
39 – beach grooming should be included as a potential source
of “loss/ alteration of habitat”
P
45 – object to the term “shoreline stabilization structure”
as seawalls, jetties, etc. do not stabilize, but rather disrupt
natural sedimentation processes and often result in the degradation
and loss of important habitat. Recommend using the term “shoreline
modification/ hardening”
Section
VI: Recommendations
On
pg 28 document states that Species and Habitat Inventory provides
a focus for planning and prioritizing specific conservation, management,
and research actions. However, the 16 recommendations fail to
adequately address some important issues identified in the Inventory.
Specifically:
Shoreline
Stabilization Structures
Seawalls,
jetties, etc can result in degradation/ loss of sandy habitats.
There is a need for
Education
and Outreach
–
impacts of shoreline modification projects and viable alternatives
to such projects
Management
and Policy
–
restrictions on “shoreline stabilization projects” in priority
habitats (e.g. forage fish spawning habitats)
Research
and Monitoring
–
investigate cumulative impacts of “shoreline stabilization” projects
on sediment budgets, habitat structure, and ecological function
-
identify ‘priority’ sandy habitats based on ecological, historical,
or recreational value (e.g. high biodiversity, spawning grounds,
surfing and diving locations)
Sandy
Beach
Makes
up 2/3 of coastline, but from a biological and ecological perspective
remain somewhat poorly understood
Research
and Monitoring
-
surveys of spawning habitats for forage fish (see WDFW efforts
in WA State)
-
identification and monitoring of ‘beach health’ indicators (i.e.
keystone species, contaminants, beach profile, sediment budgets)
-
improved water quality monitoring (needed?) – should test not
only for human health factors, but biological
Comments
on 16 identified Recommendations
General
comment – Collectively are good, but can be greatly strengthened
by including more specifics on recommended actions, and focusing
on non-fisheries issues more extensively
4)
Communication and Partnerships – need to specify exactly how
such partnerships will be promoted and what specific issues need
to be prioritized for education and outreach campaigns
5)
Nearshore Research and Monitoring Capabilities
ODFW
should not limit to just species specific monitoring. The document
should include stream data (turbidity, pollution etc.) wetland
loss, rip rap permits, sand loss, human use, population growth,
spawning ground quality, marine water quality, all environmental
parameters. – not just rely on stock assessments. If EBM and ecology
is priority, use stock assessments as benchmarks, not management.
6)
Assessment/ Indicator Strategies for Nearshore Species – scope
of this recommendation should be broadened to ‘Indicators of Nearshore
Health’. Fish and shellfish stocks can function as telling indicators,
but what about other factors – i.e (water quality, contaminants,
beach profile, sediment budgets)
7)
Nearshore Habitat Research and Monitoring – needs to include
focus on sandy habitats, as well, as these comprise 2/3 of coastline
and are crucial component of nearshore ecology.
This
section should include using undisturbed areas in the nearshore
environment for community ecology study without the polluting
factor of harvest effects. The agency needs undisturbed reference
to create a baseline for study. Results from these areas can be
compared with adjacent habitats of the same type that experience
harvest pressure. Without reference areas as a baseline, the state
will not have the scientific basis to determine the effects of
harvest practices on strategy habitats or the effectiveness of
MPAs.
16)
Interagency Management Coordination – yes, everyone agrees
this is essential to achieving ecosystem-based management, but
how can this be promoted in the context of Oregon nearshore management.
What will ODFW do? What should other agencies, governments be
doing?
Conclusion
Successful
nearshore management cannot rely on a single species-type program.
This historic approach has not been effective. To create a long-term
management approach, the species’ needs, habitat, and ecosystem
must be acknowledged and preserved. Federal Commissions have concluded
that this approach is superior, and needs to be implemented. Our
nearshore resources are as important to scientists, fishermen,
recreationists, and coastal communities as they are to fish species.
We urge the Department to make ecosystem management a strategic
priority, instead of relying on the antiquated, and ineffectual
method of reported catch, and perceived supply.
Surfrider
Foundation – Oregon Chapter thanks ODFW Staff and the Commission
for their hard work and the opportunity to speak on behalf of
our members regarding this important process. We hope that this
Strategy becomes a model to other regions for its sustainable
and innovative management methods.
Sincerely,
Surfrider
Foundation – Oregon Chapter
PO
Box 571
Newport,
OR 97365
References
EBM
McLeod, K. L., J. Lubchenco, S. R. Palumbi, and A. A. Rosenberg. 2005.
Scientific Consensus Statement on Marine Ecosystem-Based Management.
Signed by 217 academic scientists and policy experts with relevant
expertise and published by the Communication Partnership for Science
and the Sea at http://compassonline.org/?q=EBM
http://www.dfg.ca.gov/mrd/nfmp/index.html
http://wdfw.wa.gov/fish/grndfish/grndfish.htm
www.psmfc.org
Pacific
States Marine Fisheries Commission for full report Strengthening
Scientific Input and E-B Fisheries Management of Pacific and North
Pacific Fisheries Management Councils (July 2005)
www.nfcc-fisheries.org
National
Fisheries Conservation Center Consensus Statement: Integrating
Marine Reserves Science and Fisheries Management (June 2004)
Beach
Linkages
http://www.surfrider.org/makingwaves/makingwaves20-4/12-13.asp
http://www.surfrider.org/specialplaces/beach_sand.pdf
http://www.surfrider.org/makingwaves/makingwaves19-6/8-9.asp
