Oregon Department of Fish and Wildlife
RE: Oregon Department of Fish and Wildlife’s Nearshore Marine Resource
Management Strategy 2005
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.
The Surfrider Foundation 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
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. They 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.
Many human activities - ocean dumping of solid and chemical waste, dredging and drilling, damming our rivers, developing sensitive shorelines and mismanaging commercial harvesting – disturb ecological and geological processes. As surfers, we covet and seek out 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 habitat and species abundance. We believe that management agencies would be remiss to neglect this correlation by managing our marine resources by a quantitative-specific approach that is akin to body counting, rather than acknowledging the species’ habitat needs, and incorporating ecosystem management as part of the overall management strategy. This ecosystem management includes clean water, refuge from predation and overharvest, food source(s), and seafloor and water column habitat identification and preservation.
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 absolutely have to have healthy marine ecosystems that are providing the
bounty on which both of those depend. The challenge for us is to take a long-term
perspective, to protect 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.
Two separate blue ribbon commissions, the Pew Oceans Commission and the U.S.
Commission on Ocean Policy undertook the first comprehensive look at
On
One Pew Commission Recommendation for
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 impacted 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
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
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 19-26. The National Oceanic and Atmospheric Administration,
working with the U.S. Fish and Wildlife Service and U.S. Department of State,
should design a national plan of action for the
Recommendation 20-4. The U.S. Fish and Wildlife Service and National Oceanic and Atmospheric Administration should expand their cooperative agreements with states under Section 6 of the ESA, including enhanced research, management, monitoring, and public information.
Successful nearshore management cannot rely on a bodycount-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.
Sincerely,
Surfrider Foundation –