West Pac strongly opposes sanctuary expansion


The Western Pacific Regional Fishery Management Council has voiced its opposition to the proposed rule by U.S. National Oceanic and Atmospheric Administration (NOAA) to expand the current Fagatele Bay National Marine Sanctuary (FBNMS) to include five additional sites, saying that the proposal would - among other things - “reduce the currently limited fishing grounds” and “likely hamper both commercial and non-commercial fisheries development.”

The Honolulu-based council has also voiced concern over renaming the sanctuary as American Samoa National Marine Sanctuary, saying it’s a misleading name.

Council executive director Kitty M. Simonds, in a Dec. 29 letter to Gene Brighouse, Sanctuary Superintendent of the Fagatele Bay National Marine Sanctuary, outlined concerns and opposition regarding the proposed rule. 

The council provides the comments on the proposed expansion of FBNMS as outlined in the Draft Management Plan (DMP)/Draft Environmental Impact Statement (DEIS from a fisheries management perspective pursuant to its authority under the federal Magnuson-Stevens Fishery Conservation and Management Act to manage fisheries seaward of American Samoa, as well as an organization with extensive experience in working with the territorial government since 1976, according to the 13-page letter.

Firstly, Simonds said “we believe the public comment period should have been extended at least 30 days” as the comment deadline of Jan. 6, 2012 (this Friday) “is a poor choice given the time constraints of the holiday season.”

And based on its review of the DMP/DEIS, the council “supports Alternative 1”, which updates the Sanctuary Management Plan and further clarifies current provisions of the management plan. 

According to the DMP/DEIS, Alternative 1 would only update the management plan for FBNMS as it currently exists and the activities presented in the revised management plan would be primarily administrative in nature, designed to assist sanctuary managers in being proactive and able to respond quickly, appropriately and safely to threats to sanctuary resources.

In her letter, Simonds said the council does not support the proposed action to incorporate additional sanctuary units (sites) for the following reasons:

•            the scientific rationale supporting the expansion is inconsistent and unsubstantiated;

•            the current federal budget and enforcement capabilities are inadequate to support an expanded sanctuary;

•            overlaying proposed sanctuary units where existing management measures are in place provides no added conservation values, but instead creates confusion among the regulated community and tension among the agencies, which negates the goal of fostering partnership and interagency cooperation;

•            additional sanctuary units would reduce the currently limited fishing grounds, displace fishermen to potentially more dangerous fishing areas, and likely hamper both commercial and non-commercial fisheries development; and

•            expansion of the sanctuary system and the scope of ‘sanctuary resources’ have no clear fit with the matai system, which has successfully served to manage nearshore resources for thousands of years in the islands now known as American Samoa.


Some of the issues in the DMP/DEIS addressed by Simonds include a provision which states that, “Developing a science and culturally-based network of sanctuary units addresses a number of needs important to the Office of National Marine Sanctuaries (ONMS)...”

However, said Simonds, “we question whether the proposed expansion addresses the needs of the American Samoa people or their resources.”

“For example, the DMP/DEIS does not provide a cost-benefit analysis that clearly distinguishes the conservation and socio-economic benefits of the proposed expansion,” she noted. “The terse qualitative discussion in the DMP/DEIS, which is often contradictory, does not identify immediate, near-term, or long-term benefits of the proposed action.”

She also points out that the DMP/DEIS states that the purpose of this action is “to best fulfill the overarching goal of the sanctuary: to protect sanctuary resources.”

“This statement appears to lack sensitivity towards the fact that indigenous Samoans have cared for and managed their natural resources in the Samoan Archipelago for over 3,000 years,” Simonds points out. “Moreover, nearshore marine resources are resources of the American Samoa people, not a federal agency.”

“...marine resources in Samoa have been carefully managed under the matai system for thousands of years; however, the DMP/DEIS does not articulate how the federal overlay of sanctuary sites, whereby everything within those sites are considered ‘sanctuary resources’, will fit within the Samoan matai system in terms of resources access and use.”

Regarding the provision to change the name to the American Samoa National Marine Sanctuary, Simonds said, this “name change is misleading and has connotations that the whole territory is a sanctuary.”

“All of the existing sanctuaries are either site or species specific,” she said. “If ONMS is to push for a name change it should be to National Marine Sanctuaries of American Samoa, similar to the National Parks of American Samoa.”

She also points out that the introduction and overview of the proposed rule, talks about the “public scoping process” carried out in 2009 where there was “wider support” for designation of additional areas as sanctuary.

“Based on recent public hearings and online comments, it is clear that there was not wide support for additional sanctuary sites and there are statements that neighboring villages were not properly consulted prior to the release of the DMP/DEIS,” she said. “The Final DMP/DEIS should describe in detail its public consultation process.”

In tomorrow’s edition other reactions from the council on the proposal, including their concerns over the “no take area” off Aunu’u.


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