Re: Review of National Marine Sanctuaries and Marine National Monuments Designated or Expanded Since April 28, 2007; 82 Fed. Reg. 28827 (June 26, 2017)
Dear Secretary Ross,
It has been more than a year since the public comment period opposing or supporting the review of National Marine Sanctuaries and Marine National Monuments Designated or Expanded Since April 28, 2007, which was mandated by President Trump via the issuance of Executive Order #13795. Yet, a decision regarding the fate of the affected Sanctuaries has not been publicly announced.
As concerned citizens we are submitting this petition to readdress EO #13795 and urge you to keep Sanctuary status protections for the Davidson Seamount an area of 585 square nautical miles that is a unique underwater habitat and home to one of the most diverse and abundant wildlife assemblages in the world including, fragile, large, coldwater coral colonies with some species several hundred years old.
First, we respectfully submit that the unprecedented review of already designated and/or expanded national marine sanctuaries is an unlawful undertaking that seems intended to undermine the purpose and policy that are the foundation of the national Marine Sanctuaries Act, authorized by Congress to allow the Secretary of Commerce to designate and protect areas of the marine environment with special national significance due to their conservation, recreational, ecological, historical, scientific, cultural, archeological, educational or esthetic qualities as national marine sanctuaries.
Second, we want to point out that the addition of the Davidson Seamount to the Monterey Bay National Marine Sanctuary in 2008 was hardly an arbitrary decision. The expansion occurred only after extensive outreach to Federal and State governmental agencies, Native American tribes and the general public was conducted. The seven-year outreach and review process included:
- 20 public scoping meetings, during which there were extensive public comments;
- Over 12,000 written comments;
- 20 Monterey Bay Sanctuary Advisory Council meetings, and;
- 68 volunteer working groups meetings.
The invaluable time provided by members of the public and government agencies to offer advice and guidance to MBNMS in public meetings totals well over 8,000 hours in the development of the plan.
Submitted for record are the:
- Monterey Bay National Marine Sanctuary Davidson Seamount Management Zone Management Plan
- Marine Sanctuary 2008 Management Plan Environmental Impact Statement
Third, a key reason NOAA identified the Davidson Seamount for inclusion in MBNMS was to protect it from potential threats such as: bio-prospecting, i.e., energy or mineral extraction, other forms of seafloor disturbance, and new technologies enabling harvest from the seabed, e.g. “exploratory” benthic fishing. Threats of most concern should Sanctuary status for the Davidson Seamount be revoked are related to potential extractive developments such as oil drilling or mineral mining. The very nature of those activities, which could include the use of explosives, would seriously disrupt and/or completely destroy the Seamount’s unique wildlife habitat and species that depend upon those habitats. Should extractive energy or mineral exploration or production be allowed in the Davidson Seamount, the inevitable oil leak or toxic mineral release would further devastate habitat and species in other parts of the MBNMS as pipelines would be required to cross considerable Sanctuary acreage. The spill within the original MBNMS acreage could be trapped in an ocean eddy, which would make cleanup more difficult and costly. While oil spills can eventually be cleaned up (although not all potential damages avoided), there are no mitigation measures to reverse the damages associated with the released of heavy metals or polymetallics. These toxic materials would be ingested by many species of fish and other wildlife. Fisheries for miles would need to be closed, but if they are not closed quickly enough, those toxic metals will enter the human food chain causing serious short- and long-term health effects including costly (if not impossible) to treat diseases including cancers.
Fourth, it should be noted that the Davidson Seamount has not previously been explored for oil and gas reserves or rare earth minerals. Therefore, any estimates of potential resources that could be extracted from the Seamount are speculative at best. Further, the Bureau of Ocean Energy Management estimates the maximum value of any oil and gas reserves underlying the Seamount plus the other CA Sanctuary expansion areas represents only 0.00079 percent of the total outer continental shelf (OCS) oil reserves and 0.0012 percent of total of total gas reserves in the U.S. Given these de minimis figures, there is currently no indication that there is any interest in considering these reserves for active production. Moreover, the distance from shore (70 nautical miles to the southwest of Monterey and 65 nautical miles west of San Simeon,) is also likely to make extraction prohibitively expensive, strongly suggesting that there is minimal, if any, lost opportunity costs associated with the Davidson Seamount expansion.
Fifth, according to the Middlebury Institute of International Studies Center for the Blue Economy, the ocean economy outperformed the U.S. both in the recession and recovery, with employment growing by 14% since 2005, compared with total U.S. employment growth of 4%. Tourism & recreation, with more than 2.2 million jobs, is the largest employment sector in the U.S. ocean economy, followed by marine transportation with 454,000 jobs. Economic estimates associated with the local tourism economy in Santa Cruz and Monterey Counties demonstrate more precisely the potential lost opportunity cost that could result if industrial activity in the Davidson Seamount was allowed and the Sanctuary’s beaches were destroyed, its fisheries devastated and its waters contaminated for decades. The following statistics are extracted from the Monterey Bay Economic Partnership website:
- In Monterey County, Tourism is the second largest industry and generated over $2.7 billion in spending in 2015.
- In 2015, Monterey and Santa Cruz counties generated approximately $3.64 billion or 3% of California’s total travel spending, while only accounting for 1.96% of the state’s population.
- Tourism generated employment was 24,390 in 2015 in Monterey County, 13% of the county’s total industry employment.
- In Santa Cruz County, Tourism created 9,450 jobs, or 8.9% of the county’s total industry employment in 2015.
- In Monterey County, Food & Beverage Services and Accommodations industries accounted for 30.4% and 26%, respectively, of visitor travel spending by commodity purchased in 2015.
- In Monterey County, the Accommodations & Food Services industry was 66.8% of the total industry employment generated by travel spending in 2015.
- In Santa Cruz County, Food & Beverage Services and Accommodations industries accounted for 28.3% and 27.0%, respectively, of visitor travel spending by commodity purchased in 2015.
- In Santa Cruz County, the Accommodations & Food Services industry was 56.5% of the total industry employment generated by travel spending in 2015, while Arts, Entertainment & Recreation was 32.5%.
In conclusion, as signers of this petition we vehemently oppose any changes in status to the Davidson Seamount. We also implore you, Secretary Ross, NOAA staff and any other decision makers involved in the EO #13795 review process to retain the Davidson Seamount as a critical feature and acreage of the Monterey Bay National Marine Sanctuary and the prescribed protections its inclusion in the MBNMS bestows on the Seamount. Specifically and in summary we call on you to:
- Oppose any changes to the boundaries of the MBNMS to due to the appending of the Davidson Seamount to the Sanctuary in 2008.
- Oppose the authorization or allowance of any activities in the area of the Davidson Seamount that would damage the seabed, disturb or destroy critical habitat or affect the health and well-being of species living and thriving in the designated Seamount acreage, which depend on the continuing conservation and protection of the Seamount.
- Strongly urge the Department of Commerce to reject any consideration or effort to allow energy or mineral exploration or production and any other industrial activities that could alter the conservation status and ongoing protections of the six national marine sanctuaries and five marine national monument affected by President Trump’s Executive Order #13795.