Reason 1 why I oppose the PEW National Monument

So there are no misunderstandings about my purpose, I must first start out stating that the following comments are my own personal opinions and I am not representing any organizations. Additionally, I am not being paid nor am I receiving any compensation for writing this letter or subsequent letters to the editor on this topic.

My opinion on the NMI Marine National Monument (PEW Monument) being proposed by the PEW Foundation is based on my long-term involvement in the marine science and environmental regulatory fields and my personal belief in supporting sustainable fisheries programs.

As background, I was first introduced to the PEW Monument idea during the Mariana Islands Nature Alliance Strategic Planning Session held on Nov. 17, 2007 at Fiesta Resort. Those in attendance were told by PEW that they had already approached White House staff about the NMI Monument and President Bush was ready to sign the Presidential Proclamation as soon as PEW could show support from the CNMI government and residents. PEW was offering to provide operating expenses to MINA in the form of grants in exchange for their active participation in promoting and selling the PEW Monument idea to the people of the CNMI. The MINA Board declined PEW’s generous offer.

I attended a second, more formal PEW presentation on March 26, 2008, where the same concept was presented, complete with a PowerPoint show, colorful glossy handouts and various fact sheets providing general information about the northern islands. And finally, I carefully reviewed the PEW letter to Governor Fitial, dated Dec. 20, 2007, that outlined their proposal to create a very large no-take marine protected area in the Northern Mariana Islands EEZ, and an Internet investigation into both the PEW Foundation and the Northwestern Hawaiian Islands Marine National Monument (NWHI Monument) controversy. I would like to think that I have done my homework in attempting to fully understand the issues and resulting long term repercussions should President Bush designate over a third of the entire CNMI EEZ (115,000 square miles) as a National Monument.

My wish is to write a series of letters to the editor that will attempt to reveal certain issues that my not be apparent from listening to the polished PEW presentation. My purpose is to provide background information so interested people will be able to ask pertinent questions on issues important to the community. Please remember, the real stakeholders in this environmental political game are the people of the CNMI.

I have serious reservations on all the economic benefits that PEW is touting about the Monument and will address them in later letters. Meanwhile, I hope everyone understands that the PEW Foundation cannot guarantee the CNMI anything. They are simply a Washington DC-based third party expeditor trying to sell the CNMI a product that they themselves will have very little (or nothing) to do with once the Presidential Proclamation has been inked. Who will ultimately pay for the PEW Monument long after the PEW Foundation leaves the CNMI? We will, of course.

With that said, I believe the overall costs (costs are not necessarily limited to money) to the people of the CNMI are too high. Therefore, I completely oppose the PEW NMI Marine National Monument, Mariana Trench Marine Sanctuary, National Park of the Sea, or whatever name PEW is calling it this week.

Designation of the PEW Monument will permanently ban all commercial, recreational and subsistence fishing activities to U.S. citizens within Monument boundaries, an area encompassing 115,000 square miles. This will be accomplished by changing the existing resource management structure from that of promoting a sustainable fishery approach to a “no take” approach that prohibits virtually all extractive uses within Monument boundaries.

Based on management measures promulgated by the NWHI Monument, indigenous people will very likely be allowed to fish for sustenance purposes (not to be confused with subsistence fishing which will be outlawed) within Monument waters, provided the (fishing) activity is included as a term or condition on the federal permit that must be first obtained from the National Marine Sanctuary Program (NOAA/NOS), or its regulatory equivalent. Interestingly, Monument regulations require all fish caught in Monument waters to be eaten within the boundaries of the Monument. Oh, and don’t forget to turn in your catch report to the Monument management authority on the fish that was eaten!

Presently, marine resources within the federal waters of the CNMI EEZ (0 to 200 miles) are being jointly managed by two federal resource management entities; the Western Pacific Regional Fishery Management Council (Council) and the National Marine Fisheries Service (NMFS). Their approach to resource management is to support sustainable fishing practices in accordance to various federal laws (i.e., Magnuson (Stevens) Fishery Conservation and Management Act, Sustainable Fisheries Act, Endangered Species Act, National Environmental Policy Act, etc.). Both of these governmental entities also promote and embrace active participation in developing appropriate resource management measures from those who know the resources the best—the stakeholders.

If the PEW Monument becomes a reality, the existing resource management authorities (i.e., the Council and NMFS) would be replaced immediately with another federal management agency within NOAA: the National Marine Sanctuary Program under the National Ocean Service. In contrast to the existing sustainable management approach, a resource management approach of no extractive uses will be implemented by the National Marine Sanctuary Program. This federal action is permanent and commercial, recreational, and subsistence fishing activities in approximately 115,000 square miles of CNMI waters will become a memory.

In response to the above reality, PEW is quick to point out that indigenous islanders would be allowed to fish in Monument waters, just as the native Hawaiians are allowed to fish in the NWHI Monument. While this is a true statement, it is not telling you the whole story.

Regulations for the NWHI Monument (FR Vol. 71, No. 167; pages 51134-51142) require Monument visitors, including indigenous Hawaiians, to first obtain a federal permit that would allow access to NWHI Monument waters. For example, a permit could be issued for the purpose of practicing various traditional or cultural activities in the NWHI Monument.

In order to fish in Monument waters, one must have fishing activities added to the permit as a term or condition (‘404.11(h); page 51139). Sustenance fishing will only be authorized if the activity is “incidental to an activity permitted under this part” (‘404.3; page 51137). My understanding is that permits will not be issued to those persons that wish to travel to the Monument for the sole purpose of fishing.

If one actually does receive a permit to sustenance fish, the visitor would be required to eat any fish caught in Monument waters within the Monument boundaries (‘404.11e (5)). In simplest terms, no marine resources (i.e., fish and other edible marine life) can be taken from the Monument and distributed to family, friends, or community members back on their home island. And, should you be granted permission to actually eat a fish from the Monument, you will likely be required to submit a catch report to the Monument management authority documenting your eating event (see ‘404.11(h); page 51140).

The permanent ban on commercial fishing activities will detrimentally affect the CNMI’s newest commercial fishing business venture that has already invested a substantial sum of money in infrastructure development on Rota and bringing two fishing vessels to the CNMI. Creation of the PEW Monument will seriously inhibit the development of any future sustainable fishing industries as it will decrease the fishable area within the CNMI EEZ by 33 percent.

So, what does the PEW Foundation really want? Simply put, they want 33 percent of our EEZ to be designated as a no-take National Monument so they can credit their Ocean Legacy Project for creating another large Marine Monument and help President Bush put another notch on his environmental bedpost to bolster his legacy as the ”Ocean President”. Working in concert with the President to designate the PEW Monument in the Mariana Islands before he leaves office is not about science-based conservation, but U.S. mainland politics.

Though it may surprise our paid PEW lobbyist, the opposing forces grow larger and stronger every time a presentation is made. PEW cannot fool everyone with their rhetoric and empty promises.