Take Action Now To Ensure Lasting Protections For The NWHI

November 21, 2009 Subject: Aloha Ms. Wilhelm, Ms. White, and Ms. Clark, Mahalo for the opportunity to comment on the Draft Management Plan for the Papahanaumokuakea Marine Monument. I feel that the public plays an important role in the management of Hawaii's public trust resources, therefore I support more direct public involvement in decisions about the Monument. Please establish a Monument Advisory Council with the authority to oversee and advise all three Co-Trustees and with the same strict conflict-of-interest requirements that made the original Reserve Advisory Council so successful. Please also include two public seats on the currently closed Monument Management Board. Hawaii's visionary Northwestern Hawaiian Islands Marine Refuge is an equal partner in the co-management of the Monument, yet is not mentioned in the action plans for the Monument. Please remedy this including specific references to the "do no harm" standard, permit requirements, and enforcement policies of the state refuge. This draft management plan must do more to empower Native Hawaiian decision-making about this culturally significant region. Native Hawaiian traditional practice and knowledge must be integrated into the management framework on equally footing as ecological and conservation considerations. This includes a commitment to fully fund the participation of Native Hawaiian cultural practitioners in decision-making and requiring permit review by the Native Hawaiian Cultural Working Group. I also feel strongly that human activity is the great threat - and the greatest hope - for the Monument. That is why I support strictly limiting human activity in the Monument. Please establish a numerical carrying capacity for the region based on the Precautionary Principle and immediately conduct a cumulative assessment of the risks and impacts of human activity in the Monument. Please also implement the spirit and the letter of all federal and state regulations to ensure the utmost protection for the region, including mitigation for all military activities affecting the Monument. Changes are clearly needed for this management plan to uphold the mandate to fully protect and conserve this uniquely Hawaiian marine ecosystem and wahi pana. I endorse the changes requested by KAHEA and the NWHI hui in their detailed comments. This place is unique on the planet and the largest no-take marine reserve in the world. Bioprospecting, military activities, increased tourism and vessel traffic, extractive research, and fishing by permittees is inappropriate in this highly protected marine ecosystem. Mahalo for your consideration and effort to improve this management plan. We will add your signature from the information you provide.		First Name* Last Name* Email* Street* Street 2 City* State/Province* Select a state Alabama Alaska American Samoa Arizona Arkansas California Colorado Connecticut Delaware D.C. Florida Georgia Guam Hawaii Idaho Illinois Indiana Iowa Kansas Kentucky Louisiana Maine Maryland Massachusetts Michigan Minnesota Mississippi Missouri Montana Nebraska Nevada New Hampshire New Jersey New Mexico New York North Carolina North Dakota Northern Mariana Islands Ohio Oklahoma Oregon Pennsylvania Puerto Rico Rhode Island South Carolina South Dakota Tennessee Texas Utah Vermont Virgin Islands Virginia Washington West Virginia Wisconsin Wyoming Armed Forces (the) Americas Armed Forces Europe Armed Forces Pacific Alberta British Columbia Manitoba Newfoundland New Brunswick Nova Scotia Northwest Territories Nunavut Ontario Prince Edward Island Quebec Saskatchewan Yukon Territory Other Zip/Postal Code* Send an Email Send a Fax
MAKE YOUR VOICE COUNT - PERSONALIZE YOUR OWN COMMENTS NOW  HERE ARE KEY TALKING POINTS: 1. KEEP THE PEOPLE IN THE PROCESS: Management of the Monument is not open to the public.  Currently, all management decisions are made by a Monument Management Board (MMB), which is made up of 7 state and federal agency-representatives.  These meetings are not open to the public at all, yet all management decisions - including the granting of permits - are made at these closed meetings.  Because the MMB is making decisions about the future our public trust resources, all of their meetings should be open to the public.  Public meetings are one of the best ways to ensure government agencies remain accountable to the public they serve. The Co-Trustees should open all Monument Management Board meetings to the public. The Current Permitting System Is Flawed: The only public oversight of permit applications is through the state Board of Land and Natural Resources, which gives the public 6-days' notice of upcoming permit applications.  The BLNR appears to only rubberstamp permit applications, refusing to deny, modify, or even condition extremely aggregious requests to access the most-delicate state waters.  Despite promises from Co-Trustees that the permitting system would be improved through the management plan, the DMMP does nothing to correct the flawed permitting system.  Permits are still approved first at a closed meeting of the MMB and then rubberstamped six days later at hearing by the BLNR. The final management plan for the Monument must provide for meaningful public comment on all permits to access the public trust resources of Papahanumokuakea. Citizen's Advisory Council: The DMMP fails to establish a citizen-based advisory council for the Monument similar to the current Advisory Council that oversees NOAA's management of the Coral Reef Ecosystem Reserve.  The current Reserve Advisory Council (RAC) directed the Monument Co-Trustees in June 2007 to begin the process for establishing a Monument Advisory Council. The Co-Trustees did not do that. Instead the DMMP suggests establishing a "Friends of the Monument" organization and/or a "Monument Alliance" of groups and individuals interested in the Monument.  Unfortunately, these groups do not have the regulatory authority or responsibility to oversee and provide advise on the management of the Monument and such as cannot adequately take the place of a citizen-based advisory council.  Active, direct citizen involvement in management decisions is the hallmark of protections of the Northwestern Hawaiian Islands.  The final management plan for the Monument must include a Citizen's Advisory Council, complete with the authority to oversee and advise all management activities and the same conflict of interest requirements of the current RAC. 2. RESPECT THE REFUGE: The State of Hawaii led the way towards the designation of this Monument by establishing the visionary NWHI State Marine Refuge.  This Refuge is the largest "do no harm" area in all of Hawaii and it specifically protects Native Hawaiian cultural access rights, prohibits commerical extraction - like fishing - and allows only appropriate scientific research.  It enforces these standards through a one-strike rule that bars future permits to any applicant that has violated a past permit.  Although the State of Hawaii is an equal partner in the management of the Monument, as outlined in the Memorandum of Agreement between the three Co-Trustees, the DMMP barely acknowledges the State Refuge in the 22 action plans to manage the Monument.  If the State Refuge is not only fully integrated in the management of the Monument, then it will ultimately become an after-thought of forgotten protections with no funding or administrative support. The Management of the Monument must fully implement the permit requirements, penalty structure, and prohibitions against sustenance fishing and waste dumping. 3. PERPETUATE NATIVE HAWAIIAN CULTURE: Since the designation of the Monument, the Native Hawaiian community has not been directly involved in the management of the Monument.  The Native Hawaiian Cultural Working Group has not yet been convened to participate in the development of the DMMP.  Neither the Native Hawaiian Cultural Working Group or the Office of Hawaiian Affairs were consulted about the serious, foreseeable risks of the Navy's proposed ballistic missile tests directly over the sacred island of Nihoa. The vision statement for the Monument in the DMMP must integrate perpetuation of Hawaiian cultural practice on equal ground as wildlife protection. The significance of the Northwestern Hawaiian Islands to Native Hawaiian cultural practice and history is part of the foundation of the overwhelming public support for protect this immensely important region. The final management plan for the Monument must have a vision statement that equally embraces the cultural and ecological significance of the region, such as: "that the health, diversity and resources of the vast NWHI - its unique wildlife and cultural significance - be protected forever." 4. MANAGE FOR CONSERVATION, NOT INCREASED, HARMFUL USE: The public continues to overwhelmingly support setting aside Papahanaumokuakea as a sacred place not to be exploited for any reason. Yet, we see little commitment to that goal in the DMMP, which advocates for increased research activity, increased tourism, construction on several islands, deferment of the U.S. Fish & Wildlife Service's "Wilderness Stewardship" responsibilities, and increased military activity, with no commitment to clean up legacy military contamination sites, conduct a cumulative impact and risk assessment, or establish a numerical carrying capacity.   This is not implementing the strongest possible protections for the Northwestern Hawaiian Islands. To manage for conservation, the Co-Trustess must: - employ the precautionary principle to first establish a conservative, numerically-based carrying capacity for human activity in the Monument.  This will set a protective limit on all human activity in this delicate area, including military exercises, research, and tourism. There must be a cap on the number of people that can enter the Monument, especially the number day-visitors to Midway.  - conduct a comprehensive assessment of the risk and cumulative impact of past and proposed human activity in the Monument.  This will require the Co-Trustees to prioritize who is allowed to enter this fragile area and for what reasons. This is especially important for research activities in the NWHI, which should only be allowed if they further a specific management goal and can demonstrate no harm to any Monument resources.  Papahanaumokuakea is not a "natural laboratory," as the DMMP describes it.  It is a place of refuge, where no human activity should be allowed unless absolutely necessary. - fully implement the purpose and spirit of the Proclamation designating the Monument and the regulations establishing the State Refuge by dissuading sustenance fishing by researchers and vessel crew. Sustenance fishing is not allowed in the state waters of the Northwestern Hawaiian Islands and should not be permitted in the federal waters.  Yet, right now, federal Co-Trustees grant permission for vessel crew and researchers to fish for their own consumption while in federal waters. There are no apparent checks on this practice: no fishing reports or gear restrictions.  In fact, we continue to get reports of "coolers upon coolers" of fish from Northwestern Hawaiian Islands being brought back to Honolulu.   This practice is unacceptable and should be stopped. - must impose mitigations on all proposed military activities possibly affecting the region.  Monument regulations require the armed forces to minimize and mitigate activities that could harm Monument resources.  Yet, right now, the U.S. Navy is proposing ballistic missile tests with chemical agents over the Northwestern Hawaiian Islands, experiments with hypersonic weapons and vehicles, exercises with high-intensity active sonar, and significant increases in marine debris all near the Monument with absolutely no mitigations.