Saving wild ocean places, for us and future generations

COMMENTS ON SANTUARY EXPANSION PROPOSAL FOR THE GULF OF FARALLONES & CORDELL BANK NATIONAL MARINE SANCTUARIES NOAA-NOS-2012-0228 BY DR. LANCE MORGAN, PRESIDENT MARINE CONSERVATION INSTITUTE February 29, 2013 Saving wild ocean places, for us and future generations

My name is Dr. Lance Morgan. I am President of the Marine Conservation Institute and Conservation Chair of the Cordell Banks Sanctuary Advisory Committee. The Marine Conservation Institute, headquartered in Seattle WA, with offices in California and Washington DC is a nonprofit conservation organization founded in 1996 that: uses the latest science to identify important marine ecosystems around the world; advocates for their protection; and works to ensure that they are managed and enforced carefully. We are in the business of preserving wild ocean places, for us and future generations. Thank for you the opportunity to submit comments on the expansion of the Gulf of Farallones (GFNMS) and Cordell Bank National Marine Sanctuaries (CBNMS) as outlined in the recent proposal (NOAA-NOS-2012-0228) in the federal register. As a marine biologist, conservation enthusiast, and Californian who lives near the sanctuaries, I have a special interest in protecting our oceans, especially this piece of ocean. Organizationally, the Marine Conservation Institute whole heartedly supports the expansion of both marine sanctuaries because the expansion area is a unique and immensely productive ocean place that needs protection against a variety of threats. In this comment I will focus on the geography and ecological and economic importance of the expansion area together with tangible threats to it. Geography and Physical Oceanography Designated in 1981, the Gulf of the Farallones National Marine Sanctuary is located off of the north central California coast beginning just a few miles north of San Francisco Bay and going up the coast to Bodega Bay, a distance of about approximately 40 miles. i The current sanctuary is 1,279 square miles in size and includes the Farallones Islands, a series of small rocky islands that lie about 30 miles from the Golden Gate. The expansion would increase this sanctuary by an additional 2,014 square miles and take it another 60 miles up the coast to just north of Point. Arena. ii The Cordell Bank National Marine Sanctuary was designated in 1989 and is located north of the Gulf of the Farallones and is entirely off shore. iii Cordell Bank is currently 529 square miles, and the expansion would add another 757 square miles. iv The sanctuary encompasses the Cordell Bank and consists of different benthic types: rocky, granite, rock reef, sand, and mud. The bank itself rises from the ocean floor to within 120 feet of the surface and covers an area that is about 26 square miles. The topography (i.e., bathymetry) of Cordell Bank significantly influences 1

local ocean circulation patterns. Deep currents coming up the continental shelf from west bump up against the shelf and the even higher bank to create an immense upwelling system there. v The northernmost point of the expansion is just north of Point Arena, a peninsula on an elevated coastal plain, at the mouth of Alder Creek. The northernmost expansion would be contiguous with the proposed Bureau of Land Management s Stornetta Conservation Management Area that combines a beautiful piece of northern California coast with offshore rock structures. Imagine preserving this land, surf and ocean in one continuous seascape. The proposed expansion encompasses an area of ocean off Point Arena and Bodega Bay that is part of a very large coastal upwelling system that waxes and wanes seasonally and with the dominance of El Niño and La Niña conditions in the Pacific. This upwelling region is considered to be one of the four largest in the world. Ocean systems of this nature are often dynamic, changing location and varying in intensity. In addition, the California Current System, a large, strong current that moves south down the coast, moves through this upwelling zone. The California Current has a transport volume of approximately 500,000 cubic meters of water per second on average. To provide some scale for this transport volume, it is about 66 times greater than the flow of the Columbia River. Anything brought to the surface by the upwelling is therefore swept up and moved south by the California Current. Ecological Importance The California Current sweeps up the deep nutrient-rich water brought to the surface by the upwelling and transports large quantities of nutrients and larvae south along the coast of California. vi More than one-third of the world s whale and dolphin species can be found within the Pt. Arena coastal upwelling region. vii In addition, the upwelling supports hundreds of thousands of seabirds living in the largest breeding colonies in the continental US. The upwelling provides nutrient-rich waters that grow food which is consumed by this wildlife here and farther down the coast as far as the Monterey Bay marine sanctuary. Monterey Bay water temperatures and current patterns are strongly affected by the upwelling and California Current sweeping down from the north, which is why these source waters are so important. If the source waters become contaminated, areas farther south are imperiled. Protecting the upwelling zone is akin to how water supply systems protect their source watersheds. Locations and abundance of pinnipeds and cetaceans in the sanctuaries and expansion area are directly related to the abundance of their primary prey which is conditioned by the strength and duration of the deep upwelling and other environmental factors. There are currently five locations off of the coast of California that serve as important whale foraging areas; Gulf of the Farallones, Cordell Bank, Monterey Bay, Channel Islands, and Bahia Loreto. These five areas are currently protected by one or more national marine sanctuaries off the coast of California. But the Point Arena area and Bodega Bay Canyon, two additional places that offer high amounts of foraging habitat for marine mammals, are not currently protected even though they serve as destination feeding areas for a variety of marine mammals, some of which come very long distances to feed there. 2

The proposed expansion also protects parts of the continental shelf and shelf break. Northern fur seals, harbor porpoises, California sea lions, Stellar sea lions, black footed albatrosses, leatherback sea turtles, blue whales and humpback whales are all found over the continental shelf. Pacific white sided dolphins are found over the shelf break. Large humpback whale concentrations are found seasonally in the area between Cordell Bank and Bodega Bay Canyon which is another reason why expansion must include Bodega Bay and Canyon. During the period of fall to winter, seals and sea lions use the beaches on the Farallones Islands as breeding grounds. After 150 years of absence, northern fur seals have once again started to come to the Farallones Islands to breed. This fact gives us hope that our marine protected areas are working to bring back native populations of marine mammals in just the way intended. Blue whales are an endangered species that migrate along the California coast, foraging for euphausiids. These small shrimp-like crustaceans also known as krill are primarily found in highly productive upwelling areas such as the area between the Farallones Islands and Pt. Arena. Blue whales forage on the concentrated patches of krill found in the expansion area; and research has found that higher levels of krill are associated with higher numbers of whales. viii Euphausiids are also found in the Monterey Submarine Canyon, which may mean they are also live within Bodega Canyon. While there is a need for more research on this topic, expansion should occur to protect this potentially important foraging area. The California coast does not have many islands because it is a subduction zone; therefore islands like the Farallones are relatively rare off California. Twelve species of seabirds breed on the Farallones Islands surrounded by ocean waters rich in prey. ix Cordell Bank is also a popular location for seabirds to forage even though there is no roosting place there. A study using satellite tags showed that the black-footed albatross was breeding in the northwest Hawaiian Islands, but commuting to Cordell Bank to find food for its young and then flying back thousands of miles to feed them. In general, carefully selected protected places like the expansion area (sources) can produce fish larvae that are swept by the California Current to fishing grounds (sinks) along the California coast to the benefit of fishermen and the environment. This is why it is important to protect these areas from a variety threats such as oil pollution that hurt larvae. Studies show that the Gulf of Farallones is an important source for larval dispersal, especially for crab and rockfish. Cordell Bank, the Farallon Ridge, and other seamounts and rocky bottom areas in the sanctuaries provide important bottom habitat for fish, like rockfish, and invertebrates. Rockfish are an economically important group of species for commercial and recreational fishers and local economies. It is therefore important for the expansion to occur to increase the protected habitat of economically important fish. Deep sea coral reefs and sponges also provide important habitat for fish and invertebrates as well more rocky areas. Many studies have shown that marine biodiversity increases in areas with three dimensional habitats (i.e., bottom structure) which coral and sponges provide. Corals also provide shelter, feeding, breeding and nursery grounds. Much of the sea floor in the expansion has not been surveyed for coral, but over 100 species of deep sea coral are known from the west coast region. Although we know there are gorgonian corals and sponges in the current sanctuary 3

and at Point Arena, more research needs to be completed to examine the location, size, and continuity of this type of habitat. x Threats to California Coastal Ecosystem Threats to the northern coast of California include: oil spills, seismic testing for offshore oil drilling, destructive fishing practices, overfishing, shipping and coastal and vessel pollution. Marine mammals and seabirds are especially sensitive to oil spills because they feed at the surface or inhabit the surface of the ocean. We also know from other oil spills like the Exxon- Valdez and the Deepwater Horizon that spills can devastate fish, shellfish, and benthic organisms and populations sometimes for decades, especially in cold water environments. Marine mammals are especially sensitive to the extremely loud sounds caused by seismic testing that inevitably accompanies drilling. California is fourth in the nation for oil production and is a major refining center. Without the prohibitions on oil exploration and drilling in the Sanctuary expansion area, seismic testing and oil drilling are significant future possibilities and could disrupt the migration patterns and populations of a number of endangered marine mammals including the blue whale. Large vessel traffic creates many threats to living marine resources from ships strikes, vessel pollution and accidents. Three major shipping lanes converge in the sanctuary which creates a lot of traffic. While sanctuary status does not prevent large vessels from transiting, it does make captains more aware of the sensitivity of the area they are going through and lends weight to proposals to create more defined shipping lanes or other traffic management measures if those are necessary to protect wildlife. The Sanctuary program is already working with the shipping industry to address the risk of whale strikes. xi One of the most direct threats to the environment of sanctuaries is the use of destructive methods of fishing such as bottom trawling. Bottom trawling uses large, heavy nets that capture and kill many untargeted species as by catch and damage the deep sea corals, sponges and other bottom inhabitants. Trawling reduces habitat complexity which may in turn lead to a decrease in fish populations. xii Studies have shown that towed gear can cause reductions in habitat heterogeneity, biomass, productivity, and diversity. Deep sea communities contain slow growing, long-lived, fragile species that are usually poorly adapted to the impacts of towed gear. Because there is so little natural disturbance at that depth, they have not evolved to repair or rebuild after such a disturbance occurs. Many deep sea coral individuals live hundreds or thousands of years and can be killed by trawling in seconds. Other benthic species damaged by trawling perform a variety of other functions in the environment: as prey, as predators, nutrient cycling, etc. When these are removed or damaged by bottom trawling, the rest of the ecosystem suffers. The sea floor is not a flat featureless place. Even without corals or rocks, it has mounds and ridges created by a diversity of marine life including sea cucumbers and different types of marine worms. These are delicate habitats that a bottom trawl can destroy in a matter of seconds. Too 4

little is still known about them which is one reason why we need to protect more coral and sponge habitat from trawling and other threats. As NOAA writes the Environmental Impact Statement on the sanctuary expansion proposal, we strongly believe it ought to assess the impact of bottom trawling and other damaging activities in the existing sanctuaries and expansion area and examine alternatives to these practices. No other offshore human activity is as widespread, intense, or enduring as commercial fishing. Bottom trawling is a major concern off of the coast of California. For example, in the North Pacific region between 1997 and 2001, an average of 81.5 tons of deep sea coral was uprooted every year by commercial fishing. Economic Importance The economic value of this area of relatively healthy ocean is quite large. According to the most recent government statistics, the ocean economy of the two counties (Marin and Sonoma) forming most of the coastline of the proposed sanctuary expansion provided almost 15,000 jobs and nearly $700 million in GDP from coastal tourism, fishing and other marine activities. Sanctuary expansion would ensure that the clean oceans and beaches that sustain these jobs are protected and unpolluted. In terms of commercial fishing, 5.8 million pounds of fish worth $14 million dollars was landed at Bodega Bay in 2011 and 12.4 million pounds of fish worth $22 million dollars was landed at San Francisco. The expanded sanctuary could, in fact, protect the ocean from things like oil spills or drilling that could catastrophically harm this coastal economy. xiii Conclusion The Marine Conservation Institute strongly supports the proposed expansion of Gulf of Farallones and Cordell Bank NMS. There are numerous threatened and endangered species to be protected, probable areas of deep sea corals to be avoided by bottom trawling, and important seabird colonies that depend on the health of this part of the ocean. The local economy is also tied in good measure to the continued health of the ocean between Bodega Bay and Pt. Arena. In fact, there are many reasons for NOAA to consider extending the expansion area farther up the coast. For all these reasons, we urge NOAA to go forward with the expansion proposal. Endnotes i NOAA. Gulf of the Farallones National Marine Sanctuary. 25 Jan. 2013. < http://farallones.noaa.gov/about/welcome.html ii NOAA. Gulf of the Farallones and Cordell Bank National Marine Sanctuaries Proposed Northern Expansion. 25 Jan. 2013. <http://farallones.noaa.gov/manage/northern_area.html iii NOAA. Cordell Bank National Marine Sanctuary. 25 Jan. 2013. http://cordellbank.noaa.gov/ 5

iv NOAA. Gulf of the Farallones and Cordell Bank National Marine Sanctuaries Proposed Northern Expansion. 25 Jan. 2013. http://farallones.noaa.gov/manage/northern_area.html v Kudela, Raphael, Banas, Neil, Barth, John, et. Al. New Insights into the Controls and Mechanisms of Plankton Productivity in Coastal Upwelling Waters of the Northern California Current System. Oceanography 21.4 (2008):46-59. vi Wing, Stephen R., Louis W. Botsford, Stephen V. Ralston, and John L. Largier. "Meroplanktonic Distribution and Circulation in a Coastal Retention Zone of the Northern California Upwelling System." Liminology and Oceanography 43.7 (1998): 1710-1721 vii Keiper, C. A., D. G. Ainley, S. G. Allen, and J. T. Harvey. "Marine Mammal Occurrence and Ocean Climate Off Central California, 1986-1994 and 1997-1999." Marine Ecology Press Series 289(2005): 285-306. viii Croll, Donald A., Baldo Marinovic, Scott Benson, Francisco P. Chavez, Nancy Black, Richard Ternello, and Bernie R. Tershy. "From Wind to Whales: Trophic Links in a Coastal Upwelling System." Marine Ecology Press Series 289(2005): 117-130. ix Airme, Satie, Steven Gaines, and Chris Caldow (2003). Ecological Linkages: Marine and Estuarine Ecosystems of Central and Northern California. U.S. Department of Commerce National Oceanic and Atmosphere Administration National Ocean Service. x Morgan, Lance E., Chih-Fan Tsao, John M. Guinotte. Status of Deep Sea Corals in US Waters. Marine Conservation Institute. 2006 xi Bernman-Kowalewski, Michelle, Frances M.D. Gulland, Sarah Wilkin, John Calambokidis, Bruce Mate, Joe Cordaro, Dave Rotstein, Judy St. Leger, Paul Collins, Krista Fahy, and Samual Dover. "Association Between Blue Whales (Balaenoptera musculus) Mortality and Ship Strikes Along the California Coast." Aquatic Mammals 36.1 (2010): 59-66. xii Watling, Les, and Elliott A. Norse. "Disturbance of the Seabed by Mobile Fishing Gear: a Comparison to Forest Clearcutting." Conservation Biology 12.6 (1998): 1180-1197. xiii NOAA. "Ocean and Great Lakes Jobs Snapshot." 19 Dec. 2012. http://www.csc.noaa/gov/snapshots/ 6