October 25, 2002

Rick Hanks, U.S. Department of the Interior
Bureau of Land Management
California Coastal National Monument
299 Foam Street
Monterey, CA 93940

Re: Scoping Comments on California Coastal National Monument

Dear Mr. Hanks:

We appreciate this opportunity to submit the following scoping comments on the California Coastal National Monument on behalf of The Marine Mammal Center.

The California Coastal National Monument (the Monument) represents a long-needed rationalization of the management of the unappropriated or unreserved Federal islands, rocks, reefs and pinnacles above mean high tide within 12 nautical miles of the shoreline. As part of a nearshore ocean zone rich in nutrients supporting a diverse array of habitats and organisms, these unique geologic features provide foraging and breeding habitat for a number of marine mammal species, as well as feeding and nesting habitat for hundreds of thousands of sea birds. The Marine Mammal Center supports the full implementation of the executive proclamation designating the Monument and the clear intent of this proclamation to ensure the management the subject area to maximize protection for its important values in the public interest.

We would offer the following observations as comments for the record during the scoping process:

The Monument provides countless critical pinniped haul-out habitats, and these need to be protected. These haul-out areas may provide important refuge for pinnipeds during oil spill incidents. The Monument provides a life-cycle living laboratory for marine mammals, seabirds and shorebirds, and breeding and nesting areas safe from terrestrial predators. The management regime for the Monument should provide protection for these populations, at all life stages, as much as possible.

Wildlife disturbance associated with low-altitude over-flights by conventional fixed-wing aircraft and powered and non-powered light aircraft should be minimized, particularly as it impacts birds and pinnipeds. Buffer zones, and where necessary, exclusion zones, precluding wildlife interference associated with sea kayaking and personal watercraft should be implemented to protect birds and pinnipeds. Research activities utilizing Monument features should be carefully monitored and managed in such a manner as to ensure "no harm" to Monument values.

Surrounding many of the offshore features now part of the Monument is some of the only relatively undisturbed inter-tidal zone remaining on the California coast. Management regimes for this near-intact inter-tidal ecosystem should ensure continued protection of this important "baseline" reference habitat. Important data, available nowhere else on the California coast, is embodied in the remnant inter-tidal populations of the Monument.

The hard rock substrate surrounding the offshore rocks of the Monument provides important habitat critical to several rockfish species now determined to be subject to serious population declines. This sub-tidal ecosystem should also be protected by the management plan for the Monument, to the maximum extent possible, since it represents the key food source for the marine mammals and seabirds that utilize the offshore rocks. Recent research suggests that offshore islands may be especially important feeding refuges during periods of low ocean productivity, such as ENSO events, because food resources such as shoaling forage fishes appear to congregate near the islands.

As BLM develops the management plan for the Monument, the plan should consider indirect effects of adjoining activities on the values for which the Monument was established. The management plan should clarify and refine current regulations and laws that protect natural resources where necessary. Since birds and marine mammals utilize all elements of the ecosystem, including the inter-tidal zone and nearshore waters, management regimes should ensure stewardship of the whole system. It is necessary to protect not only the offshore rocks, but also the animals that use them.

Thank you for this opportunity to provide these scoping comments on the preparation of a NEPA document for the California Coastal National Monument. We look forward to reviewing the DEIS on this project.

Sincerely,

B.J. Griffin
Executive Director