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HOPE Helping Our Peninsula's Environment |
Monterey Bay National Marine Sanctuary
Saturday, December 8, 2001
Re: Sanctuary Management Plan Requested Improvements
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Sanctuary n. a sacred place, a place of refuge, a wildlife preserve. -New American Webster Dictionary 1972 |
Let us begin by bringing to your attention that our Sanctuaries have important values other than economic. While Ecological Values are often well recognized and described, our Sanctuaries also have important Intrinsic Values and Aesthetic Values which are often overlooked by agencies, but are vitally meaningful to the appreciative public and to the biota who have lived here for untold millennia before humans arrived.
Irreversible Harm Requires the Precautionary Principle
Those who make money by extraction of environmental phenomena typically trivialize environmental impacts no matter how much evidence exists complaining "There is no incontrovertible proof yet."
They know most science, including physics, is less than an absolute certainty and want an impossible standard of proof so they can continue making money as long as possible while the environmental damage they are causing grows.
Their position is equivalent to having smoke pouring out of a house and they stop you from calling the fire department until you can prove it is on fire - that you can see flames is not good enough. While the house is burning down they want a study that measures the temperature of the wood. Then they'll argue you need to have evidence of burned wood.
If we wait until an effect is detectable, environmental damage may be irreversible or impossible to mitigate; an example is radiation poisoning.
Causing a human's death is irreversible and absolutely impossible to mitigate.
Causing a wild animal or plant to go extinct is irreversible and absolutely impossible to mitigate. Humans have caused numerous species to go extinct and are forcing many more to the brink of extinction.
California's Environmental Quality Act (CEQA) specifically recognizes this precautionary principle in defining a "Significant effect on the environment" as a "potentially" substantial, adverse change in the environment - not only the fewer "certain" environmental harms. (Sec. 21068)
Rachel's Environment and Health Weekly #586 reports: "An international group of scientists, government officials, lawyers, and labor and grass-roots environmental activists met January 23-25, 1998 at Wingspread in Racine, Wisconsin to define and discuss the precautionary principle. After meeting for two days, the group issued the following consensus statement:
"Wingspread Statement on the Precautionary Principle
'The release and use of toxic substances, the exploitation of resources, and physical alterations of the environment have had substantial unintended consequences affecting human health and the environment. Some of these concerns are high rates of learning deficiencies, asthma, cancer, birth defects and species extinctions, along with global climate change, stratospheric ozone depletion and worldwide contamination with toxic substances and nuclear materials.
'We believe existing environmental regulations and other decisions, particularly those based on risk assessment, have failed to protect adequately human health and the environment --the larger system of which humans are but a part.
'We believe there is compelling evidence that damage to humans and the worldwide environment is of such magnitude and seriousness that new principles for conducting human activities are necessary.
'While we realize that human activities may involve hazards, people must proceed more carefully than has been the case in recent history. Corporations, government entities, organizations, communities, scientists and other individuals must adopt a precautionary approach to all human endeavors.
'Therefore, it is necessary to implement the Precautionary Principle: When an activity raises threats of harm to human health or the environment, precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically. In this context the proponent of an activity, rather than the public, should bear the burden of proof.
'The process of applying the Precautionary Principle must be open, informed and democratic and must include potentially affected parties. It must also involve an examination of the full range of alternatives, including no action.' [End of statement.]"
PROJECTS
We respectfully request you consider how to place a high priority on the following suggestions to significantly increase protection of Intrinsic, Aesthetic and Ecological Values of Sanctuary natural phenomena.
Prohibit Oil Drilling
Oil Tankers Outside Sanctuary
Study and Prohibit Harmful Noise
Pesticide Study and Reduction
Some 13 million pounds of pesticides were reported sprayed on Salinas Valley crops in 1996. A substantial amount of those pesticides run off into the Salinas River and then into our Sanctuary causing potentially catastrophic harm.
Fertilizers - Nitrates & Phosphorus Permitting, Study and Reduction
A hypoxic "Dead Zone" in the Gulf of Mexico the size of New Jersey (20,000 square kilometers in 1999) is caused by nitrogen runoff from fertilizers used in the Mississippi River watershed. The EPA task force hopes to reduce the size of the dead zone to 5,000 square kilometers by 2015 by cutting the amount of nitrogen reaching the Gulf by 30%. Scientific American, July 2001
No official source (the County Agricultural commissioner's office, the UC Extension Office and the Farm Bureau) has any idea how many million pounds of fertilizers and nitrates are applied to the Salinas Valley crops yearly as fertilizer use does not require a permit. Amounts can be very roughly estimated by the ratio of pesticide to fertilizer use as 10 pounds of fertilizer for every pound of active pesticide ingredient (or 1.5 pounds of fertilizer per pound of pesticides). Using this admittedly rough estimate, there may be as much as 20 million pounds of nitrate and phosphorus fertilizer applied in the Salinas Valley yearly.
"Up to 84% of the nitrogen fertilizers applied to turfgrass may leach to groundwater, with the average hovering between 5% and 10%." Petrovik, A.M. 1990 The fate of nitrogenous fertilizers applied to turfgrass. Journal of Environmental Quality 19:1-14
This indicates that yearly at least a million pounds of fertilizer, and probably many times more, may make its way into Salinas Valley groundwater, runs off into the Salinas River and from there directly into our Sanctuary.
"Nitrogen and phosphorus compounds from sewage discharges, fertilizers and some industrial wastes nourish the algae, causing their populations to explode and release poisons." World Wildlife Fund, 1990
"Vast blooms of Algae have emerged as the most serious effect of marine pollution." Ibid "In the summer of 1988, a slick of toxic algae more than 10 meters deep and 10 kilometers wide, spread through the Kattegat and Skagerrak, which separate the coasts of Sweden, Norway and Denmark. More than 200 kilometers of coastline was blighted, beaches were closed, millions of fish are thought to have died; it became known as the 'Marine Chernobyl.'" Ibid
"Toxic algae caused sea lion die-off" Herald headline, Jan 7(?) 1999 "Over 400 sea lions in Central Coast perished in 1998" This was due to domoic acid produced by microscopic marine organism called diatoms. "Domoic acid is poisonous to people as well as animals." It is a poison created when a microscopic algae, Pseudo-nitzchia, multiplies rapidly in the sea. The toxin cause neurological problems, with seizures and severe depression.
"A toxin [Domoic acid] that has killed at least 25 sea lions along the Central Coast [of California] in the past couple of weeks was identified Tuesday as the same one that killed pelicans and cormorants in Monterey Bay in 1991 and dozens of sea lions in 1998." Herald, July 12,00 pB1
Prohibit Trawling
Large No-Take Areas
Monterey Peninsula Marine Park and Conservation Area
Include All Harbors
Prohibit Seawalls
Military Underwater Vehicle Prohibitions
Thank you sincerely,
David Dilworth, Acting Secretary