A Letter From Clifton Dean Ferguson

Dear Clatsop
County Commissioners;


Thank you for
taking the time to read my comments and concerns regarding Marine
Reserves off the Oregon Coast. Proposals have been submitted and are
now available for public review.



I have the
following comments for your consideration:



1)



I
would like to express my disappointment at the Marine Reserve
proposals submitted for the North Oregon Coast area for the following
reasons:

a.



You
may or may not be aware, but much of the year bottom fishing is
constrained to inside 40 fathoms. This leaves very little productive
bottom fishing areas for those of us fishing out of Columbia River
ports. The major areas inside 40 fathoms we have access to are the
Tillamook head and Cannon Beach areas.

b.



Closing
these areas to recreational bottom fishing effectively closes bottom
fishing to North Coast sport fisherman year around.

c.



These
closure areas would have the same affect as having the ODFW simply
close the area north of Cape Falcon to all bottom fishing without the
expense of maintaining Marine Reserves.

d.



The
Tillamook Head Marine Reserve closes one of the most productive
salmon, bottom fishing, and crabbing areas available to North Coast
residents. This will have a major economic impact upon:



i.



Charter
operators who run bottom fishing trips. This will effectively kill
the bottom fishing charter business from Columbia River ports.



ii.



Commercial
salmon trollers who frequent this area as this is one of the most
productive areas certain times of the year.



iii.



Commercial
crabbers who frequently fish in that area.



iv.



Recreational
fisherman and the plethora of industries that are supported by tourism
and fishing as that area will now be out of bounds.

e.



The
Cannon Beach and Manzanita reserve is troublesome due to the following:



i.



The
size of the MPA extends north to encompass Tillamook Head. This is a
VERY large area singled out as an MPA.



ii.



As
your aware, MPAs will be managed by rule making specific to each MPA.



iii.



As
proposed, commercial fishing has been singled out as being allowed in
the MPA. No mention of recreational fishing is made in the proposal.
One of the reasons cited for the need of Marine Reserves is due to
excessive commercial harvest. Here we are allowing commercial
harvest exclusively within an MPA. I do not believe that is congruent
with the spirit of an MPA and certainly not the Marine Reserve process.



iv.



Should
surfing, paddling, recreational fishing, and commercial fishing all be
equally allowed within the MPA then certainly I have much less
objection to the proposal.

f.



One
of the stated goals of a Marine Reserve is to stabilize fishing
regulations and opportunities (provide safe haven to “Big Fat Females”
in order to increase overall fish populations). This goal cannot be
studied if ALL fishing areas are closed. We would never know if the
MR has been successful in providing a net increase in fishing
opportunities and populations without areas adjacent to a MR remaining
open to fishing.

g.



I
personally fish these areas frequently and spend in excess of $15,000
per year on fishing equipment, electronics, fuel, bait, licenses,
launch fees, etc. These closures will cause a considerable reduction
in fishing opportunities and therefore a reduction in economic
activity as far as my dollars are concerned.

h.



The
ODWF has expressed concern over declining revenues in license fees.
One of the reasons for this decline is continued erosion of fishing
opportunities. These closures will be one of the largest losses of
fishing opportunities ever implemented. I would anticipate another
large decline in license sales with the implementation of these
reserves. This past year I obtained a fishing license in both Oregon
and Washington, but fished nearly exclusively out of Ilwaco. Should
these productive bottom fishing areas be closed off the coast of
Oregon I see no reason for me to purchase an Oregon fishing license
next year. I will fish exclusively from Washington ports.



2
I
would like to express my disappointment at the Marine Reserve
proposals as I was never contacted by any of the groups proposing
marine reserves along the North Coast.

a
The
ODFW stated many times that involvement by Ocean users would be
critical in considering these proposals.

b
I
am an Ocean user but was never contacted, nor do I know of any other
Ocean users in my area that were contacted.

c
The
process we were promised was not followed and therefore these proposed
areas are invalid.

3
I
DO support the Depoe Bay proposal and any other proposal that is
reasonable and was done via collaboration of all the affected parties.

a
I
believe strongly that this is the road toward successful
implementation of Marine Reserves.

b
It
is in alignment with the Governor’s Executive Order #08-07 and avoids
severe economic impacts to the coast communities.



Again, thank
you for taking the time to listen to my comments and concerns and
thanks for your involvement in this process.



Sincerely,



Clifton Dean
Ferguson

OPAC

There is a proposal to establish marine reserves off the Coast of Oregon. The Oregon Ocean Policy Advisory Council (OPAC) has been legislatively mandated to advise the governor regarding marine reserves. OPAC will be meeting in Florence, Oregon on October 23 and 24, 2008 to consider 20 proposed sites and to make recommendations to the governor as to which should become marine reserves. Marine reserves, as I understand, them prohibit all public human activies and even entry. No commercial or sports fishing, or any ‘extractive’ activity would be allowed. In fact they areas would be completely off-limits, forever, except for scientific research. Three marine reserve sites are being proposed in waters off Clatsop County that are linked with marine protected areas, from Tillamook Head south to Cape Falcon in Tillamook County. In effect, if these three areas are adopted, they would close important ocean waters to charter boat operator, crabbers and commercial fishermen alike. The Board of County Commissions has taken a stand against establishing additional no fishing area without releasing areas already off limits. The impact and cost to our communities would be too high. For more information go to the Oregon Marine Reserves site: www.oregonmarinereserves.net The following are excerpts from this web site: How were sites proposed? Oregon Ocean Policy Advisory Council Marine Reserves Process PROPOSAL FORM FOR SITES FOR FURTHER EVALUATION Please submit one proposal per site. Complete and submit the two sections of this proposal form. Attach your answers from section 2 to this form, including a map showing the proposed boundaries of the site. Proposals can be submitted to the Oregon Department of Fish and Wildlife up until September 30, 2008. Where to submit your proposal: By mail: Oregon Department of Fish and Wildlife OPAC Marine Reserves Process 2040 SE Marine Science Dr. Newport, OR 97365 By email: Odfw.MarineReserves@state.or.us (please include “Submit Proposal” in the email subject line) SECTION 1: CONTACT INFORMATION PLEASE FILL IN THE FOLLOWING INFORMATION: Please type, or print legibly to ensure we are able to contact you with any questions. Attach this sheet as the first page of your proposal. 1. A Name for Your Proposed Site: Tillamook Head Marine Reserve 2. Name of Principal Contact: Mike Manzulli & Nadia Gardner 3. Affiliation/Organization: Coastal landowners and residents 4. Daytime Phone: (503) 440‐7862 5. Email: manzulli@hotmail.com 6. Mailing Address: P.O. Box 1281 Cannon Beach, OR 97110 7. Additional Information: PROPOSAL FORM FOR SITES FOR FURTHER EVALUATION What information has be submitted? Where are these sites located?

Since 1999 3 large areas of our local ocean have been closed to our drag fishermen. First, the state of Washington closed all it’s state waters, out to three miles. Then in 2001 a lawsuit brought against the National Marine Fisheries Service by Oceana, the Natural Resource Defense Council, and the pacific Marine Conservation Council was ruled in favor of the environmentalist. The result closed a swath of water from Canada to Mexico between 50 and 250 fathoms to drag fishermen called the Rockfish Conservation Area. This area alone represented 75% of the traditional fishing grounds of our local drag fishermen. Off cannon Beach this area is over 30 miles wide. Then in 2005 the last large area closure was made when Oceana threatened another lawsuit. This area closure is called the Essential Fish Habitat and closes the ocean from the 700 fathom line as far out as any bottom fishing vessel can fish. Drag fishermen have modified their fishing techniques to provide net designed that do not drag across the ocean floor and thus are environmentally friendly. The new nets have “excluders” that greatly reduce if not eliminate Rockfish species and retain the targeted Sole. The vessels now have location and observation methods that are being overseen by governing bodies. All commercial vessels are required to have monitoring systems( black boxes that operate 24 hours a day 7 days a week / all 365 days), and human observers. Despite these improvement no water have been reopened to our fishermen. The local fishing fleet has been reduced to half as a direct result of these three large area closures. If the state waters are also closed fishermen will be put out of business and processors severely harmed. These state water closures include sports fishermen as well as commercial. Our local economy would be delt a huge blow and our communities would face further devastation. The County Board of Commissioners is requesting the state review these initial federal water closure and consider the impact upon our local economy and communities. If state waters are to be closed can federal waters be re-opened? To date the Oregon governing bodies has not even attempted to negotiate with the Federal authorities. If you have an opinion please sent it to Terry Thompson, the Lincoln County Commissioner and representative for Lincoln, Tillamook and Clatsop Counties on OPAC before October 23- 24 meeting. tthompson@co.lincoln.or.us Attached are map showing the waters already closed to fishing. Map of the Rockfish Conservation Area Closure :

The following map shows the Essential Fish Habitat Closure: