January 27, 2023
Marine Monument Superintendent
U.S. Fish and Wildlife Service
300 Westgate Center Drive
Hadley, MA 01035
Re: Comments on U.S. Fish and Wildlife Service and National Oceanic and Atmospheric Administration’s Intent to Prepare a Draft Monument Management Plan for the Northeast Canyons and Seamounts Marine National Monument
Dear Ms. Petersen,
On behalf of the 41 undersigned organizations, we submit these comments to the U.S. Fish and Wildlife Service (FWS) and National Oceanic and Atmospheric Administration (NOAA) (“Co-Trustees”) regarding their intent to prepare a draft monument management plan for the Northeast Canyons and Seamounts Marine National Monument (“Monument”).1See 87 Fed. Reg. 79,901 (Dec. 28, 2022).
President Obama designated the Monument in 2016 to safeguard fragile and interconnected ecosystems, improve ocean resilience, and sustain tourism, recreation, fishing, and other sectors of the New England economy that depend upon a healthy marine ecosystem.2See Presidential Proclamation No. 9496, 81 Fed. Reg. 65,161 (Sept. 15, 2016) (the “2016 Proclamation”). Located about 130 miles off the coast of Cape Cod and encompassing three undersea canyons deeper than the Grand Canyon and four seamounts rising higher than any mountain east of the Rockies, the Monument is recognized as “one of the Atlantic Ocean’s most biologically productive and important marine environments, and one of science’s greatest oceanic laboratories.”3U.S. Department of the Interior, Administration Leaders Applaud President Biden’s Restoration of National Monuments, https://www.doi.gov/pressreleases/administration-leaders-applaudpresident-bidens-restoration-national-monuments (updated Oct. 8, 2021). The Monument spans only 1.5% of the Atlantic region of the U.S. Exclusive Economic Zone (EEZ) and 0.11% of the entirety of the U.S. EEZ, yet its diversity of topography, depths, and substrates protects a diverse array of marine life including deep-sea corals, fishes, sea turtles, whales, and seabirds.
The Monument is a national treasure that must now have a clearly defined and comprehensive management plan. As the Co-Trustees embark on the development of a management plan, it is critical to keep front of mind the recent recommendation from scientists worldwide: We must set aside at least 30% of land and ocean by 2030 to stem biodiversity loss and build resilience against climate change.4See E. Dinerstein et al., “A Global Deal for Nature: Guiding Principles, Milestones, and Targets,” Science Advances 5, no. 4 (April 2019): eaaw2869, https://doi.org/10.1126/sciadv.aaw2869. President Biden embraced this call when he restored protections to the Monument in 2021,5See Presidential Proclamation No. 10287, 86 Fed. Reg. 57,349 (Oct. 15, 2021) (the “2021 Proclamation”). and the management plan should likewise prioritize conservation outcomes that protect biodiversity and address the climate crisis to ensure the area will flourish. Marine protected areas are a key tool for maintaining, restoring, and enhancing ecosystem resilience in a changing climate,6See Jenna Sullivan-Stack et al., A Scientific Synthesis of Marine Protected Areas in the United States: Status and Recommendations, Front. Mar. Sci. Sec. Ocean Solutions (May 18, 2022), https://doi.org/10.3389/fmars.2022.849927. and the Canyons and Seamounts provide strong and permanent protection to their highly vulnerable species and ecosystems. A successful management plan will guide future stewardship of this national treasure and ensure sufficient investment in safeguarding and sharing the story of this important place. To effectively manage the Monument and to achieve the goals, vision, and guiding principles of the 2016 and 2021 Presidential Proclamations, we offer the following recommendations.
The management plan should include an action plan to inventory the Monument’s resources and identify and minimize any impacts to those resources. As the only marine national monument in the U.S. Atlantic Ocean, the Monument provides refuge for spectacular wildlife and habitats. Among other things, the slow-growing deep-sea corals, large marine mammals, apex predator fish, migratory seabirds, and unseen critters make this area a biodiversity hotspot. Some of these deep-sea organisms are highly vulnerable to human disturbance.7See Risk, M.J., et al., Lifespans and growth patterns of two deep-sea corals: Primnoa resedaeformis and Desmophyllum cristagalli, Hydrobiologia 471, no. 1-3 (2002): 125–131; see also Roark, E.B., et al., Extreme Longevity in proteinaceous deep-sea corals, Proceedings of the National Academy of Sciences of the United States 106, no. 13 (March 23, 2009): 5204–5208. To sufficiently protect these unique and fragile ecosystems, the Co-Trustees should undertake a comprehensive inventory of the natural and cultural resources contained in the Monument. Such an assessment will facilitate resource protection and provide a baseline for monitoring the area’s health and productivity. The action plan should also assess current impacts to the Monument and address how the Co-Trustees will minimize such impacts.
The management plan should establish a scientific monitoring, exploration, and research plan. It is estimated that only 50 percent of the potential species in the Monument have been discovered to date; much remains to be uncovered about these unique, isolated environments and their geological, ecological, and biological resources.8See Kelly NE, Shea EK, Metaxas A, Haedrich RL, Auster PJ. 2010. Biodiversity of the Deep-Sea Continental Margin Bordering the Gulf of Maine (NW Atlantic): Relationships among Sub-Regions and to Shelf Systems. PLoS ONE 5(11): e13832. In recent years, scientists from government and academic oceanographic institutions have conducted limited research within the Monument using remotely operated vehicles (ROVs), airplanes, research vessels, and submarines—such research should be expanded to yield important new information about living marine resources. But beyond learning about what the Monument contains, scientists can also use this critical living laboratory to study the impacts of climate change and provide strategic information to managers. Therefore, the management plan should include a scientific monitoring, exploration, and research plan that seeks to document the biodiversity in the monument and answers pressing questions about the impacts of climate change on our ocean.
The management plan should include a comprehensive public education and outreach program. The Monument is a public resource that serves as a unique opportunity for the public to connect with and build an appreciation for our deep-sea ocean ecosystems. Because the Monument itself is not physically accessible to the public, the Co-Trustees should provide creative ways to connect the public to this special place. For example, previously live streamed research expeditions led to massive public engagement with the Monument, and similar events would provide a great opportunity for future engagement. It is important that such programs create and share accessible and inclusive educational resources in multiple languages. Additionally, education and outreach programs should prioritize serving communities that have historically not had access to nature and outdoor spaces.
The Monument’s management plan should include monitoring and enforcement programs to effectively protect the unique ecological resources within the Monument. When President Obama designated the Monument, his presidential proclamation identified numerous prohibited activities within the Monument’s boundary.9See 81 Fed. Reg. at 65,164-65 The management plan should clearly define the prohibited activities within the Monument. Successful protection and maintenance of the Monument’s ecosystems and biological diversity will require adequate monitoring and enforcement to prevent unlawful activities. The management plan should therefore include strategies to ensure adequate year-round monitoring and enforcement programs. Further, the Co-Trustees should identify strategic partnerships with local enforcement agencies to coordinate enforcement actions and share resources and information.
The Monument’s management plan should include the development of an effective permitting program to ensure compliance with Monument rules and regulations. The management plan should clearly set forth management measures for the activities permitted within the Monument (e.g., research and scientific exploration, sailing or bird and marine mammal watching).10See 81 Fed. Reg. at 65,165. It is essential that the Co-Trustees ensure permitted activities are performed consistently with care and management of the objects within the Monument. In addition to establishing monitoring and enforcement plans, the Co-Trustees should develop an effective permitting program. Such a program, including the permit application, evaluation, and granting process, should allow opportunity for public participation and be based on the best available science.
The management plan should include a robust process to ensure effective collaboration and coordination among the Co-Trustees, stakeholders, and additional relevant agencies. As Co-Trustees of this remarkable area, FWS and NOAA must successfully coordinate to effectively manage the Monument. Additionally, to date, thousands of people from across the nation have raised their voices in support of the Monument. The management plan should include a robust process for continued engagement of the public and stakeholders in management of this extraordinary public resource. Finally, it is not only important for the Co-Trustees to successfully coordinate; they must also coordinate with the numerous other relevant federal agencies.
Finally, the management plan should include a requirement to review and update the plan periodically, at least every 10 years if not sooner. Such a review should be preceded by a comprehensive assessment of the status of human uses, water quality, habitat, living marine resources, cultural resources, and ecosystem services of the monument and enforcement of the monument’s regulations. The management plan should then be revised to address issues that surface in the assessment.
We thank FWS and NOAA for the opportunity to provide these comments.
Blue Planet Strategies
Californians for Western Wilderness
Coalition to Protect America's National Parks
Conservation Law Foundation
Creation Justice Ministries
Defenders of Wildlife
Endangered Species Coalition
Environmental League of MA
Friends of the Earth US
Healthy Ocean Coalition
Hispanic Access Foundation
Inland Ocean Coalition
International Fund for Animal Welfare
|League of Conservation Voters
Marine Conservation Institute
Menunkatuck Audubon Society
National Ocean Protection Coalition
National Parks Conservation Association
National Wildlife Federation
Natural Resources Defense Council
Santa Barbara Zoo
The Connecticut Audubon Society
The New England Aquarium
The Ocean Project
The Wilderness Society
Virginia Aquarium & Marine Science Center
- 1See 87 Fed. Reg. 79,901 (Dec. 28, 2022).
- 2See Presidential Proclamation No. 9496, 81 Fed. Reg. 65,161 (Sept. 15, 2016) (the “2016 Proclamation”).
- 3U.S. Department of the Interior, Administration Leaders Applaud President Biden’s Restoration of National Monuments, https://www.doi.gov/pressreleases/administration-leaders-applaudpresident-bidens-restoration-national-monuments (updated Oct. 8, 2021).
- 4See E. Dinerstein et al., “A Global Deal for Nature: Guiding Principles, Milestones, and Targets,” Science Advances 5, no. 4 (April 2019): eaaw2869, https://doi.org/10.1126/sciadv.aaw2869.
- 5See Presidential Proclamation No. 10287, 86 Fed. Reg. 57,349 (Oct. 15, 2021) (the “2021 Proclamation”).
- 6See Jenna Sullivan-Stack et al., A Scientific Synthesis of Marine Protected Areas in the United States: Status and Recommendations, Front. Mar. Sci. Sec. Ocean Solutions (May 18, 2022), https://doi.org/10.3389/fmars.2022.849927.
- 7See Risk, M.J., et al., Lifespans and growth patterns of two deep-sea corals: Primnoa resedaeformis and Desmophyllum cristagalli, Hydrobiologia 471, no. 1-3 (2002): 125–131; see also Roark, E.B., et al., Extreme Longevity in proteinaceous deep-sea corals, Proceedings of the National Academy of Sciences of the United States 106, no. 13 (March 23, 2009): 5204–5208.
- 8See Kelly NE, Shea EK, Metaxas A, Haedrich RL, Auster PJ. 2010. Biodiversity of the Deep-Sea Continental Margin Bordering the Gulf of Maine (NW Atlantic): Relationships among Sub-Regions and to Shelf Systems. PLoS ONE 5(11): e13832.
- 9See 81 Fed. Reg. at 65,164-65
- 10See 81 Fed. Reg. at 65,165.