September 6, 2024
Samantha Murray
President
Marine Resources Committee
California Fish and Game Commission
715 P Street
16th Floor
Sacramento, CA 95814
Subject: Market Squid Fishing within Channel Islands National Park and Channel Islands National Marine Sanctuary.
Dear Ms. Murray:
It has recently come to our attention that conservation community members appointed to the Squid Fishing Advisory Committee presented a proposal to protect Scripps’s murrelet in and around Channel Islands National Park. The Coalition to Protect America’s National Parks supports their proposal to close night-time fishing around Santa Barbara, Anacapa, and San Miguel Islands to protect the breeding grounds of the Scripps’s murrelet. The California Fish and Game has this rare opportunity to maintain an economically sustainable squid fishery while protecting the natural diversity and abundance of marine life and the structure, function, and integrity of marine ecosystems.
The Coalition is a non-profit organization composed of more than 2,800 retired, former, and current employees of the National Park Service who collectively have over 50,000 years of experience managing and protecting our national parks. The Coalition studies, educates, speaks, and acts for the preservation of America’s National Park System. We support this proposal for the following reasons:
1. The National Park Service is legally mandated to conserve wild life unimpaired for the enjoyment of future generations. However, they cannot do this alone with neighboring jurisdictions permitting activities potentially impacting natural resources that depend on the park islands for continued survival.
a. The Scripps’s murrelet is a nocturnal seabird. Research shows that artificial lights at night cause high mortality of seabirds, one of the most endangered groups of birds globally. There are two primary causes of mortality: 1) Fledglings of burrow-nesting seabirds, and to a lesser extent adults, are attracted to and then grounded (i.e., forced to land) by lights when they fly at night. 2) Increased predation by predatory birds (including barn owls and gulls) (Rodríguez et al. 2019).
b. The Commission has taken action in the past by requiring shields. However, these actions do not prevent the scattering of artificial lights, especially during periods of fog and varied sea-state. Shielding, even when the shields extend beyond the tip of the bulb, does not prevent the reflection and scattering of horizontally.
2. Channel Islands National Park was established by Congress on March 5, 1980, “In order to protect the nationally significant natural, scenic, wildlife, marine, ecological, archaeological, cultural, and scientific values of the Channel Islands in the State of California” (Pub. Law 96-199). The Scripps’s murrelet is a State-listed threatened species. Eighty percent of the United States population nests within Channel Islands National Park. The primary nesting locations are Santa Barbara, Anacapa, and San Miguel Islands. Santa Barbara Island has the largest Scripp’s murrelet colony in the United States, and possibly the world.
3. The National Park Service continues to do its part in protecting the Scripps’s murrelet.
a. Channel Islands National Park has a proven record of ecological restoration.
i. The park eradicated the non-native black rat from Anacapa Island preventing Scripps’s murrelet egg predation.
ii. The park has restored nesting habitat on Santa Barbara and Anacapa Islands.
iii. The park continues to conduct seabird monitoring.
iv. The park has established policies to reduce island-based lighting during the nesting season.
Current harvest information provided by the Department continues to reinforce the height of the season around the Channel Islands (October-February). The closure as called for:
a. Only prohibits night-time fishing and the use of artificial lights around Santa Barbara, Anacapa, and San Miguel Islands. The critical period necessary to protect the breeding/nesting/fledgling period of the State-listed threatened Scripps’s murrelet is February through October. The prohibition would be in place (February through October) outside of the highest season of market squid harvest (late fall through early winter).
b. It does not prohibit daytime fishing around Santa Barbara, Anacapa, and San Miguel Islands.
c. The proposal does not call for prohibiting or restricting the fishery around Santa Cruz and Santa Rosa Islands where squid harvest is the greatest. However, a ban on all night-time fishing would benefit other nocturnal seabird communities nesting within Channel Islands National Park.
In closing, we want to thank the Commission for actions they have taken to protect and manage California’s marine ecosystems with the creation of marine protected areas and special closures. However, when it comes to protecting the Scripps’s murrelet not enough has been done to protect this State-listed threatened species. In 2004, the Commission prohibited the take of market squid for commercial purposes using attracting lights in all waters of the Gulf of the Farallones National Marine Sanctuary. This regulation also applies to vessels pursuing squid for live bait purposes. It is time to do the same on a more limited basis to protect the State-listed threatened Scripps’s murrelet within an area that we as American’s set aside for future generations – Channel Islands National Park and Channel Islands National Marine Sanctuary.
Sincerely,
Philip A. Francis, Jr.
Chair of the Executive Council
Coalition to Protect America’s National Parks
2 Massachusetts Ave NE, Unit 77436, Washington, DC 20013
Phone: (202) 819-8622
cc: Ethan McKinley, Superintendent, Channel Islands National Park