[PAL]

Former SAC president Bob Fletcher read this letter into the record, excerpted below. MJ Kennedy and I both signed it, as the ground rules have been continually changed, usually at the last minute, making sound decision making next to impossible.

Dear Chairman Benninghoven:


We, the undersigned members of the South Coast Regional Stakeholders Group (SCRSG), are writing to express serious concerns with the direction of the South Coast Marine Life Protection Act (MLPA) planning process.


When we agreed to constructively participate in this project, we did so with the belief that the process would be fairly adjudicated, unbiased, open and transparent based on consistent direction and quality science. Current events demonstrate this is not the case.


Laboring mostly in the dark and lacking information (habitat mapping, LOPs, etc) which is vital to good judgment, we nonetheless completed our first round of network proposals.


These have now been analyzed by the Science Advisory Team (SAT). As of the Blue Ribbon Task Force’s (BRTF) recent meeting, none, not even the most preservation oriented plans - could make the grade. This is astonishing. Those of us with intimate, expert knowledge of the study region expected better results. Although the proposed networks may in fact require adjustment, we believe most of the shortcomings lie with the data and its analysis. Many SAT members said as much during their last meeting.

We respectfully disagree with I-team statements that data resolution good enough for the North Central Coast Study Area is sufficient for the South Coast study area. But, southern California is not northern Californiala. Some 24 million people are clustered along our intensively used coastline. We don’t have the luxury of mile after mile of undeveloped shoreline, a situation which permitted the previous process to get by with incomplete and inaccurate science in the Central and North Central study areas.


Furthermore, the BRTF has failed to resolve the military use area issue. The BRTF’s ultimate decision will have serious implications. Without clear policy guidance on the military areas, the RSG’s hands are tied, because we cannot reasonably balance impacts between the user groups likely to be impacted.


The RSG only has two opportunities to revise MPA proposals following SAT feedback. We believe it would be irresponsible to waste round two on guesswork. The science data – the habitat maps - must be significantly improved and made readily available. The BRTF must provide certainty on the military use area issue.


These are serious issues that threaten the successful conclusion of this public process. We ask: what is the penalty for waiting until we can get it right? Insisting on sticking to the timetable only serves to heighten suspicions of bias.