Westem

Paclllc
Beglanal
Rsherv

Management
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April 8, 2016
The Honorable Barack H. Obama
President of the United States
The White House
1600 Pennsylvania Avenue NW
Washington, DC 20500
Dear Mr. President:
On behalf of the Western Pacific Regional Fishery Management Council (Council), we
are writing to you regarding a January 2016 request to expand the Papahanaumokuakea Marine
National Monument (PMNM) around the Northwestern Hawaiian Islands (NWHI). This marine
protected area (MPA) was established in 2006 by President George W. Bush. At the time, NWHI
ecosystems had been managed under a suite of state and federal regulations and supported lowimpact, sustainable fisqeries that supplied Hawaii with half of its local bottomfish and the
majority of its local lobster.
The PMNM encompasses the NWHI-a string of islands and atolls stretching 1,200
nautical miles (nm) northwest of Kauai and Niihau. With a breadth of 100 nm and length of
1,200 nm, the PMNM is the world's largest no-take MPA and accounts for virtually all of the
United States' no-take MPAs. At approximately 138,000 square miles, the PMNM contains coral
reef ecosystems, deep benthic habitat, seamounts, the abyssal plain, and pelagic waters of the
NWHI. The boundaries of the PMNM mirror an existing protected species zone that was
established by the Council in 1991 and which prohibited longline fishing in the zone. Coupled
with the fishing exclusion areas established under the Magnuson-Stevens Fishery Conservation
and Management Act and other authorities, the Hawaii longline fishery is currently banned from
24 percent to 37 percent of the US exclusive economic zone (EEZ) around Hawaii. Eighty
percent of this fishery's landings is consumed in Hawaii; this fishery also supplies the US
mainland with 80 percent of its domestic bigeye tuna and 50 percent of its domestic swordfish
and yellowfin tuna.
From Presidential actions within the last 1.0 years, approximately 28 percent of the US
EEZ in the US Pacific Islands Region has been established as Marine National Monuments
(MNM). Your Executive Order in 2014 to expand the Pacific Remote Islands MNM created the
world's largest non-contiguous MPA. The significant percentage of US waters already
established as MPAs in our jurisdiction far exceeds any other area of the US. Less than 1 percent
of state and federal waters combined in the other US regions are designated as no-take MP As.
The cultural and economic importance of fisheries to Hawaii are unmatched elsewhere in
the Nation. I trust you have fond memories of local Hawaii seafood from your childhood and
from your recent visits and understand why Hawaii's per capita seafood consumption is twice the
A Council Authorized by the Magnuson Fishery Conservations and Management Act of 1976
1164 BISHOP STREET • SUITE 1400 • HONOLULU • HAWAII 96813 USA • TELEPHONE (808) 522-8220 • FAX (808) 522-8226
www.wpcouncil.org

 national average. Healthy fisheries sustained indigenous Hawaiian communities for over 1,500
years, and fisheries continue to remain important today. Hawaii fisheries support subsistence,
non-commercial, charter, and commercial fishing activities, contributing to local food security
and supporting Hawaii's tourism economy with fresh, sustainably caught seafood. Hawaii's
commercial fisheries alone generate approximately $110-120 million annually in landed value,
which is multiplied several times over in the local seafood industry, supporting thousands of
direct and indirect jobs.
The best scientific information available indicates that the expansion of the PMNM will
not yield marine conservation benefits. The Council's Scientific and Statistical Committee
(SSC), which is comprised of distinguished scientists, recently agreed on the following:
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Marine resources that occur in the NWHI and surrounding US EEZ are already protected
and subject to comprehensive management regulations and monitoring;
Expanding the PMNM will not provide any additional conservation benefits for highly
mobile species such as tuna, billfish, sharks, sea turtles, and marine mammals that range
well beyond the US EEZ;
Seabirds such as Laysan and black-footed albatross are already protected by a suite of
domestic and international mitigation measures that will not be augmented by boundary
expansion of the PMNM; and
Expansion of the PMNM will result in negative socio-economic impacts to Hawaii
fisheries, Hawaii economy, and the Nation.

Expansion of the PMNM would adversely impact the Hawaii longline fishery, and
potentially small-scale troll and bottomfish vessels operating out of Kauai. Approximately 10
percent of the Hawaii longline fishing effort occurs in the US EEZ around the NWHI. If these
Hawaii vessels are forced to fish on the high seas, they face increased competition with foreign
vessels,, ,h lower catch rates, and higher operating costs. Based on reports from the US Coast Guard
and NOAA's Office of Law Enforcement, there are fleets of several nations that fish in close
proximity to the US EEZ around the Hawaii Archipelago. Negative impacts to Hawaii fisheries
affect the local seafood market, leading to increased reliance on foreign imports. It is estimated
that 30 percent of foreign imported seafood is caught by lllegal, Unregulated, and Unreported
fisheries. There are also concerns with foreign imported seafood in regards to labor practices and
food safety.
,
The assertion that the expansion is warranted because large MP As are important to
mitigating the impacts of climate change is unfounded, especially in regards to highly migratory
species as their locations and migratory patterns are expected to shift while the boundaries of
MP As remain static. The creation of large MP As does not reduce fishing effort; instead, it
concentrates that effort elsewhere, which arguably has more dire consequences. For example, the
creation of no-fishing areas in the high seas pocket areas of the Western and Central Pacific
Ocean was a failed experiment and did not reduce tuna catches, but merely redistributed them in
the EEZs of neighboring countries.
There are increasing calls for closing the high seas to fishing, even if fishing is monitored
and subject to international management measures adopted by regional fishery management
organizations. If the high seas are further restricted, coupled with increased loss of operational
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 area in the US EEZ due to monument expansion, the sustainable, highly-monitored US fisheries
such as the Hawaii longline fishery face eminent demise, further exacerbating US reliance on
foreign seafood imports.
The US Pacific Islands region has already contributed a vast amount of waters to the
national MPA inventory and virtually all of the no-take MPA waters. The proposed expansion of
the PMNM contradicts Executive Order 12898 on Federal Actions to Address Environmental
Justice in Minority Populations and Low-Income Populations. Mr. President, as you know,
minorities account for two-thirds of Hawaii's population. These waters are important as their
fishing grounds to support their sustenance, livelihoods and culture. Further expansion of MPAs
in our region would increase the existing disproportionate burden on people of the US Pacific
islands that rely on fish as their main renewable natural resource.
Executive Order 13158 on Marine Protected Areas encourages Federal agencies charged
with strengthening the Nation's MPA network to avoid creating ineffective MPAs. The
Executive Order directs agencies to base management decisions on science-based prioritization
for the protection of marine areas, gaps in levels of protection currently afforded, economic
effects of management actions, scientific evaluation of the effectiveness of MPAs, among other
factors, in consultation with other agencies and the regional fishery managem~nt councils.
Because of the existing protections and management measures, the expansion of the
PMNM will not provide marine conservation benefits nor mitigate the impacts of climate
change. Expansion would, however, result in negative socio-economic impacts to Hawaii
fisheries and the local seafood market. Therefore, we respectfully ask that you not advance the
request to expand the PMNM.
Enclosed is more information on Hawaii fisheries and existing protections in the NWHI.
We are available to discuss this letter and the information contained herein with you and
representatives of your administration at any time. Mahalo for your attention to this.
Sincerely,

~~:1::J~~L
Executive Director

~~-dJ

Edwin Ebisui Jr.
Chair

Enclosures:
WPRFMC Information Paper
SSC Member Affiliations
c/c: Hawaii US Congressional Delegation
Honorable David Y. Ige, Governor, State of Hawaii
Honorable Ronald D. Kouchi, Hawaii State Senate, President
Honorable James K. Tokioka, Hawaii State Representative, Kauai
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