Position on Management of Marine Conservation Areas

Over the last several decades, NPCA has worked with dozens of our coastal parks and protected marine areas around the nation. One of the best success stories for marine protections and community engagement is off the coast of South Florida at Biscayne Bay. NPCA has been involved in the development of Biscayne National Park’s General Management Plan (GMP) since its initiation over 15 years ago. As such, we are uniquely positioned to provide testimony regarding the public consultation and decision-making process in which we have been a key participant, in addition to the strong science underlying its development. We strongly support the decision of the National Park Service to create a marine reserve within Biscayne National Park (BNP) in order to protect the park’s incredible but severely threatened coral reef ecosystem.

Biscayne National Park is a national treasure and home to one of the largest barrier reefs in the world. It is the largest marine park in the National Park System, originally established as a national monument in 1968, and elevated to national park status in 1980, “in order to preserve and protect for the education, inspiration, recreation, and enjoyment of present and future generations a rare combination of terrestrial, marine, and amphibious life in a tropical setting of great natural beauty.”¹ BNP is composed of a unique marine environment, encompassing the longest stretch of mangrove forest existing on Florida’s east coast, rich and productive seagrass meadows in Biscayne Bay, over 40 of the northernmost Florida Keys, and a once-spectacular living coral reef. BNP is approximately 171,000 acres, 87,000 of which are reef tract, containing some of the only living coral reef remaining in the continental United States. From a regional perspective, the park’s coastal bay and coral reef habitats play a critical role in the function and dynamics of the larger Florida coral reef ecosystem, serving as a receptor of larvae and juveniles from offshore spawning adults, and as a source of production of adult fish and other marine life that undergo habitat shifts and migrations during various stages of development to habitats outside the park.² BNP receives over half a million visitors annually who come to boat, swim, fish, snorkel, paddle, SCUBA dive, and observe nature and wildlife. The park has also typically had concessions for snorkeling and SCUBA diving on the reef tract, in addition to glass-bottomed boat tours that allow visitors to view coral reefs.

In addition to its ecological value, the park is a significant economic driver, supporting a variety of economic and recreation activities, such as fishing, diving, snorkeling, and boating. According to a National Park Service report, over half a million visitors to Biscayne in 2015 spent nearly $32 million and sustained 450 jobs in the local area, with a total economic output of more than $44 million.³ Importantly, the majority of visitors and resulting economic output are non-local. Non-local visitors spent approximately $31 million and generated about $44 million in economic output in 2014.⁴ In addition, South Florida benefits from a multibillion dollar fishing and boating industry, which is directly dependent on the health of its marine resources. Without healthy and sustainable fish populations and coral reefs, the economic value and productivity of fishing, boating, and water-dependent activities in South Florida will plummet.

The decision by the National Park Service (NPS) to include a marine reserve in its final General Management Plan was based on decades of sound science and research from around the world attesting to the success of marine reserves at protecting coral reef ecosystems. NPS compiled substantial scientific evidence over the course of its 15-year decision-making process that documents the severe decline in the health of coral reef resources within Biscayne National Park that necessitates the creation of a marine reserve. To highlight just a few facts relied on by NPS:

• According to a 2002 report by NOAA fisheries,⁵ live coral cover has declined 37% in just five years, throughout the Florida Keys reef tract.
• Only approximately 6% of Biscayne’s reefs are still alive, and they continue to be under stress from derelict fishing gear, warming seas, and the absence of a stable, healthy ecological food web resulting from overfishing.⁶
• The majority of data indicates that many fish species in Biscayne National Park are heavily exploited and/or overfished, as defined in the Magnuson-Stevens Fishery Conservation and Management Reauthorization Act of 2006.⁷
• 77% of 35 fish stocks studied within the park are overfished.⁸
• Six of the 14 species listed by the South Atlantic Management Council as overfished occur within the park and include goliath grouper, Nassau grouper, gag grouper, black grouper, vermillion snapper, and yellowtail snapper.⁹
• Stock biomass is critically low for species targeted by recreational fishermen.¹⁰
• Data from a reef fish visual census performed in 2002 indicated that groupers and snappers were smaller in the park compared to other areas.¹¹

Furthermore, an abundance of scientific data and research exists to support the ability of marine reserves to quickly and effectively improve the health of coral reef ecosystems.

• A marine reserve will help protect reefs from overfishing, damage from fishing gear, anchoring, and vessel groundings. It would also provide the best opportunity to increase the resiliency of Biscayne’s reef ecosystem to the impacts of climate change, ocean acidification, land-based sources of pollution, and damage from derelict fishing gear.¹²
• Marine reserves function over the long-term, improving the size and quantity of fish and providing habitat and ecosystem protection and preservation.¹³
• Science shows that marine reserves are more effective at reducing mortality, particularly for reef fish, than other management tools, such as catch and release and slot limits.¹⁴
• Research indicated an increase in the size of red grouper, mutton snapper, yellowtail snapper, and hog fish within the boundaries of marine reserves in the Dry Tortugas and documented the spillover effect, in which larger and more abundant fish species were documented in areas directly surrounding the reserves.¹⁵ In contrast, the size and abundance of these species either declined or remained the same in nearby regions that remained open to fishing.¹⁶
• Marine reserves improve the size and quantity of fish, and protect and preserve ecosystems and habitat.¹⁷

NPS conducted an extensive, 15-year public engagement process during the development of its GMP and received strong public backing for the creation of a marine reserve in Biscayne, with tens of thousands of individuals voicing their support. NPS noted that 90 percent of public comments received on the GMP were in favor of implementing a marine reserve.¹⁸ The marine reserve was supported by world-renowned anglers, business owners, scuba divers, environmental organizations, the Everglades Coalition, Miami-Dade County, and internationally recognized marine conservation experts Jean-Michel Cousteau, Dr. Sylvia Earle, and Dr. Jeremy Jackson. NPS underwent a substantial public consultation process leading up to the finalization of the GMP, including 22 public meetings attended by more than 1,000 people and received 43,000 pieces of correspondence.¹⁹ Due to concerns from the State of Florida, NPS and the Department of the Interior spent two additional years in consultation with the state to develop additional alternatives.²⁰ These discussions occurred at high executive levels including meetings of the Executive Director of Florida’s Fish and Wildlife Conservation Commission (FWC) and the Principal Deputy Assistant Secretary for Fish, Wildlife, and Parks. Unfortunately, the supplemental alternatives were deemed ineffective and unsatisfactory by the public and government agencies.²¹ Ultimately, FWC withdrew its support for one of the alternatives it helped devise.²²

Finally, before the marine reserve is actually implemented via the federal rulemaking process, additional opportunities for public comment and engagement will occur. FWC and stakeholders in the angling community will be able to provide additional science and analysis during that time.

The development of a recommendation for a protective marine reserve, particularly in Biscayne National Park, demonstrates the diligent work of federal agencies at ensuring public engagement and the protection of a treasured natural resource. Similarly, the bipartisan Antiquities Act has provided opportunities to protect marine and mixed marine-terrestrial landscapes in our oceans bolstering local economies, safeguarding unique ocean resources, and creating opportunities for advancement in fisheries management.

National monuments such as Papahānaumokuākea Marine National Monument, originally designated by President George W. Bush in 2006 and the Northeast Canyons and Seamounts Marine National Monument designated by President Obama in 2016 were created using a century-old conservation law. The Antiquities Act has been used to protect some of our most iconic sites and most important history. The Antiquities Act of 1906 allows the president to establish national monuments on federal lands—already owned by all Americans. At Papahānaumokuākea, this means the protection of extensive coral reefs, the “rainforests of the sea” that host over 7,000 marine species. In the northeast Atlantic, protections include a number of underwater mountains and canyons as well as sea turtle and other marine mammal habitat, all while narrowing the monument’s geographic boundaries to recognize the needs of the fishing industry in the region.²³

Nearly every president since 1906 (eight republicans and eight democrats) has used the Antiquities Act as a bipartisan conservation tool to protect our nation’s history and culture. The Act was passed by a Republican-led Congress and signed by President Theodore Roosevelt; since then, those 16 U.S. Presidents have declared 157 national monuments using the act.

Theodore Roosevelt alone created 18 national monuments using the Antiquities Act during his presidency, as well as 150 national forests, 51 federal bird reserves, four national game preserves and five national parks. In total, he protected 230 million acres of public resources. Roosevelt alone demonstrated the power and opportunity of the Antiquities Act to protect our nation’s treasure resources and remarkable history. We are fortunate that modern day presidents like George W. Bush utilized this tool to protect our marine life as well.

We urge the committee to consider these success stories, park sites, and remarkable national monuments as they consider additional discussion regarding protected marine areas, including reserves and national monuments during the 115th Congress. NPCA is happy to provide additional feedback or information and welcomes your support of our parks and the laws that help protect and create them.

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1 16 U.S.C. 410gg.

2 Ault, J. S. Smith, S. G., Meester, G. A., Luo, J. and Bohnsack, J. A., Site Characterization for Biscayne National Park: Assessment of Fisheries Resources and Habitats, May 2001.

3 Cullinane, T. C., & L. Koontz. 2015 National Park visitor spending effects: Economic contributions to local communities, states, and the Nation. 2016, Natural Resource Report NPS/NRSS/EQD/NRR—2016/1200, National Park Service, Fort Collins, Colorado.

4 Cullinane, T. C., Huber, C., & Koontz, L. 2014 National Park visitor spending effects: Economic contributions to local communities, states, and the Nation. 2015, Natural Resource Report NPS/NRSS/EQD/NRR—2015/947, National Park Service, Fort Collins, Colorado.

5 U.S. Department of the Interior, National Park Service, Biscayne National Park Final General Management Plan/Environmental Impact Statement, April 2015, 169/106381B, Vol 1, 24.

6 National Park Service South Florida / Caribbean Network. 2013. Annual administrative report (FY 2012) and work plan (FY 2013) for inventories and Vital Signs monitoring: South Florida / Caribbean Network. Natural Resources Report NPS/SFCN/NRR—2013/702. National Park Service, Fort Collins, Colorado.

7 Ibid, 174.

8 Ault, J. S., Ault, J. S., Smith, S. G., Meester, G. A., Luo, J., & Bohnsack, J. A. Site characterization for Biscayne National Park: Assessment of fisheries resources and habitats. NOAA Technical Memorandum 2001 NMFS-SEFSC-468 (as cited in U.S. DOI, NPS, Final GMP/EIS, Vol 1, 174).

9 National Marine Fisheries Service. Status of Fisheries of the United States- Report to Congress, 2001, (as cited in U.S. DOI, NPS, Final GMP/EIS, Vol 1, 174).

10 Ault et al. 2001 (as cited in U.S. DOI, NPS, Final GMP/EIS, Vol 1, 174).

11 Ault, J. & Smith, S. Unpublished Data, University of Miami (as cited in U.S. DOI, NPS, Final GMP/EIS, Vol 1, 175).

12 Jackson, J. B. C., Donovan, M. K., Cramer, K. L., & Lam, V. V. (editors), Status and Trends of Caribbean Coral Reefs: 1970-2012. Global Coral Reef Monitoring Network, IUCN, Gland Switzerland (as cited in U.S. DOI, NPS, Final GMP/EIS, Vol 1, 123).

13 Bohnsack, J.A., How Marine Fishery Reserves Can Improve Reef Fisheries, Proceedings of the 43rd Gulf and Carribbean Fisheries Institute, 1994, 43: 217-241; Bohnsack, J.A. & Ault, J. Management Strategies to Conserve Marine Biodiversity, Oceanography, 1996, 9(1): 73-82; Halpern, B., The Impact of Marine Reserves: Do Reserves Work and Does Reserve Size Matter? Ecological Applications, 2003, 13, (1), Supplement, S117-S137; Lester, S. E., Halpern, B. S., Grorud-Colvert, K., Lubchenco, J., Ruttenberg, B., Gaines, S. D., Airamé, S., & Warner, R. R. Biological Effects within No-Take Marine Reserves: A Global Synthesis, Marine Ecology Progress Series, 2009, Vol. 384:33-46, (doi: 10.3354/meps08029) (as cited in U.S. DOI, NPS, Final GMP/EIS, Vol 1, 125).

14 U.S. DOI, NPS, Final GMP/EIS, Vol 1, 125.

15 Ault, J. S., Smith, S. G., Bohnsack, J. A., Luo, J., Zurcher, N., McClellan, D., Ziegler, T., Hallac, D., Patterson, M., Feeley, M., Ruttenberg, B., Hunt, J., Kimball, D., & Causey, B. Assessing Coral Reef Fish Population and Community Change in Response to Marine Reserves in the Dry Tortugas, Florida, USA. Fisheries Research, 2013, 144, 28-37 (as cited in U.S. DOI, NPS, Final GMP/EIS, Vol 1, 125).

16 South Florida Natural Resource Center, Everglades and Dry Tortugas National Parks, and Florida Fish and Wildlife Conservation Commission, Dry Tortugas National Park Research Natural Area Science Plan, the Five-Year Report, 2012 (as cited in U.S. DOI, NPS, Final GMP/EIS, Vol 1, 125).

17 See Bohnsack J.A., 1994, “How marine fishery reserves can improve reef fisheries,” Proceedings of the 43rd Gulf and Caribbean Fisheries Institute, 43: 217-241; Bohnsack, J.A. & J. Ault, 1996, “Management strategies to conserve marine biodiversity,” Oceanography, 9(1): 73-82; Halpern, B., 2003, “The impact of marine reserves: Do reserves work and does reserve size matter?” Ecological Applications, 13, (1), Supplement p. S117-S137; Lester, S.E., B.S. Hapern, K. Grorud-Colvert, J. Lubchenko, B. Ruttenberg, S.D. Gaines, S. Airame, & R.R. Warner, 2009, “Biological effects within no-take marine reserves: a global synthesis,” Marine Ecology Progress Series, Vol. 384:33-46, (doi: 10.3354/meps08029).

18 U.S. Department of the Interior, Biscayne National Park, Final General Management Plan Briefing Presentation, May 2015, 8.

19 Ibid., 4.

20 See U.S. Department of the Interior, National Park Service, Biscayne National Park Supplemental Draft General Management Plan/Environmental Impact Statement, November 2013, 169/106381B.

21 U.S. Department of the Interior, Biscayne National Park, Final General Management Plan Briefing Presentation, May 2015, 7-8.

22 Ibid., 7.

23 See 2016 White House Fact Sheet at https://obamawhitehouse.archives.gov/the-press-office/2016/09/15/fact-sheet-president-obama-continue-global-leadership-combatting-climate