General Public comment from Dr. Dennis Allen on behalf of the Estuarine Research Federation Nov 2002

Nufor - Dennis And Wendy Allen

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U.S. Commission on Ocean Policy
th1120 20 St., NW
Suite 200 North
Washington, DC 20036

November 7, 2002

Dear Commissioners,

The Estuarine Research Federation (ERF) is a scientific organization committed to
excellence in estuarine and coastal marine research and the communication of scientific
knowledge. Our more than 1500 members represent a cross-section of the research,
education, and management communities within academic institutions, government, and
the private sector. Our interest in understanding and advancing the well-being of estuaries
and contiguous coastal systems is consistent with that of the U.S. Commission on Ocean
Policy. We are grateful for the opportunity to provide input into the process that you have
undertaken to develop recommendations for a coordinated and comprehensive national
ocean policy for the President and Congress.

Since our initial statement at the first regional meeting in January 2002 at Charleston, SC,
the Governing Board of the Estuarine Research Federation has followed the
Commission’s activities with interest. As the Commission nears the end of its public
input phase, we appreciate the opportunity to provide you with this synthesis of our
thoughts about the status and future of ocean policy. We are not able to provide specific
recommendations for changing the structure of federal agencies or modifying federal
laws, but we are hopeful that by identifying those issues of greatest concern and
indicating actions that will likely lead to improvement, we will be making a useful
contribution.

In your recently published Mid-term Report, you conclude that our coasts, ocean, and
marine resources are in trouble and that development of a comprehensive National Ocean
Policy is of utmost importance. We concur and recognize an essential need to make some
fundamental changes in the current fragmented approach to managing and studying our
coastal and ocean systems. Better coordination and efficiency within and among federal
agencies and programs are necessary, and we favor the creation of a national ocean
policy council to facilitate progress on many fronts. We envision such a council working
with the National Academy of Sciences to develop much needed national strategies for
environmental research, monitoring, and education.
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Given the increasing growth of our population, economy, and stress on our estuaries and
oceans, we believe that the nation has not made sufficient investments in acquiring the
scientific information necessary to support the level of decision-making that we are
facing today. There is much to discover and understand about coastal systems in order to
achieve a long-term balance between often conflicting needs. There are many signs that
natural systems are strained or failing. Until sufficient science is available to support
decisions that potentially affect the health of our coastal systems, we recommend the
precautionary approach to management.

In developing this input, our goal was to identify issues and problems of particular
concern and suggest actions that may be used to address them. We recognized that
several basic procedural changes need to be considered in defining a new national coastal
and ocean policy.

Policy and management must be based on ecological - hydrological units rather
than on political boundaries.

More emphasis must be placed on linking land-use and the management of
aquatic systems. Future policy must integrate information and activities from the
watershed to the ocean.

Coastal and ocean management must make better use of existing scientific
knowledge. Access to and translation of technical information must be improved.

The link between science and management can be facilitated by establishing peer
review as a standard procedure prior to the approval and implementation of major
management initiatives or programs.

Coastal and ocean education must be improved at all levels; a better-informed
citizenry is a key element to the success of a national policy on the oceans.

In the sections that follow, we offer more specific observations and recommendations.
These are organized according to the topical categories used in your document entitled
“Towards a National Ocean Policy”. In the interest of brevity, we present these as
statements without supporting rationale or discussion. We would be pleased to address
any questions you may have about these statements.

Living marine resources:

A national strategy must be established for the protection of wetlands, seagrasses, reefs,
and other coastal and ocean habitats.

Future management of fisheries species and stocks must be based on assessments of
impacts on communities, habitats, and ecosystems as well as on individual populations.

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Fisheries stock assessments and related scientific information must be supported at a
level that enables the development of more reliable predictive models and sustainable
management strategies.

Goals must be set to reduce overharvesting and the destruction of habitat and non-
targeted species; all participants in the process must be accountable for meeting those
milestones.

Marine protected areas (MPA’s) should be evaluated as additional management strategies
for reducing the overharvesting of populations, protecting habitat, and rebuilding
fisheries stocks.

Increased research and regulatory oversight are necessary to reduce environmental
impacts of aquaculture and introduced species in aquatic systems.

Pollution and Water Quality

A national strategy for reducing eutrophication in our coastal and ocean systems is
essential; it should be based on the need to reduce loads and directed by realistic
standards and timetables for achieving specific goals.

New engineering and technological solutions must be developed to supplement
traditional activity-based management efforts to reduce nutrient, contaminant, and
sediment inputs to rivers and estuaries.

Economic incentives for implementing Best Management Practices in agriculture,
industry, municipal and other land-based operations that discharge water and materials to
coastal waters and the atmosphere may be necessary for making substantial
improvements in water and habitat quality.

Management decisions regarding freshwater inflow to estuaries must include thorough
assessments of ecological and economic impacts on rivers, estuaries, and coastal ocean
systems.

Research, Exploration, and Monitoring:

Increases in funding for basic and applied research in the following areas will yield
information needed to address critical management needs:

Understanding the natural and human dimensions of biocomplexity and the
effects of climate change and variability.

Investigating cumulative impacts of disturbances and the mechanisms by which
changes in environmental conditions occur.
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Developing better indicators of stress in coastal systems.

Environmental monitoring programs must be more fully supported to increase our
understanding of both natural changes and the consequences of management decisions in
coastal systems.

More programs that foster collaborations between scientists representing different
disciplines, engineers, and social scientists will be necessary to address broad and
complex questions about our coastal and ocean systems.

The establishment of more research centers that facilitate interactions among academic,
federal, and state scientists and managers of coastal systems and resources is likely to
accelerate progress toward achieving balances between conflicting interests.

Significant investments must be made in the development of new research infrastructure
and the maintenance of existing coastal and marine research laboratories.

Support for programs that train new scientists and provide more opportunities for career
development for young professionals is critical to the future of our coastal and ocean
systems.

Education:

Efforts to synthesize, translate, and disseminate scientific knowledge for use by decision
makers, educators, and the general public must be increased.

The scope, content, and effectiveness of coastal and ocean education in schools must be
improved; support for programs that increase ocean and coastal science literacy represent
critical investments in our future.

Next generation scientists must be provided with sufficient training in the social sciences
and economics to more effectively address complex issues and assist with policy
development.

Technology and Marine Operations:

Expansion of the national network of coastal and ocean observing systems that integrate
information from the uplands to the seas is central to the success of a new national coastal
and ocean policy; observing systems must be coordinated at all levels, effective in
predicting events, and re