August 15, 2014
President Barack Obama
The White House
Washington, DC
SIERRA CLUB COMMENTS SUPPORTING EXPANSION OF THE BOUNDARIES OF
THE PACIFIC REMOTE ISLANDS MARINE NATIONAL MONUMENT
Dear President Obama:
These comments are submitted jointly by the Sierra Club Hawai‘i Chapter and the Sierra Club
national Marine Action Team on behalf of the Sierra Club’s more than two million members. We
strongly support your proposal to expand the boundaries of the Pacific Remote Islands Marine
National Monument (PRIMNM) from 50 nautical miles to 200 nautical miles, including a ban on
commercial fishing and other extractive activities.
SCIENTISTS SUPPORT EXPANSION OF BOUNDARIES
The scientific evidence supporting expansion of the current boundaries of the PRIMNM has been
thoroughly documented in the Report on Expansion of Pacific Remote Islands Marine National
Monument (The Expansion Report), issued May 20, 2014.1 In addition, as of 8/15/14, 211
scientists have signed on to a letter titled Pacific Scientists in Support of Pacific Remote Islands
Marine National Monument,which supports the proposed expansion (see Attachment A).
We have learned that islands and atolls alone warrant strong protection. But the size of those
protections must be in the broader context of the rich ecosystems that extend far beyond their
shores, including those associated with seamounts and foraging areas for seabirds and other
species. True ecosystem protections call for the large boundaries President Obama proposes,
which coincide with the 200 nautical mile U.S. Exclusive Economic Zone.
EXPANSION CONFIRMS AMERICA’S STEWARDSHIP ROLE IN THE PACIFIC
Beginning with our founder, John Muir, the Sierra Club has long recognized the value of
wilderness areas and championed the creation of national parks and other means for protecting
wilderness areas. As expanding populations spread into former woodlands and open spaces, the
wisdom of setting aside protected areas has become more apparent. Over time, these wilderness
areas have provided humans with values greatly exceeding that of the timber, minerals, or other
resources which otherwise might have been extracted.
Sala, E., L. Morgan, E. Norse, and A. Friedlander. 2014. Expansion of the US
Pacific Remote Islands Marine National Monument: The largest ocean legacy on
Earth. Report to the US government.
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Most protected wilderness areas have been on the land. This is true internationally as well as
nationally. We have similar opportunities, and responsibilities, to protect the few remaining
ocean wilderness areas that still exist in an age of global industrial scale fishing ranging over vast
areas of the ocean in search of declining fish populations. Coral reef ecosystems in particular
have proven to be vulnerable to human impacts, and very difficult to restore once their natural
balance has been affected by human activities. As true on land, we can expect fishing, mining,
and other extractive activities to press further into remote areas of the ocean in coming years.
John Muir also noted that "When we try to pick out anything by itself, we find it hitched to
everything else in the Universe." Ecosystem-based management incorporates this notion. We
now recognize that the rich and unique coral reef ecosystems of the remote Pacific Islands of
Jarvis, Baker, Howland, Kingman, Palmyra, Wake, and Johnston are hubs of a much more
expansive ecosystem that includes seamounts and deep coral beds, together with a wide array of
creatures that inhabit, forage within, or travel through the wide expanses of ocean and air
encompassed within the proposed boundaries of the PRIMNM.
The Sierra Club has long championed the notion of stewardship, and the responsibilities of each
generation to protect the resources of the Planet for succeeding generations. The motto of the
Hawai‘i Chapter of the Sierra Club is “E Mālama I ka Honua,” – “Care for the Earth.”
You also have made stewardship the core principle of our national ocean policy, adopted under
your Executive Order 1354, the full title of which is the National Policy for the Stewardship of
the Ocean, Coasts and Great Lakes.
The Native Hawaiian culture goes even beyond the concept of stewardship of natural resources,
to one of kinship with other creatures inhabiting the land, sea, and air. Natural resources are
viewed as having intrinsic value beyond whatever uses they may provide to humans.
Pacific Islanders, both within and beyond U.S. borders, and on both sides of the equator, are
taking bold actions to protect their coral reef ecosystems and ocean environment. In 2006, the
leaders of Federated States of Micronesia, the Republic of the Marshall Islands, the Republic of
Palau, the U.S. Territory of Guam and the U.S. Commonwealth of the Northern Mariana Islands
launched the Micronesian Challenge--a shared commitment to “effectively conserve at least 30%
of the near-shore marine resources and 20% of the terrestrial resources across Micronesia by
2020.”2 More recently, Palauan President Tommy Remengesau announced his intent to fully
protect 80% of Palau’s Exclusive Economic Zone.
Farther south, the Cook Islands have created a no-take marine reserve 50 miles around the
southern islands in the archipelago. The U.K. government is considering full protection of the
Pitcairn Islands’ EEZ in the South Pacific (322,781 square miles), which would become the
largest fully protected marine reserve on Earth. President Anote Tong of Kiribati announced the
creation of a no-take marine reserve to protect over 154,440 square miles surrounding the
Phoenix Islands. He has also indicated his intent to establish a no-take reserve around the
Southern Line Islands – the southern counterpart to the Pacific Remote Islands Marine National
Monument atolls.
A Report on Progress to Implement the Micronesia Challenge 2006-2011
Submitted by the Micronesia Challenge Steering Committee to the Micronesia
Chief Executives Summit July 2011.
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Designation of the PRIMNM by President George W. Bush in 2009 was an important action by a
United States President to complement the actions of other leaders in the Western Pacific.
Expansion of the boundaries of the PRIMNM by President Obama, based on more recent
scientific knowledge of the area, will demonstrate the continued commitment of our Country to
the conservation efforts of the region.
FISHERY MANAGEMENT ASPECTS
Opposition to the proposed expansion has come primarily from the Western Pacific Regional
Fishery Management Council, which has argued that the proposed monument expansion won't
benefit fisheries conservation and would unfairly penalize US fishermen.3 The Council states
that the expanded boundaries would displace longline and purse seine fisheries. As the
Expansion Report points out, however, tuna are highly migratory and the annual quota could be
obtained from areas outside the new boundaries.4 Also, the tuna catch from within the proposed
boundaries represent only about 5% of the quota for U.S. fisheries. While having a small impact
on the tuna quota, the new boundaries would have the important benefits of reducing or
eliminating the impacts of longline and purse seine fisheries on Monument resources, including
direct impacts from the removal of tuna and indirect impacts of bycatch on turtles, sharks, birds,
and other species.
Not that many decades ago, locally based pole and line fisheries were able to supply the people
of Hawai‘i with fresh tuna, while also supporting a cannery at Kewalo Basin, not far from the
State Capitol. This was done with minimal bycatch compared to longline or purse seine fisheries,
and without the need to travel the long distances commercial fishing vessels currently travel.
Successful fisheries management should not require fishers to travel so far from home, and catch
and discard so many other species, in order to provide tuna for the people of Hawai‘i.
ENFORCEMENT IS CRUCIAL
Enforcement will be an important element of the Management Plan developed for the expanded
Monument. The Coast Guard is currently obligated to protect against foreign fishing within the
EEZ. Expanding the Pacific Remote Islands National Marine Monument to that same boundary
simplifies the surveillance and enforcement tasks, while also elevating their importance.
Improved enforcement to reduce illegal fishing in the EEZ will benefit U.S. fisheries as well as
the environment.
The vast areas and distances involved make this challenging at present, but there are promising
developments for the future. These include the analyses of data from satellites tracking the
identification and movements of vessels having Automatic Identification Systems. Computer
software can help distinguish between vessels engaged in fishing and those that simply traverse
an area. The improved capabilities for identifying suspicious vessels as part of our Homeland
Security mission is also providing new capabilities for enforcement, including unmanned aircraft
and surface vessels, high resolution airborne radar, and more. All of these capabilities, combined
with fisheries management information regarding the seasonal movements of tuna populations
will allow enforcement assets to be used more efficiently and effectively than is presently
WPRFMC Press release by Sylvia Spaulding,June 30, 2014.
Sala, E., L. Morgan, E. Norse, and A. Friedlander. 2014. Expansion of the US
Pacific Remote Islands Marine National Monument: The largest ocean legacy on
Earth. Report to the US government. Page 4.
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possible.5 Enforcement will also be aided by cooperation between the managers of large
protected areas, who have developed the Big Oceans network for carrying out, among other
things, the ambitious goals of the Biodiversity Convention target of protecting 10% of the
world’s oceans in the near future. Aulani Wilhelm, Superintendent of the Papahānaumokuākea
Marine National Monument, is one of the Big Oceans founding members.6
None of the proponents of the expansion want it to become a “paper park,” and we will work to
ensure sufficient attention and resources are devoted to surveillance and enforcement.
CONCLUSION
In conclusion, we strongly support full expansion of the boundaries, including prohibitions on
commercial fishing and other extractive activities.
Thank you for the opportunity to express our views on this important initiative
Sincerely,
Dave Raney
Co-Chair, Sierra Club Marine Action Team
Scott Glenn
Chair, Hawai‘i Chapter of the Sierra Club
Patricia Matejcek
Co-Chair, Sierra Club Marine Action Team
-------------------------------------------------------------------------------------------------------------ATTACHMENT A
PACIFIC SCIENTISTS IN SUPPORT OF PACIFIC REMOTE ISLANDS MARINE
NATIONAL MONUMENT
August 15, 2014
Dear President Obama:
We the undersigned marine scientists strongly support your proposal to expand the Pacific Remote
Islands Marine National Monument. As professors, researchers, graduate students, and other academics
who work in the Pacific region, we hope that you will consider our perspectives carefully when
determining the size of the Monument.
5
http://www.pewtrusts.org/~/media/legacy/uploadedfiles/peg/publications/other_r
esource/MaritimeElectronicToolsARTFINALv4pdf.pdf
6 Toonen,R.J. etal.,2013. One size does not fit all: The emerging frontier in
large-scale marine conservation. Marine Pollution Bulletin.
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We believe you should expand the Monument to the full 200-nautical-mile United States Exclusive
Economic Zone (EEZ) in order to preserve the ecological integrity of one of the last remaining pristine
ecosystems on earth. We believe that this region of the ocean has substantial conservation value and
unique natural qualities that require strong protection.
The proposed Monument expansion would:

protect a substantial number of endangered, threatened, or over-exploited species (e.g., sharks,
sea turtles, manta rays, marine mammals, and seabirds) that move well beyond the current 50
nautical mile boundary and are therefore not sufficiently protected under the current
Monument, including:
-
feeding and breeding grounds for 14 million seabirds of 19 species;
-
migratory and feeding grounds for five species of threatened and endangered sea
turtles;
-
habitat for 22 marine mammal species, 7 of which are endangered, including sei and
blue whales; and
-
migratory and feeding grounds for manta rays.

safeguard from potentially destructive fishing and mining activities nearly 250 seamounts, or
undersea mountains, which are hotspots of biodiversity, and likely home to thousands of yet
undiscovered species.

ensure ecological connectivity from the tropical rainforests and coral reefs surrounding these
islands and atolls to the rich pelagic environments and seamounts that extend out to the full US
EEZ. These linkages are critical to sustaining the biodiversity and ecological function of this
unique region.

help replenish pelagic fish stocks. Although large predatory fishes, such as tuna, swordfish,
marlin, and oceanic sharks can move great distances, recent studies have shown that many
would likely remain within an expanded Monument and grow larger and produce more offspring
if protected from fishing. Dispersing offspring from these populations could therefore help
replenish fishery resources outside the protected area.
We understand that fish caught within the proposed Monument expansion accounts for < 5% of the US
tuna catch in the central and western Pacific. However, we believe that the benefits of protecting these
uninhabited ocean jewels far transcend the value of what can be removed for short-term commercial
gain. Owing to the intact nature of this ecosystem, full Monument protection presents an unparalleled
opportunity to understand how healthy marine ecosystems function, while by comparison examining
the impacts that humans are having on our environment today. Indeed, there are countless other
benefits that we cannot fully imagine, such as new medicines from the rich diversity of species
inhabiting this region.
We understand the importance of preserving our natural heritage for the benefit of future generations
across the Pacific, and beyond. Expansion of the Monument provides the opportunity to double the
area of ocean that is fully protected globally from 1% to 2%. Marine scientists and conservation experts
agree that to ensure the health and productivity of our oceans for future generations, at least 20% of
the ocean needs to be protected in marine reserves. The United States must do its part, while calling on
other world leaders to follow your lead in protecting the ocean and its marine ecosystems.
As an academic community with a strong interest and belief in the importance of protecting one of the
richest areas on earth for ocean life, we support full protection of the Pacific Remote Islands to the 200nautical-mile US EEZ.
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