7/27/2019 Comments on Draft Regional Ocean Planning Goals

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Comments on Draft Regional Ocean Planning Goals

Submitted by Dr Damon E. Cummings, Ph.D. Ocean Engineering, Gloucester, MA,

damonc2@aol.com

6/27/2013

I found your comment form far too restrictive for what I wish to say and therefore have written this

memo.

In general your introductory language is just what I wanted to hear, but the follow up and details of the

goals are just what I was afraid I would hear. The overall purpose of this effort is to manage the common

pooled ocean resource for the benefit of our generation and future generations. That idea including the

preservation of ecosystems and of human history and traditions is expressed clearly in your introductory

language. However in practice your mapping emphasis and tendency to divide areas up for specific

purposes leads inevitably to privatization of the common resource and encourages consolidation of

ownership of specific areas of the commons in a few wealthy corporate hands. There is no effort

stated to restrict corporations from dominating vast areas of the ocean that are presently used by many

stakeholders. Someone at the meeting mentioned enclosures. That is my worry as well. I would prefer

that you state explicitly that your fundamental task is management of a common pooled resource for

the benefit of the public. (See Elinor Ostrom, Governing the Commons for example). Your task is huge,

but unfortunately you are taking the logical but fatal tack of narrowing it down to a zoning exercise and

skipping over the vital issues of pollution and climate change and basic research and preservation of the

commons. Please do not make decisions impacting hundreds of future years of ocean uses based on a

few short term goals such as mineral extraction or aquaculture or wind farms. I do not see anything

about restoring sea life along the coast, but lots about wind farms.

On the specific subject of fishing and sea life, there seems to be little recognition that commercially

important fish species tend to occur in only a tiny fraction of the ocean. There is much written in the

draft about locations for ocean mining and energy production, but little about the potential impact on

fisheries and fish. It is the shallow banks with upwellings of cold oxygen rich deep water that support

dense schools of fish and other marine species important for human consumption. It is those very

shallow areas close to shore where energy and mining corporations like to place their facilities and

structures. I would like to see far more emphasis on determination of where fisheries are important and

if you are going to zone, give them space and a buffer zone around those grounds. Anything moored or

built on a fishing bank is a hazard to navigation.

You have caught on to including indigenous tribes in your process. However not all the indigenous

groups were here before the Pilgrims. People have been living in Gloucester and fishing out of this port

for four hundred years. When we go to your meetings we see that NGOs and corporations are well

represented. However there were no fishermen at your Gloucester meeting. They did not even know

about it. Do they not count as a tribe? The public outreach you are doing is very restrictive and should

be far better advertised and publicized.