Volume V: Response to Comments Comment Category 25 – Research 2) While marine debris is a larger problem in shallow water because many items float rather than sink, at what depth does it cease to be of concern? To our knowledge, there has never been a coordinated depth zonation study for marine debris starting from land and going down to at least 400 m at a site known for its accumulation (e.g., Pearl and Hermes) and/or a site near a monk seal colony. Monk seals, as I am sure most are aware, have been documented to frequent precious coral beds down to depths of 400 m (see Frank Parrish’s studies and his National Geographic Explorer production). We think a study of this type could and should be mentioned in the plan. How much bottomfishing debris (anchors, anchor lines, fishing leads and fishing lines) exists on popular deepwater fishing sites? This might be important to document particularly following the closure of the fishery in the next 4-5 years. In the main Hawaiian Islands, alien species have been documented in deeper than typical SCUBA depths (see Sam Kahng’s various papers on Carijoa riseii). Is this species in the monument and if so, how deep does it go given that monument waters are clearer and thus likely pushing it to even deeper depths than in the MHI (C. riseii is negatively phototaxic). How big of a threat is it to the monument’s black coral beds? Again, we think this should be mentioned as a potential research effort in the plan. A likely study site and one for long-term monitoring focus would be Middle Bank at the lower end of the monument. 3) Therefore, my proposal is that NO research should be conducted in or around the NWHI for the next 10 years unless it will benefit the protection and restoration of these islands. After 10 years researchers can go in and do their tests on the status of restoration efforts only when approved by the citizen based advisory council. 4) Permission should only be granted to research absolutely necessary for protection and recovery of threatened and endangered species and their habitats, and restoration of those habitats as needed. Research having only tangential or general relevance to critical management decisions in the Monument should be revised to clearly distinguish between these two categories of research proposals. 5) In addition to the Proclamation findings and permitting criteria, the Research and Monitoring Action Plan must prioritize research and provide criteria that managers will use regularly to fund and prioritize research activities in the Monument. 6) 3.1.1 Marine Conservation Science Action Plan. Ocean Conservancy is concerned that the “Desired Outcome” stated at the beginning of this section fails to capture all of the research outcomes that are required for effective Monument management. The statement should reflect all five of the thematic areas in the Hawaiian Archipelago Marine Ecosystem Research Plan (HAMER Plan) and repeated here in this section. As currently written it fails to cover the critical need to research and understand human impacts, among other elements. Under “Strategies to Achieve the Desired Outcome”, Strategies MCS-1, 2 and 314 are not linked to the basic requirement that all research serve to improve management of the Monument. We suggest that these strategies December 2008 290 Volume V: Response to Comments Comment Category 25 – Research should read something like [emphasis on added language]: • MCS-1: Continue and expand that research, characterization and monitoring of marine ecosystems for the life of the plan that will advance and improve management of the Monument. • MCS-2: Assess and prioritize research and monitoring activities over the life of the plan with respect to the contribution it will make to improving management of the Monument. • MCS-3: Communicate results of research and monitoring over the life of the plan and how that research and monitoring has been or will be used to improve Monument management. 7) 3.1 and 3.2: The RAC has consistently over the years recommended that any and all research in the NWHI should be focused exclusively on whether such research is essential to management. Keeping this in mind and to consolidate the action plans that involve scientific research into one section, the RAC recommends that these two sections be reorganized as follows. 3.1 Conserving Wildlife and Habitats Threatened and Endangered Species Action Plan Migratory Birds Action Plan Habitat Management and Conservation Action Plan Research and Monitoring Action Plan 3.2 Conserving Cultural and Historic Resources Native Hawaiian Culture and History Action Plan Historic Resources Action Plan Maritime Heritage Action Plan 25-02. The revised research Action Plan Section 3.1.1 now reflects some of these suggested changes. To address specific details Response for research-related topics, a Natural Resources Science Plan will be created to guide and regulate research in the Monument, as defined in the Priority Management Need Understanding and Interpreting the NWHI, Marine Conservation Science Activity 2.1. This step-down plan will define and prioritize research activities based on management needs to protect, conserve, and when possible, restore ecosystems within the Monument. Based largely on the HAMER plan, research activities will be prioritized by the necessity of information for management purposes, including the highest priority management critical activities you point out. Due to the remoteness of the NWHI, research will be limited by vessel and field station space, so only those research December 2008 291 Volume V: Response to Comments Comment Category 25 – Research activities ranking highest in management priority will be accommodated. In addition, Marine Conservation Science Activity 2.1 stipulates that the MMB will produce a Natural Resources Science Plan to guide and regulate research in the Monument. It is in this step-down plan where detailed research and monitoring activities beyond the scope of management activities will be developed and discussed in great detail and where salient questions such as yours will be incorporated. In the Priority Management Need Managing Human Resources, cumulative impacts of human activities are addressed via the following activities, located in the Permitting Section: P-2.1, P-2.2 and P-2.3. These activities are designed to address the cumulative impacts of both research and human impacts on the Monument. They will be used to assess and evaluate these effects to aid in management decisions to provide the Monument with the best overall protection and resource conservation. These impacts will also be addressed in numerous sections of the Natural Resources Science Plan, in which more detailed studies will evaluate the cumulative impacts ongoing within the boundaries of the Monument. Investigations into the sources, types, and accumulation rates of marine debris and its removal and prevention are described in the Marine Debris Action Plan (3.3.1). Monument Management Plan Sections 3.1 and 3.1.1 have undergone a major revision. Although these revisions do not correlate directly to your suggested placement, your comments were addressed by incorporating additional language to 1) further detail the need for research, 2) to directly link any research conducted with management needs, and 3) to consider cumulative impacts of research. 25-03. The comments below express concern and objection to bioprospecting activities within the Monument. Comment Comments: 1) ABSOLUTELY NO BIOPROSPECTING EVER. 2) Additionally, a new Action Plan should be added to the DMMP regarding protection of indigenous resources from bioprospecting that may occur during activities authorized under the remaining 5 priority Action Plan groupings. This must include an enforcement action plan, a penalty schedule, and methods for repatriating resources taken from Native Hawaiians. 25-03. There is no place within the Monument Management Plan where bioprospecting is proposed. All Monument permits Response dealing with specimen or sample collecting specifically prohibit the sale of collected organisms. Bioprospecting, which is defined in the glossary as the “search for new chemicals, compounds, genes and their products in living things that will have some value to people,” inherently involves identifying biological resources with potential commercial value that may be developed into marketable commodities, such as pharmaceuticals, pesticides, and cosmetics. The special condition applied to these permits states that authorized activities must be noncommercial and must not involve the use or sale of any organisms, by-products, or materials collected within the Monument for obtaining patent or intellectual December 2008 292 Volume V: Response to Comments Comment Category 25 – Research property rights. For this reason, commercial bioprospecting would not be permitted. To clarify this, language was added in Section 3.4.1, Permitting Action Plan, in the Monument Management Plan. Please refer to the Enforcement Action Plan, Section 3.4.2, as well as NHCH 2.7 for more information on repatriation. Unique Comments 25-04. p. 120 the phrase “complementary Western science” would be rejected by many Hawaiians. Recommend remove this Comment phrase 25-04. The MMB contends that the categorization and wording is sufficient for its management purposes. Response 25-05. The former section 3.1 (p105), is now retitled “3.2 Conserving Cultural and Historic Resources.” The old section 3.1 Comment (p105) should be rewritten to reflect the new strategies and activities (following): 3.1 Conserving Wildlife and Habitats (3.1.1 Threatened and Endangered Species Action Plan, 3.1.2 Migratory Birds action plan, 3.1.3 Habitat Management and Conservation Action Plan, 3.1.4 Research and Monitoring Action Plan). Then, the new: 3.2 Conserving Cultural and Historical Resources (3.2.1 Native Hawaiian Culture and History Action Plan, 3.2.2 Historic Resources Action Plan, 3.2.3 Maritime Heritage Action Plan) 25-05. We believe that the existing structure of the document suits the purposes of the Co-Trustees and, thus, have not made the Response proposed changes.