Final environmental impact statement prepared on the proposed Channel Islands marine sanctuary

[From the U.S. Government Printing Office, www.gpo.gov]

114 oll (o
ov", OF CO 4, OASTAL ZONE
FORMIATION CEN

Vol

FINAL ENVIRONMENTAL
IMPACT STATEMENT
ON THE PROPOSED
CHANNEL ISLANDS
MARINE SANCTUARY

I T I T fj-,F.@

COASTAL ZONE
INFORMATION CENTER

FINAL ENVIRONMENTAL IMPACT STATEMENT
Prepared on the Proposed Channel
Islands Marine Sanctuary

May 1980

U.S. Department of Commerce
National Oceanic and Atmospheric
C
Administration
Office of Coastal Zone Management
3300 Whitehaven Street, NW
Washington, D.C. 20235

A*
CZIC COLLECTION

DESIGNATION: FINAL ENVIRONMENTAL IMPACT-STATEMENT

TITLE: Proposed Channel Islands Marine Sanctuary

ABSTRACT: The National Oceanic and Atmospheric Administration
proposes the designation of the waters surrounding
the four northern Channel Islands and Santa Barbara
Island as a marine sanctuary. The proposed sanctuary
would extend six nautical miles seaward from the
mean high tide line. If these waters are designated
as a marine sanctuary, the following activities would
be subject to the proposed regulations described in
this document: oil and gas operations,@discharging
or depositing any substance, alteration of or con-
struction on the seabed,, navigation and operation
within one nautical mile of the Islands of vessels
not engaged in fishing, kelp harvesting, research,
recreation, military activities, or enforcement,
aircraft overflights below 1000 feet-within one
nautical mile of the Islands,and removing or other-
wise deliberately harming cultural resources. All
regulations shall only be applied consistent with
international law. Activities necessary for national
defense or to respond to an emergency threatening life
or property are not prohibited.

Alternatives to the.proposed action include no marine
sanctuary designation, modification of the sanctuary
boundaries, and more stringent and.less stringent
regulations.

LEAD AGENCY: U.S. DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
Office of Coastal Zone Management

CONTACT: JoAnn Chandler
Sanctuary Programs Office
Office of Coastal Zone Management
3300 Whitehaven Street, N.W.
Washington, D.C. 20235
202/634-4236

TABLE OF CONTENTS

Page
A. Cover
B. Note'to the Reader B-1
C. Summary C-1
D. Purpose and Need for Action D-1
E. Description of the Affected Environment E-1

1. General Overview of the Nominated Area E-1
a Location E-1
b: Environmental Setting E-3

2. Natural Resources of Exceptional Value E-11
a. Marine Mammals E-11
b. Marine Birds E-29
c. Fish and Plant Resources E-45
d. Intertidal Organisms E-52
e. Cultural and Historic Resources E-55

3. Human Activities E-59
a. Introduction E-59
b. Oil and Gas Activities E-59
c. Commercial and Recreational Fishing and
Plant Harvesting E-70
d. Commercial Shipping E-78
e. Military Operations E-87
f. Research E-90
g. Recreation E-90

F. Alternatives F-1

1. Status Quo Alternative F-1
a.i Introduction F-1
b. Existing Management Authorities F-6
c. Environmental Consequences F-50

2. Alternative 2--the preferred alternative F-61

a. Introduction F-61
b. Management F-63
c. Regulated Activities F-70
1. Hydrocarbon operations F-71
2. Discharges of polluting substances F-116
3. Alteration of or construction on the seabed F-113
4. Operation of commercial vessels F-119
5. Disturbing marine mammals and birds by overflights F-124
6. Removing or.damaging historical or cultural
resources F-125
d. Other Regulations F-126

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3. Alternative F-131
4. Alternative 4 F-146

S. Alternative 5 F-157

6. Alternative 6 F-160

G. Comments on the Draft Environmental Impact Statement and
NOAA's Responses

H. Literature,and Personal Communications Cited H-1
a' References H-1
b: Personal Communications H-12

I. List of Preparers I-1

J. Appendices J-1
Appendix 1. Proposed final designation document and proposed
proposed regulations

Appendix 2. Fish and shellfish species of commercial and
recreational interest in the waters around the
northern Channel Islands and Santa Barbara
Island

Appendix 3. Brief review of the outer continental shelf
(OCS) oil and gas development process
Appendix 4. BLM special stipulations for Sale #48

Appendix 5. Summary of USGS Pacific OCS orders and notices
to lessees

Appendix 6. Analysis of the economic impacts of the proposed
Channel Islands sanctuary regulations
Appendix 7. Distribution list for the Channel Islands HIS

LIST OF FIGURES' Page
C-1 Preferred marine sanctuary C-7

E-1' Location of Southern California Bight E-2
E-2 Generalized water current patterns during upwellings E-6
E-3 Generalized water current patterns for oceanic period E-7
E-4 Generalized water current patterns for Davidson period E-8
ErS Santa Barbara Channel region physiographic features E--:10
E-6 Pinniped breeding and haulout areas on San Miguel
Island
a. Callorhinus ursinus E-14
b. Zalophus 'ITo 'Fni anus E"15
c. Phoca vitulina E-16
d. Mirounga angustirostris E-17
E-7 Migration ;o tes of the gray whale in the nominated area E-28
E-8 Di stribution of bird nesting colonies on San Miguel Island E-36
E-9 Distribution of bird nesting colonies on Santa Cruz Island E-37
E-10 Di stribution of bird nesting colonies on Santa Rosa Island E-38
E-11 Di stribution of bird nesting colonies on Anacapa Island E-39
E-12 Distribution of bird nesting colonies on San.ta.Barbara
Island E-40
E-13 Diversity of fish species along the Pacific coast E-47
E-14 Distribution of kelp beds in the northern Channel Islands
and Santa Barbara Island region E-49
E-15 Underwater diagram of a kelp bed E-50
E-16 Known marine cultural resources E-58
E-17 Tracts withdrawn from OCS Sale #48 by the Secretary of
the Interior E-63
E-18 Existing leases and operators and tracts offered in Sale
#48 in the Northern Channel Islands area E-64
E-18a Tracts leased in OCS Sale #48 E-65
E-19 Existing lease numbers and all tract numbers proposed
for Sale #48 E-66
E-20 Mean annual fish landings (1970 to 1974) around the
northern Channel Islands and Santa Barbara Island E-71
E-21 Cumulative density of partyboat fishing landings be-
tween 1973 and 1975 E-80
E-22 Cumulative density of anglers fishing from partyboats
in the southern California partyboat fleet E-81
E-23 Vessel traffic lanes E-83
E-24 Recreational boating concentrations and access routes
around the northern Channel Islands and Santa Barbara
Island E-95
E-25 Popular skin and SCUBA diving sites E-98

F-1 Existing federal and state management authorities as
they relate to resources and activities F-4
F-2 Ecological reserves F-10

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F-3 San Miguel Island ecological reserve F-12
F-4 Anacapa Island ecological reserve F-14
F-5 Santa Barbara Island ecological reserve F-16
F-6 Boundaries for alternative 2--the preferred marine
sanctuary F-62
F-7 Existing leases and operators, and tracts offered in
Sale #48, in the northern Channel Island area F-75
F-7a Tracts leased in OCS Sale #48 F-76
F-8 Existing leases and tracts subject to Sale #48 F-77
F-8a Tract numbers in the immediate vicinity of the
northern Channel Islands F-78
F-9 Potential oil spill trajectories F-93
F-10 Hypothetical spill locations from proposed Sale #48
leases F-98
F-11 Hypothetical spill locations from existing leases F-99
F-12 Hypothetical spill locations which correlate with tracts
withdrawn from Sale #48 F-100
F-13 Locations of Clean Seas., Inc.--the 'oil spill coopera-
tive for the northern Channel Islands area F-104
F-14 Santa Barbara Channel traffic separation scheme (TSS)
and the I nmi (1.8km) prohibition zone F-122

LIST OF TABLES Page

E-1 Marine mammals of the Southern California Bight E-12
T-2 Pinniped rookery and haulout areas E-18
E-3 Summary of ecological information for seals,'sea lions,
and sea otters I E-20
E-4 Approximate times of pinniped activity in the study
area E-22
E-5 Historical species accounts and ecological information
for cetaceans E-25
E-6 Marine avifauna of the Southern California Bight E-30
E-7 Marine birds sighted or reported near the nominated
area E-31
E-8 Known marine bird colonies in the nominated area E-35
E-9 Numbers of seabird pairs on the California Channel
Islands in 1975 E-41
E-10 Frequency of bird sightings for all species E-44
E-11 Intertidal species of.the nominated area E-53
E-12 Shipwrecks recorded in the nominated area E-57
E-13 Milestones in Santa Barbara Channel and the northern
Channel Islands area oil and gas development E"60
E-14 Estimated oil and gas reserves for currently leased
tracts in Southern Cali 'fornia Bight E-62
E-15 Platforms in the Santa Barbara Channel area E-68
E-16 Number of wells drilled on existing leases in the
vicinity of the*northern Channel Islands and Santa
Barbara Island E-69
E-17 Commercial fish landings for selected species caught
off the northern Channel Islands and Santa Barbara
Island between 1971 and 1975 E-73
E-18 1975 commercial fish landings by species around the
northern Channel Islands and Santa Barbara Island @E-74
E-19 Kelp harvests off the northern Channel Islands and
Santa Barbara Island between 1974 and 1978 E-79
E-20 Commercial passenger fishing vessel catch in numbers
of fish for the northern Channel Islands between 1970
and 1974 E-79
E-21 Commercial passenger fishing vessel catch in numbers of
fish for Santa Barbara Island between 1970 to 1974 E-79
E-22 Major research organizations which have or are likely
to conduct marine related scientific investigations on.
the coastal ocean environment in southern California E-91
E-23 Research funding entities with potential or demonstrated
relevance to the northern Channel Islands and Santa
Barbara Island waters E-92

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F-1 Summary of boundary, activity regul.ation, and management
alternatives for a marine sanctuary designation, exclusive
of the status quo alternative F-4,
F-1a Abbreviations of authorities and agencies F-5
F-2 Catch restrictions for species of commercial -fish in the
northern Channel Islands area F-19
F-3 EPA effluent guidelines and standards for far offshore
oil and gas extraction facilities F-35
F-4 Summary of potential hazards to,marine mammals, seabirds,
and marine organisms resulting from offshore oil resource
development and production F-73
F-5 Potential oil and gas development impacts mitigated by
NOAA's preferred marine sanctuary F-74
F-6 Seabird species most vulnerable to impacts related to
OCS oil resource exploitation F-87
F-7 Probability of contact by one or more 1000 bbl. spills
between 1979 and 2000 F@92
F-8 Probabilities (i'n percent) that an oil spill starting
at a particular location will reach in three days.:
(1) major haulout andbreeding areas and (2) seabird
breeding areas F-96
F-9 Oil spill recovery equipment in the vicinity of the
northern Channel Islands, F-97

B. Note to the Reader

The major segments, of this HIS are Section E, the Description of
the Affected Environment, which presents a review of the resources
and activities in the Channel Islands area; Section F,- Alter-
natives, which discusses the preferred alternative Of designating
a marine sanctuary and regulating certain activities, and five
other alternatives including a status quo or no action alter-
native; and. the summaries of comments received on the DEIS and
NOAA's responses in Section G. Certain additional documentation
is appended. Particular attention should be paid to the proposed
Designation Document and the proposed regulations presented in
Appendix 1. A compendium of the full written comments received by
NOAA is included in a separate volume. This compendium is being
mailed to all the commenters'and Federal contacts .and is available
from NOAA upon request.

citations are referenced in the text by the name of the author or
source in parentheses. Section H, Literature and Personal Commu-
.nications Cited, contains detailed information on both documentary
references and personal communications.

B-1

C. Summary

Introduction

The Marine Protection, Research and Sanctuaries Act of 1972 (16
U.S.C. 1431-1434) authorizes the Secretary of Commerce, after
consultation with appropriate Federal agencies, concurrence of the
affected State, and Presidential approval, to designate ocean
areas having distinctive conservation, recreational, ecological,
or aesthetic values as marine sanctuaries. In 1977, the National
Ocean ic and Atmospheric Administration (NOAA) of the Department of
Commerce sent out a nationwide letter asking for recommendations
of sites appropriate for consideration as marine sanctuaries. The
response included several different recommendations for the waters
around the northern Channel Islands and Santa Barbara Island. The
Resources Agency of the State of California recommended the waters
extending 12 nmi (22km) around each of the eight Channel Islands,
the National Park Service proposed the waters extending 8 nmi
(14.8km) around the northern Channel Islands and Santa Barbara
Island, and the County of Santa Barbara proposed the entire Santa
Barbara Channel and the waters around the northern Channel Islands
and over the Santa Rosa Plateau, but excluding State waters. In
June 1978, the County of Santa Barbara followed up its recom-
mendation with a formal nomination.

This Final Environmental Impact Statement (FEIS) proposes the
creation of a marine sanctuary in the waters around the northern
Channel Islands and Santa Barbara Island extending 6 nautical
miles (nmi) (11.1 kilometers (km)) seaward from the mean high tide
line. The waters immediately around the Islands support an
extraordinary assemblage of marine mammals, numerous seabirds
including the endangered bro n pelican, and important fishery
C

resources, including kelp and shellfish (see Section E for a
discussion of the natural resources). Until recently, the waters
around the islands have been left relatively untouched by human
activity because of their distance from the populous mainland.

Use of the Santa Barbara Channel is increasing, however, and,
based on the unique characteristics of the marine sanctuary
program, designation and management of a sanctuary at this site
would assist in the preservation of its distinctive ecological and
recreational values. Establishment of a marine sanctuary would
provide a formal institutional recognition of' the national signi-
ficance of the resources of this site and would focus, over the
long term, on the range of actions necessary to preserve these
resources. The proposed sanctuary will concentrate on the manage-
ment of this marine area in a manner which will complement the
management of the recently created Channel Islands National Park.

The management of the sanctuary will include research, assessment,
education, coordination and regulation. A comprehensive program
of this nature does not exist and will not be created in the
absence of a sanctuary. Preservation of these marine resources
requires an understanding of their condition, both current and
evolving. A research, assessment and monitoring program is
essential and would be instituted by the marine sanctuary. Funds
would be available for the conduct of specific studies and for
projects to coordinate and analyze existing data to assist in the
decisions concerning sanctuary management. Likewise, the long
term preservation of ecological, conservation, and recreational
values requires public awareness of the value of the resources and
of potential harm to the resources. Users of the proposed sanc-
tuary must be informed and educated in order to reduce harm to
sensitive areas. The proposed sanctuary would undertake a variety

r_2

of such educational programs. The proposed marine sanctuary would
also provide a focus for the coordination of the variety of
regulatory actions which state, local and federal agencies already
undertake in this area. This coordination, which would occur
through a sanctuarv advisory committee or some other struc'ture
created by mutual agreement, would help assure that.
complete information concerning the cumulative impacts of activi-
ties within the proposed sanctuary is considered as each separate
agency pursues its discrete mission and regulatory activities.
Finally, through the promulgation of limited additional regu-
lations, the. sanctuary would control certain activities which are
currently 'not addressed in a manner most appropriate to the
preservation of the special values of this rich marine area.

To determine the desirability and feasibility of proceeding with
the designation, NOAA has gathered and analyzed information and
consulted with other Federal agencies; State agencies, particu-
larly the California Coastal Commission (CCC); the Pacific Regio-
nal Fishery Management Council; and local interest groups. In
April 1978, NOAA held a public workshop in Santa Barbara to
discuss the sanctuary proposal. An Issue Paper on possible
California marine sanctuary sites, including the Channel Islands,
was circulated for review and discussion in December 1978. In
February and March 1979, the California Coastal Commission (CCC)
held regional and State hearings to solicit reaction to the
possibility of a marine sanctuary near the Channel Islands. Based
on public response and a recommendation by the CCC to develop a
draft environmental impact statement (DEIS), NOAA prepared a DEIS
which described the proposed action to designate the sanctuary,
including draft regulations on activities and uses. NOAA distri-
buted copies of and solicited comments on a preliminary draft of
the Description of the Affected Environment (Section E.) and an
outline of five designation' options and the status quo option in

C-3

June, 1979. NOAA held public meetings in Santa Barbara and
Ventura to discuss these documents and answer questions about the

program.

In *November 1979, NOAA issued proposed regulations and the DEIS
for public review. NOAA held public hearings on the DEIS in
Ventura and Santa Barbara on January 10 and January 11, 1980, and
accepted written comments until January 23. The comment period
was extended to February 4, 1980, to be, consistent with the
comment period on the proposed regulations and again to March 7,
1980, to assure receipt and consideration of comments from the
maximum number of interested parties.

This final environmental impact statement (FEIS) summarizes and
responds to all the comments received through March 7, 1980. It
proposes the designation of a marine sanctuary in the waters
around the northern Channel Islands and Santa Barbara Island and
describes the proposed regulations in this sanctuary. The bound-
aries and regulations proposed for the Channel Islands Marine
Sanctuary are summarized below, discussed in Section F, and set
forth in Appendix 1. The changes to the proposal from the prefer-
red alternative in the DEIS are as follows:

1) The regulation of vessel traffic within I nmi of the
Islands has been rewritten so that it is absolutely
clear that fishing, recreational and research vessels
are allowed within the Islands' nearshore waters.

2) Airplane overflights for the purpose of surveying kelp
beds have been exempted from the prohibition on over-
flights below 1000 ft. within 1 nmi of the Islands.

3) The harvest of kelp has been exempted from marine sanctuary
regulation in the designation document along wfth fishing.

C-4

4) The navigation of vessels within vessel traffic separation
schemes and port access routes designated by the Coast
Guard outside the Islands' nearshore waters have been
exempted from regulation by the Designation.

5) Any amendment to the regulations which significantly alters
the extent to which activities are restricted will be auto-
matically considered a direct effect on California's coastal
zone for Federal consistency purposes. If California proposes
to relax any requirement in State waters, NOAA will propose
an amendment to conform the sanctuary regulations unless
clearly inconsistent with the purposes of the sanctuary.

The proposed Designation and regulations do not represent a final
decision. NOAA will receive comments on this FEIS for thirty days
following publication and then consult with Federal agencies.
After review and consultation, a decision will be made whether to
proceed with the designation. If so, the Secretary of Commerce
must obtain Presidential approval of the designation.

The final rules will be promulgated after desig*nation. The
Designation and, therefore, the regulations are not effective
within State waters for a period of sixty days following publi-
cation of the Designation. During this period, if the Governor
certifies that the Designation is unacceptable to the State, the
sanctuary will not include State waters and the Secretary may
withdraw it entirely if it no Jonger meets statutory and regul-
atory objectives.

C-5

PROPOSAL TO DESIGNATE THE CHANNEL ISLA14DS MARINE SANCTUARY

The Office of Coastal Zone Management, which is reponsible for the
marine sanctuary program within NOAA, proposes the designation as
a marine sanctuary' of the waters surrounding the northern Channel
Islands and Santa Barbara Island, extending from the mean high
tide water line on the four northern Channel Islands (San Miguel
Island and adjacent rocks (Castle Rock and Richardson Rock), Santa
Cruz Island, , Santa Rosa Island, and Anacapa Island) and Santa
Barbara Island seaward 6 nmi (11.1km) (see Figure C-1). The exact
boundary by coordinates is presented in an appendix to the pro-
posed regulations. The proposed sanctuary encompasses 1252.5
square nautical miles (4286.7km2

Designation

The Designation Document (the proposed Designation for the Channel
Islands marine sanctuary is presented in Appendix 1) serves as a
constitution for the sanctuary. It establishes the boundary and
purposes of the sanctuary, identifies the types of activities that
may be subject to regulations, specifies the extent to which other
regulatory programs will continue to be effective within the
sanctuary, and provides a framework for sanctuary management,
including research, assessment, education, and coordination. The
Designation requires the approval of the President. Its content
can be altered only after repeating the entire designation process
and securing Presidential approval.

If the designation is adopted, the following activities will be
subject to necessary and reasonable regulation:

C-6

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Sancti

CONTOUR

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Coo.

SAN WGUEL
ISLAND ANACAPA
SANU CRUZ

sum
BLAND

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9:71
e-N I

NAUTICAL MWES

FIGURE C-1. The preferred Marine Sanctuary
SAAA

-oil and gas operations
-discharging or depositing any substance
-alteration of or construction on the seabed
-navigation (except within a designated VTSS or PAR)
and operation of vessels (other than fishing
and kelp harvesting vessels) and aircraft over-
flights below 1000 ft (305m)
-r emoving or otherwise deliberately harming cultural
or historical artifacts

The proposed restrictions on these activities are set forth in the
proposed regulations. NOAA may legally promulgate regulations
only in relation to the specific activities listed in the Desig-
nation. Article 5 of the proposed Designation specifically
exempts fishing and kelp harvesting activities from sanctuary
regulation, except that fishing and kelp harvesting vessels may be
regulated with respect to discharges.

Management

Management of the marine sanctuary will be designed to preserve
the resources of the waters surrounding the northern Channel
Islands and Santa Barbara Islands in their present relatively
undisturbed state. By integrating education, environmental
monitoring, research, and compatible use regulations into a
coordinated management strategy, NOAA will insure that the public
can derive maximum benefit from the marine sanctuary with a
minimum of environmental damage.

C-8

If a sanctuary is established, NOAA will emphasize the national
importance of the sanctuary,s resources. NOAA will establish a
Sanctuary Information Center and will promote the public's aware-
ness of sanctuary resources through brochures and other tech-
niques. NOAA will encourage and seek to coordinate research
within the sanctuary. Such coordination will not only help to
improve the data base on area resources and stimulate information
exchange, but also should help to eliminate duplicative research
and close data gaps. Sanctuary management will strive also to
improve public access. Finally, both resource quality and effects
of human activities in the sanctuary will be monitored. These
results should aid in further upgrading the management system
whenever necessary.

NOAA plans to delegate onsite sanctuary management to an existing
authority with regional experience, for example, the California
Department of Fish and Game (DFG). The onsite manager will
coordinate with other Federal and State agencies, conduct re-
search, monitoring, review permit applications, and make recom-
mendations to NOAA concerning changes in regulations or overall
management policies. NOAA will encourage the onsite manager to
fbrm an advisory council with representatives from Federal, State,
and local agencies, user groups, and citizen associations.

Enforcement and surveillance will be an integral part of the
management and protection of the Channel Islands Marine Sanctuary.
NOAA is exploring various means of providing enforcement and
surveillance; the National Marine Fisheries Service, the U.S.
Coast Guard, the National Park Service, and DFG have experience in
such operations so NOAA will further explore the possibility of
cooperative management with each of these agencies. The parti-
C-9

cipation of any enforcement agent will, of course, be subject to
continuing discussions and will be affected by the precise scope
an'd content of the final regulations, as well as by other demands
and'priorities facing NOAA and the other agencies involved.

Under a cooperative agreement with NOAA, DFG is currently gather-
ing information and consulting with other interested agencies to
formulate more detailed suggested management programs, addressing
research, education, interagency coordination, and access.

DFG will also explore enforcement issues both as they relate to
the need for additional resources to enforce existing regulations
and to the mechanisms and resources appropriate to enforce the
proposed regulations. Some regulations are unlikely to require
extensive enforcement activities, such as those relating to
hydrocarbon exploration and development and dredging. Others,
such as the regulation of discharges, may require surveillance of
areas of the proposed sanctuary or intensive education of sanc-
tuary users. The U.S. Coast Guard has indicated its willingness
to cooperate to the limits of its normal enforcement activities.
The National Park Service and DFG already have a cooperative
relationship in relation to enforcement of State regulations in
the very nearshore waters around the Islands which is likely to be
susceptible to modification to serve the enforcement needs of the
sanctuary.

The draft report by DFG should be available for final consul-
tations with other agencies and will be made available for public
comment and review when final and prior to the institution of
management measures, if the sanctuary is designated.

C-10

Proposed Regulations

Specific regulations are proposed as reasonable and necessary for
the protection of the natural resources. To the extent possible,
the sanctuary managers will coordinate with existing authorities
in both the administration and enforcement of the regulations.
This coordination may be accomplished in several ways. Agencies
may wish to alter their regulations in this area to conform with
sanctuary regulations, or they may want to use their review and
enforcement capabilities to implement NOAA provisions. Other
interagency arrangements to facilitate coordination are possible.
Each such step will be the subject of discussion with the indivi-
dual agency concerned. If no specific . arrangements are agreed
upon, and more than one regulation affecting certain activities is
.in effect, all regulations will apply and the most stringent
restrictions must be met. These regulations will apply only
within the sanctuary boundaries. The full text of the proposed
regulations is presented Appendix 1.

The proposed regulations would impose the following controls:

--Hydrocarbon operations

The proposed regulation prohibits any activity for the exploration
or exploitation of hydrocarbons (oil and gas) anywhere in the
sanctuary pursuant to leases executed on or after the effective
date of these regulations. Exploration, production and develop-
ment pursuant to leases predating the effective date of the
regulations and the construction of pipelines are allowed subject
to all other proposed- sanctuary regulations and all regulations

C-11

and conditions imposed by the following entities: the Department
of the Interior, the U.S. Coast Guard, the Corps of Engineers, the
Environmental Protection Agency, the State of California under the
Federal consistency provisions of the Coastal Zone Management Act,
and any other State or Federal authority. This activity is
permitted subject to the further requirement that certain oil
spill contingency equipment is present for such operations (see
Section F.2.b.1). The regulations are designed to reduce the risk
of contamination of the nearshore resources by spilled oil, and to
protect the island shores from visual and acoustic disturbances.

Currently, the Bureau of Land Management and the U.S. Geological
Survey regulate hydrocarbon activities on the Outer Continental
Shelf (OCS), and the State Lands Commission has responsibility for
oil and gas leasing in State waters. The Secretary of the Inter-
ior withdrew 24 tracts in the proposed marine sanctuary from
leasing in OCS Sale #48, but, absent sanctuary regulations, tracts
within the area of the proposed sanctuary may be considered for
and offered in future lease sales.

--Discharges

The proposed regulation prohibits all discharges into sanctuary
waters, except discharges of indigenous fish waste and chumming
materials, effluents from marine sanitation devices, non-polluted
cooling waters from ocean-going vessels,,and effluents incidental
to allowed hydrocarbon operations regulated by the standards
imposed in an NPOES permit. Discharges from foreign flag vessels
are also prohibited to the extent consistent with international
law. The prohibition on discharges will help maintain the water
quality in the sanctuary and prevent aesthetic degradation. The
exemptions insure that this regulation will not prevent activities

C-12

consistent with the goals of the sanctuary.

Existing regulations control through permits some of the present
sources of contamination of the ocean waters. Point source
discharges are controlled by permits issued by the Environmental
Protection Agency (EPA), which also has authority to regulate oil
and hazardous substance discharges and ocean dumping. However,
discharges may be permitted by EPA in the proposed sanctuary since
no special status is permanently assigned to this site. Solid
waste overboard discharges from vessels are not currently regu-
lated. Existing regulations do not prohibit discharges from
tankers and other vessels smaller than 150 gross tons, respec-
tively, which might occur beyond the territorial zone (3 nmi
(5.4km)). The limited discharge standard proposed by the sanc-
tuary would eliminate a variety of currently allowed discharges.

--Alteration of, or construction on, the seabed

The proposed regulation prohibits dredging, drilling, constructing
on, or altering the seabed within 2 nmi (3.7km) of the islands,
except to construct navigation aids or lay pipelines. This
prohibition offers a buffer for sensitive nearshore resources,
including marine mammals, seabirds, and benthic organisms, from
the visual, acoustic, and pollution/sedimentation disturbances
associated with seabed alteration.

The Army Corps of Engineers and the California Coastal Commission
currently have permitting authority over construction, dredging,
and dredge spoil disposal. The Bureau of Land Management and
State Lands Commission have authority over mining. No agency has
issued particular restrictions on dredging and construction which

C-13

areAntended to benefit and preserve the ecosystem of this area.
Dredge spoil disposal, while subject to permit requirements, is
not otherwise prohibited in the proposed sanctuary.

The laying of pipeline 's is exempted from this regulation because
the level of disturbance and risk of oil pollution associated with
barging supplies and oil and gas to and from offshore platforms is
often higher than the disturbance and pollution risk associated
with the laying of pipelines.

--Vessel traffic

The proposed regulation prohibits the passage of certain U.S. flag
and, to the extent consistent with international law, foreign
vessels within 1 nmi (1.8km) of the islands to protect sensitive
nearshore resources from disturbance and possible oil spills or
discharges resulting from groundings, collision, or normal opera-
tion. This restriction also serves to decrease congestion in
nearshore zones. Fishing, kelp harvesting, recreational, re-
search, military, and enforcement vessels are exempted from this
prohibition.

The Coast Guard currently recommends vessel traffic lanes but does
not require adherence to them. The California Department of Fish
and Game restricts vessel access in parts of the ecological
reserves around Anacapa and San Miguel Islands.

C-14

--Disturbing marine birds and mammals by overflights

To insure that sensitive nearshore resources, particularly marine
mammals and seabirds, are fully protected, disturbance by over-
flights at less than 1000 ft (305m) is prohibited within 1 nmi
(1.8km) of the islands. Military search and rescue, and enforce-
ment operations, kelp harvesting surveys, and access to the
islands are exempted from this regulation.

The Federal Aviation Administration (FAA), which currently regu-
lates air traffic, will indicate some sensitive areas on charts,
and will print a request from the concerned agency that pilots
maintain a certain altitude in those areas. However, the FAA
issues regulations for the safety of air traffic, and not to avoid
potentially adverse impacts on ecosystems, species, or habitat.
Accordingly, overflights of this area are not currently limited.
The California Department of Fish and Game controls overflights
directly over San Miguel, Anacapa, and Santa Barbara Islands.

--Historical or cultural resources

California can register sites as either "points of interest" or
"landmarks." The latter would afford some protection against
harmful activities, but only within State waters. Sites beyond
State waters can be registered on the National Register of Histo-
ric Sites; however, reQi stration-provi des protection only against
Federal and not private activities. Accordingly, the proposed
sanctuary regulations would prohibit removing or damaging histo-
rical or cultural resources within the sanctuary.

C-15

Environmental and Soclo-Economic Consequences of the Pro@2sed Action

The proposed action would institute an integrated management
program including research, monitoring, education, long term
planning, coordination and regulation that would provide increased
protection for the special resources of the proposed sanctuary,
particularly marine birds and mammals. The Director of the Fish
and Wildlife Service has concluded, following official consul-
tation under Section 7 of the Endangered Species Act, that the
marine sanctuary will promote the conservation of the bald eagle,
American peregrine falcon, and the southern sea otter and is not
likely to jeopardize the continued existence of the California
brown pelican (Greenwalt, 1980', personal communication),

The research, assessment and monitoring programs would increase
available knowledge on the present condition of the resources and
would help measure impacts of human activities. Results from
these programs would be utilized not only to increase the effec-
tiveness of sanctuary management, but to advise other agencies
proposing actions. The sanctuary would establish a special
institutional voice for the resources of this area.

The long term preservation of the special resources near the
Islands will depend on public awareness and education. The
sanctuary would promote public awareness and increase the atten-
tion of users to the issues of conservation.

The sanctuary would also address long range planning issues and
other concerns which may arise in the future, which are presently
not addressed by any institution. For instance, the sanctuary
management plan would address matters such as the desirability of
a public transportation system to all or parts of the sanctuary,
and it would consider methods to increase access and enjoyment of
the sanctuary by the poor, the elderly, and the handicapped.

The sanctuary managers would be concerned with the separate and
cumulative impacts of all activities occurring within its bound-
aries, and would therefore perform a coordinating function.
Coordination, even in the simple form of assuring transfer of
information, will help assure full consideration is given by all
agencies to the resources of the area.

Finally, through limited proposed regulations, the Sanctuary would
control certain activities which require further restriction to
assure preservation of the resources of the area. The regulations
attempt to minimize any adverse socioeconomic consequences on
affected industries, to the extent consistent with the primary
mission of resource preservation. In addition, by contributing to
the preservation of the natural resources of the area, the pro-
posed action should benefit those activities such as fishing,
tourism, and recreation which depend on these resources.

Because the proposed regulations have been formulated in detail
and are the aspect of the sanctuary management program most likely
to produce socio-economic consequences; they are discussed in some
detail below.

C-17

The prohibition of petroleum operations on leases acquired on or
after the effective date of the sanctuary regulations will guar-
antee the continued existence of an area of minimal OC.S develop-
ment. The Department of the Interior withdrew 24 tracts within 6
nmi of the Islands from OCS Lease Sale #48. The existence of such
an area of minimal petroleum development will protect sanctuary
resources that are particularly vulnerable to spilled oil and to
human activity associated with normal petroleum operations and oil
spill cleanup attempts from increased activity levels in the
future.

The 6 nmi (11.1km) buffer provides time and distance for natural
forces to weather and volatilize oil spills and other discharges
before they reach nearshore communities. The buffer also in-
creases the available response time for at-sea cleanup and oil
spill containment, and if nearshore cleanup becomes necessary,
allows a longer planning period; nearshore cleanup activities may
.otherwise be even more damaging than the oil itself. The buffer
reduces the visual and acoustic disturbances of petroleum develop-
ment which may affect marine mammals, seabirds, and the aesthetic
qualities of the islands. Finally, 'the buffer will insure the
continued integrity of California's oil and gas sanctuaries and
prevent the potential need for a drainage sale with associated
disruption and potential damage to nearshore resources.

This prohibition does not affect activities pursuant to leases
within the sanctuary which predate the effective date of the
regulations and are partially or wholly within the proposed
sanctuary. While the majority of tracts wholly or partially
inside the proposed sanctuary were withdrawn from Lease Sale #48
(which occurred June 29, 1979), the regulation is necessary to

C-18

assume the long-term protection of the area. For example, the
call for nominations and comments on Lease Sale #68 included some
of the waters within 6 nmi of the Islands. Although the Secretary
of the Interior retains the authority to exclude these tracts from
Lease Sale #68 later in the lease sale process and such a with-
drawal would be consistent with the Secretary of the Interior's
decision to withdraw 24 tracts from Lease Sale #48,no authorit.y
exists to withdraw permanently this area from leasing.

NOAA will seek the cooperation of the Department of the Interior
to insure that the tracts affected by the prohibition are not
offered for lease. If petroleum reserves exist in these areas
which cannot be tapped from outside the sanctuary, these reserves
will be unavailable under the proposed regulation. In February
1979 the U. S. Geological Survey (USGS) estimated that there were
6.7 million barrels of oil and 8.9 billion cubic feet of gas
underlying 24 tracts in the proposed sanctuary which the Secretary
of Interior withdrew from Lease Sale 48 although these resources
may not all be profitable to produce. No reliable data are
available on the amount of petroleum underlying the entire pro-
posed sanctuary. Past exploration in the area has proven nega-
tive, but that does not preclude the possibility of recoverable

reserves.

This area adjoins the Santa Barb.ara Channel, which is an area of
high proven petroleum reserves. Currently, production of oil and
gas is concentrated near the mainland and several leases near the
northern Channel Islands were terminated because of insufficient
attempts at exploration and development by the leaseholders.
However, as petroleum prices rise, reserves that are not now
profitable to produce may become so. If the need for oil under-
lying the proposed sanctuary increases and the technology becomes

C-19

environmentally safe, the regulations could be changed at a later
date to allow hydrocarbon development.

The 6 nmi (11.1km) buffer created by the prohibition on oil and
gas activities does not provide complete protection from the
adverse effects of petroleum operations: first, in a marine
environment the transport of substances from one location to
another is inevitable; and secondly, operations on existing leases
are allowed in the sanctuary in order to minimize the economic
impact of the sanctuary and the burden on the lessees. The
proposed regulations allow development of existing leases in
accordance with other sanctuary regulations and all conditions
imposed by existing authorities. The requirement for certain
additional on-site oil spill containment equipment should not
place large additional cost on the industry, particularly since
similar equipment may also be required by the State of California
under the consistency provisions of the Coastal Zone Management
Act.

The prohibition of discharges will enhance the area's aesthetic
features by lessening levels of litter thrown overboard and will
reduce the threat that marine mammals and seabirds in the sanc-
tuary will swallow or become entangled in potentially harmful
trash. It will further maintain water quality by ensuring that no
ocean dumping or dredge spoil disposal occurs in the sanctuary.
The economic impact of this regulation on sanctuary users is
minor, although they will be required to retain their trash for
proper disposal on land. The regulation supplements prohibitions
of discharges of oil and hazardous substances within 50 miles of
the nearest land.

C-20

The:impacts of prohibiting seabed alteration and construction are
expected to be minor since all current dredging occurs outside the
sanctuary.*

The regulation prohibiting certain commercial vessels from the
waters within 1 nmi (1.8km) of the islands will probably have
minimal economic impacts because the affected vessels generally
remain in the vessel traffic lanes and thus well away from near-
shore areas. Fishing, recreational, kelp harvesting, research,
military and enforcement vessels will be allowed in nearshore
waters.

Since military and enforcement operations, kelp surveys, and
landings on the islands are exempted from the overflight prohi-
bition and commercial aircraft fly much higher), the prohibition
on flying below 1000 ft (305m) within I nmi (1.8km) of the islands
will primarily affect recreationists observing area resources,
especially whales.

The environmental and economic consequences of prohibiting the
removal or damage of historical or cultural resources should be
minimal. More precise estimates of the consequences will be
possible after all identified resources are mapped.

NOAA's preferred marine sanctuary and the proposed regulations
will not prohibit military operations necessary to the national
defense or in a national emergency or actions necessary to respond
to an emergency threatening life, property, or the environment.

r-71

Marine Sanctuary Permits

Marine sanctuary permits, issued by NOAA, will be required for any
activity otherwise prohibited by the regulations and may be
granted only if the activity will serve research or educational
purposes. The permit procedure is specified in the regulations
(Appendix 1). NOAA will coordinate its permit procedure with
other authorities to the maximum extent possible.

Certification of Other Permits

The regulations propose to certify in advance any permit, license,
or other authorization issued pursuant to any other authority
within the sanctuary as long as the activity does not violate
marine sanctuary regulations. This notice of validity avoids
permit delays and costs from duplicative reviews where there is no
violation.

C-22

D. Purpose and Need for Action

NOAA proposes that, as an area of exceptional value subject to
mounting development and use pressures, the waters offshore of San
Miguel, Santa Rosa, Santa Cruz, Anacapa, and Santa Barbara Islands
deserve special recognition, protection, and management as a
marine sanctuary.

Located at the confluence of two major biogeographic coastal
provinces, in an area of exceptionally high biologic productivity,
on a submarine ridge possessing. a wide variety of open water
marine habitat, the waters around the northern Channel Islands and
Santa Barbara Island support a large and varied array of signi-
ficant natural resources.

Among the resources found at the northern Channel Islands and
Santa Barbara Island is one of the largest and most varied assem-
blages of pinnipeds in the world. The waters surrounding the
islands serve as Jeeding grounds for six species of seals and sea
lions including one species (the Guadalupe fur seal) which may be
proposed for listing as an endangered species. In addition,
numerous species of whales and dolphins migrate through the area,
including several endangered species. A large number of marine
birds also depend on the waters around the northern Channel
Islands and Santa Barbara Island. The islands serve as rookery
areas for 9 of the 12 species of nesting marine birds found in the
Southern California Bight, and the surrounding waters provide an
essential foraging and rafting area for resident and transient
species. Marine fish, algae (particularly kelp beds), and inter-
tidal habitats also comprise a major component of the ecosystem.
Finfish, shellfish, and kelp found in the area have exceptional
ecological, recreational, and commercial value.

D-1

Wi th this concentration. of highly productive, diverse, and rich
living resources in a relatively small geographic area, the waters
around the Channel Islands are also of high research value.
Extensive studies of these marine areas have been conducted.

The recreational opportunities in the waters surrounding the
northern Channel Islands and Santa Barbara Island include pleasure
boating, skin diving, sportfishing, and nature studies, such as
bird and mammal watching.

Congress recently acknowledged the extraordinary value of this
area through its, creation of the Channel Islands National Park,
which expanded and strengthened the Channel Islands National
Monument. Park designation will provide protection and management
for the special values of the Islands. However, in the debates- in
the House which accompanied the legislation creating the Channel
Islands National Park, Congressman Sibelius voiced concern about
the ability of the park to protect adequately the resources of the
Islands from threats orginating in surrounding waters such as
tanker traffic and oil and gas drilling (Congressional Record, May
7, 1979, H2751). The park boundary does extend 1 nmi into the
water but is purely an administrative boundary and does not carry
with it any authority for NPS to regulate activities in the
waters. It does provide authority for NPS enforcement agents to
enforce the regulations issued by other agencies that apply to the
waters, such as those issued by DFG or any final regulations
promulgated for the proposed marine sanctuary.

Until recently, the island waters maintained relative isolation
from activities which could affect them, primarily due to their
distance from the mainland. Therefore, formal recognition of the
particular value of these waters to marine mammal, marine bird,

D-2

fish, kelp, and intertidal communities, and to recreational and
research activities was not needed. Various '@ agencies regulated
specific uses of the waters, but the establishment of a compre-
hensive management system to protect these waters was not re-
quired. More recent and ever-increasing development and use,
however, have made the reliance on geographic remoteness insuf-
ficient to avoid increased pressure upon and potential harm to the
components of this rich ecosystem.

Although the Secretary of the Interior withdrew 24 tracts within 6
nmi (11.1km) of the islands from' Lease Sale 48, pressure for
expanded offshore oil an.d gas development in the Santa Barbara
Channel and around the Channel Islands is likely to increase.
Several tracts within 6 nmi (11.1km) of the islands,were leased in
Sale 35, and unless the area is given special status, future lease
sales (Sale #68 in 1982 and Sale #73 in 1983) may include, near-
shore areas. New drilling and redrilling for oil and gas is being
planned on several existing leases near the islands.

The Santa Barbara Channel also has become an important commercial
shipping area with use levels expected to increase as additional
tankers bring oil and liquid natural gas (LNG) into southern
California ports. Specifically, the movement of oil from the Elk
Hills Petroleum Reserve and from drilling platforms in the Chan-
nel, as well as the projected development of an LNG terminal in
the Channel region, may significantly increase tanker transport'of
oil and hazardous substances through the Santa Barbara Channel.
The shipment of rocket boosters and external tanks to Vandenberg
Air Force Base for the Space Shuttle Vehicle System will increase
the number of barges transitting the Channel. The construction of
a Northern Tier pipeline and of platform to shore pipelines in the
Channel may, however, cut down on some of the tanker and barge

D@-3

traffic in the Channel.

Commercial fishing activity, already firmly established around the
northern Channel Islands, will continue and. possibly increase in
intensity as market demands for fish expand. With' a growing
southern California population, the area has also become more
freque.ntly sought out as a recreational resource. Because of the
areals varied recreational potential and the paucity of undis-
turbed natural marine settings elsewhere in the region, the demand
for recreational opportunities will grow. Finally, the Department
of Defense, particularly the U.S. Navy, uses much of the Channel
and Channel Isl ands area for various training and testing activi-
ties.

In summary, increasing development within the Channel and in the
waters surrounding the northern Channel Islands is gradually
eroding the buffer of isolation that previously protected the
areals outstanding natural resources, and pressures are likely to
continue growing in the future. Therefore, some form of special
protection is desireable in order to ensure that the extraordinary
wealth of natural resources in the area is not jeopardized, and a
focussed management program dealing with research, assessment,
education, coordination, long-term planning, and regulation is
required.

Although many agencies currently regulate or have authority over
specific activities and particular natural resources of the island
waters, no single authority has responsibility for mor0toring the
entire system and acting to protect that system. Consequently,
the impacts of each activity which might affect the resources are
evaluated separately, and cumulative impacts may be overlooked.

0-4

Currently, there is no provision for comprehensively monitoring
the effects of human activities in the area. Without some provi-
sion for study and monitoring, it is impossible to act in a manner
insuring the long-term protection and preservation of the marine
resources of the waters near the islands. The absence of a
program of public education reduces public- awareness of the value
and sensitivity of the area's natural resources.

Furthermore, the waters around the islands have no formal recoq-
nition of their special environmental value. In some cases, it
may be in.the general public's interest to allow activities which
may pose threats to the environment, such as the siting of an LNG
terminal. Such decisions, however, must be balanced against the
region's important resources. In the absence of formal recog-
nition of the importance of the waters around the Channel Islands,
there is no assurance that the existing authorities will ade-
quately consider the particular value and. vulnerability of this
vital habitat.

The designation of a marine sanctuary in these waters would create
a system responsible for assessing the overall impacts of activi-
ties in the area. More formal acknowledgement of the special
value of the area would insure that it is given special protection
and consideration in an overall planning sense, and would en-
courage particularly careful review of any proposals for future
siting of potentially harmful activities nearby. Finally, moni-
toring and study of the sanctuary would provide the basis for a
greater understanding of the area's needs and ecological balance
and would provide the foundation for better management.

In light of the identif Iied needs, the proposed sanctuary would
have the following objectives:

L. To preserve a unique and strategically located part of the
California outer continental shelf where marine life, geo-
logical formations, and ocean currents combine to form an
outstanding marine..ecosystem by ensuring that human uses
and activities within the proposed sanctuary boundaries do
not: (a) degrade intertidal and subtidal habitats and
their associated communities or foraging, resting,
migratory, or other open water habitat areas of value
to marine birds and mammals.; or (b) otherwise threaten'
.the continued health, stability, diversity or numbers
of seabird or marine mammal populations using sanctuary

waters.
2. To encourage scientific research consistent with objective 1
on the significant resources of the area which will contribute
to the.understanding of ecologic relationships*and to the re-
solution of management and regulatory issues.
3. To enhance public awareness of sanctuary resources by
ensuring adequate interpretive and educational services.

D-6

E. DESCRIPTION OF THE AFFECTED ENVIRONMENT

E.1. General Overview of the Nominated Area

EA.a. Location

The ocean area currently under investigation lies within the
northern portion of a regional coastal ocean area commonly refer-
red to as the Southern California Bight (see Figure E-1). This
area (also referred to below as the study area) includes the Santa
Barbara Channel and the waters surrounding the four northern
Channel Islands of San Miguel, Santa Rosa, Santa Cruz, and Anacap4
as well as Santa Barbara Island. The shoreward boundary of the
area under consideration extends to the upper limit of high tide.
A set seaward boundary was not established for purposes of asses-
sing environmental resources, but specific boundary alternatives
are developed in Section F based upon this assessment of the
affected environment.

This area was selected in large part because of the extraordinary
concentration of the following resources: 1) marine mammals; 2)
seabirds; 3) fish, shellfish, and kelp resources; 4) intertidal
organisms; and, to a lesser extent, 5) archaeologic/historic
resources. Accordingly, each of these resource categories is
addressed separately. in Section E.2. Human activities in areas
near these resources are discussed in Section E.3.

E-1

w too. 130

NAUTICAL MILES

1?0 @00 300
10
KILOMETERS
San Francisco

CALIFORNIA

Point Conception
southern California.Bigh
,,Los Angeles
San Miguel Is.
Santa Rosa Is.
San Diego

MEXICO
Anacapa Is.

San Nicolas Is.

Santa Barbara Is.

Santa Catalina Is.

San Clemente Is.
@ @h

FIGURE E-1. Location of the Southern California Bight

E-2

E.1.b. Environmental Setting

Prior to reviewing each of the above-listed resource categories,
it is necessary to recognize the significance of the broader
ecologic system which supports and influences the localized
resource assemblage. This requires some understanding of the role
and importance of intricate physical and biological processes
which link resources to,the regional environment.

A marine sanctuary cannot be a self-contained environmental unit
whose living natural resources are independent of broader environ-
mental conditions. The sanctuary can, however, describe an area
whose natural conditions, as influenced by surrounding environ-
mental processes, permit the site to serve as a focal point for
biologic activity or .resources of special significance. The
following discussion briefly highlights some of the most important
region-wide processes, conditions, and pathways which serve to
influence the significant resources concentrating within the
Channel Island shelf marine environment.

Perhaps the most significant aspect of the northern Channel
Islands is their location at the transition point between two
biogeographic coastal provinces. Stretching along the coast to
the north from Point Conception to Alaska is a biologically rich
cold-temperate province referred to by Hedgpeth (1975) as the
boreal - antiboreal littoral province. To the south from Point
Conception to the lower third of Baja California in Mexico is a
warm-temperate area referred to by Briggs (1974) as the San Diego
biogeographic province. The biota of this transition zone in-
cludes cold temperate species from the north and tropical species
from the south, as well as a large number of endemic (or regional-
ly limited) species.

E-3

The importance'of Point Conception as a major marine biogeographic
boundary is well documented. Briggs (1974) cites several investi-
gators who- note that this California point lies at a significant
biogeographic boundary for many species of fish, and invertebrates
such as bryozoans* and mollusks.. In addition, the point is also a
significant boundary area for several species of marine mammals
and seabirds. The area marks a northern breeding limit for some
warm-temperate species and a southern breeding limit for certain
northern cold-temperate organisms. Located directly in this
tr ansition area, the northern Channel Islands area possesses a
unique and extraordinarily rich species assemblage.

Two of the major factors contributing to the creation of this
biologic transition area are the area's geomorphology and current
patterns kee Figure E-3). At Point Conception the coastline
turns sharply to the east while the e dge of the outer continental
slope offshore continues in a generally south-southeasterly
direction. The California Current, which carries cold water down
from the north, sweeps along the shoreline in a meandering south-
easterly direction. When the current reaches the Point Conception
promontory, this direction of flow carries the current away from
the shoreline and thus induces a large eddy (gyre) effect in the
Southern California Bight area. The return flow, carrying waters
through the Channel Islands toward the shore in a southeast to
northwesterly direction, is called the Southern California Coun-
tercurrent. Both the California Current and the Countercurrent
are surface currents extending about 328 ft (100m) deep. The
current gyres in the Southern California Bight circulate both
nutrients and pollutants throughout the areas and,thus provide a
major force tying the conditions in the northern Channel Island

*Bryozoans include many of the small marine organisms commonly seen
encrusting submerged rocks, pilings and other solid substrates.

E-4

area to those of the broader region.

During the course of a year, surface currents in the Southern
California Bight undergo three dist inct phases:, the oceanic
period from July to November; the Davidson Current period from
November to mid-February*;' and an upwelling period from mid-
February through August during which nutrient rich deep waters are
drawn to the surface. The current patterns characterizing these
periods have been reviewed by the U.S. Bureau of Land Management
(1979) and are graphically presented in Figures E-2, E-3, and E-4.

During the spring, when day length and light intensity are in-
creasing, the high nutrient levels in surface waters foster
exceptionally high primary production (phytoplankton and other
plant growth). High primary production increases the food supply
for other marine animals and thereby supports greater numbers of
fish, shellfish, and other marine life than would otherwise be
possible. Patches of upwelling occur in a sporadic fashion during
this late winter-early summer period; the waters off Point Con-
ception are particularly prominent as an upwelling center (U.S.
Bureau of Land Management, 1979). Water current gyres throughout
the Southern California Bight as well as species movement serve to
distribute the high productivity benefits of this phenomenon
beyond the localized upwelling patches and throughout the southern
California coastal area.

*The Davidson Current is a northwesterly flowing mid-water current
which rises to the surface along the southern California coast
during this time of the year.

E-5

LEGE

-7 i
AV -,'!f
Intermediat
E
Cool Temper
l

Curren

CONTOUR

MAI
A C-F k
GAM CRUZ
r 15LAND

MLAND.@.,
M

PIP

HAMWIC MILES

FIGURE E-2. Generalized current patterns for the February to
August upwelling period (Mod fied from Resources,
1978).

................. .... ............. . ....... ...... ............
..........
..........
............... ..........
..............
................
................

..........

..... . ...
................ .....
....... ..

.............
..........................
Cu r

ANACA
'Mmlit
........................

.7777
rw@
..................
0 ...............
................
. . ........

rn )6- Aft
tj 84
I
RES
foclr.
SAN U
MICOL4S

t4
Q)

0 =10 N15MILES CALIFORWk
FIOURE E-3. Generalized Southern California Surface 'Currents for Oceanic Period (Modifie
of Land Management, 1979).

..........Z...... . . . . . . . . . .

. . ..............
. ..... TAR,' ............

............

...........

..............
...............
....... ..........
...... . .............
..... ................. ......

............ ......
Cur
................

SA JAV

:.TA ..... ......
do

...... ....
... . ................
... ...........
...............

0
..........
..............

Aft
0 &A

SAN V rA
NICOLAS

4n, AV V

'5
o 7L7,oN.M1LES

FIGURE E-4. Generalized Southern California Surface Currents for Davidson Period -(U. S.
L

Management, 1979).

Another extremely important feature of the Southern California
Bight and the northern Channel Islands area in particular is the
accentuated bottom relief and varied bottom substrate. The
northern Channel Islands, and Santa Barbara Island are actually
peaks of extensive offshore ridges. A relatively shallow island
shelf extending to a depth of about 330 ft (100m) surrounds the
islands, usually extending from 3 to 6 nmi (5.6 to 11.1km) from
the island coast. At this depth the bathymetry either plunges
steeply to a deep coastal basin,perhaps 1600.to 2500 ft,(500 to
750m) in depth (such as to the north of the northern Channel
Islands) or slopes more gradually to the peak of a submerged ridge
perhaps 600 to 1200 ft (180 to. 350m) in depth (such as to the
southeast of Santa,Rosa Island) (see Figure E-5).

The abrupt change in, Idepth provides a spectrum of marine habitats
which support a wide diversity of benthic and other marine organ-
isms, As cited in the U.S. Bureau of Land Management (1979) Final
Environmental Statement on OCS Sale #48, Jones and Fauchauld
(1976) indicate that "... the single most important environmental
variable governing the distribution of (benthic) species within
(the Southern California Bight) sampling areas was depth."
Although depth may be the most important factor contributing to
the area's diverse benthic communities, a gradation of substrate
material from soft muddy deep-water trenches to sandy island shelf
flats to rocky submerged outcrops also adds a significant dimen-
sion to the bottom species diversity. Finally, and as described
further in Section E.2, the number of species and abundance of
both bottom living and mid-water species increases dramatically as
the depth decreases from deep coastal basins to island shorelines.

E-9

30' 10-

0,
LEGE

Sh
19/0, P.'

:::2. Tgue lo Centrc I
Ox d
PlQ!q sAN-t
eep if
a4RRA,@
Jil'
CONTOUR
Chann sl
5
.an lope-@:_@'@
wd@
Rmk
Chan
k Pi..,,. r)el island 1000
SAN M CAJU Uen
MLAND ANACAPA
e-
R*mm Cam

'u-'s"m
-Gull
rn A Huepeme-Mugu
on
0

%
AU
N

N
lk

rICAL MILES

FIGURE E-5. The Santa Barbara Channel region and its physio-
graphic features (Resources, 1978). B RAJO

Two crucial pathways, which. are addressed more fully. in Section
E.2 below, are the migratory movements of species to and from the
northern Channel Islands area and biologic food chains. In both
instances, the movement of living organisms and nutrients indi-
cates the importance in the immediate sanctuary area of dynamic
marine processes and conditions in areas as far away as the'Bering
Sea.

Although the influence of geographically wide-ranging 'factors is
clearly significant, it does not diminish the exceptional impor-
tance of the localized marine habitat and resources of the Waters
surrounding the northern Channel Islands and Santa Barbara Island.
Their location (1) at the confluence of two major biogeographic
provinces; (2) in an area of upwelling and thus exceptionally high
productivity; and (3) on a submarine ridge possessi' ng a wi de
variation of open water marine habitat, makes the waters sur-
rounding these islands one of the biologically richest and most
diverse marine environments in the United States.

E.2 Natural Resources of Exceptional Value

E.2.a Marine Mammals

More than 30 species of marine mammals have been sighted in the
Southern California Bight including 27 species of whales and
dolphins (cetaceans); 6 species of seals and sea lions (pinni-
peds); and the sea otter (a member of the weasel family) (See
Table E-1). While. several species of whales and dolphins are
common and important transient inhabitants of the waters sur-
rounding the Channel Islands, the area is especially significant
for seals and sea lions which require the island shelves and

E-11

TABLE E-1 Marine mammals of the Southern California Bight
(Point Conception-Mexican Border). Daugherty,
1965; University of California, Santa Cruz, 1976;
Resources, 1978.

Common Name Genus/Species

Estimated Population
Pinnipeds 1976
California sea lion Zalophus californianus) 40,000
Steller sea lion to ia s jubatusq) 5-20
Northern fur seal (Callorhinus ursinul) 1,200
Guadalupe fur seal Etoce- s townsendi) 1-5
Northern elephant seal rAugfflnu ostris) 16,600
Harbor seal (Phoca vitulina) 1,400

Fissipeds

Sea otter (Enhydra lutris) 1-5
Cetaceans Number of individuals sighted
in 1975-76 study
Bryde's whale (Balaenoptera endeni) -
Ninke whale a aeno tera acutorostrata) 60
Blue whale BalaenoPtera muscu us 7
Sei whale Balaenoptera borealis) -
Finback whale Ta7a-enoptera 23
Humpback whale Megaptera novaeangliae) 6
Gray whale Eschricht us robustus 336
Cormon dolphin Delp 'nus 33,564
Pacific pilot whale (Globicepha a macrorhynoa 4,333
Risso's porpoise (Grampus griseus) 556
White-sided dolphin ( qenorhynchus obliuidens) 10,007
Northern right whale dolphin (qEissodelphIS borealis) 1,848
Killer whale (urcinus orca) 122
Harbor popoise 09ocena ocoena) 0.
Dall porpoise (ptiocoenoides daill) 647
False killer whale Tseudorca crass S) 0
Long-beaked dolphin Stenella coe leoalba) 0
Pacific bottlenose dolphin 557
Sperm whale (Physeter cata on) 0
Pygmy sperm whale (Kogia breviceps) 0
Baird's beaked whale Berardlus balrdil) -
Ginko-toothed whale Plesovolodon qinkodens) -
Cuvier's beaked whale i hius cav ro tris) 0
Pacific right whale (Pa0qrae-na I , 17is7 0
Pacific spotted dolphin (-te-ne16q=a gra ani 0q0
Rough-toothed dolphin (Steno bredanensis) 0
Hubb's beaked whale 0qca-rFu-bbsi) 0

TOTAL SIGHTED

E-12

shoreline habitat for haulout and feeding, purposes. San Miguel
Island, particularly the west end around Point Bennett, is the
only location in the U.S. and one of the very few places in the
world where breeding populations of 5 species of pinnipeds can be
found virtually side by side, with transient individuals of a
sixth, the *Guadalupe fur seal, also being occasionally sighted.
The isl'ands and surrounding waters are made even more important
since the southern California mainland coast does not have major
rookeries.

The pinnipeds, along with cetaceans, seabirds, and humans, repre-
sent one of the top carnivore groups in the Southern California
Bight (University of California, Santa Cruz, 1976). Appro ximately
75,0W. seals and sea lions have been estimated to live in the
Bight where they consume some 185,625 metric tons (168,750,000 kg)
of food annually (University of California, Santa Cruz, 197 6).
This makes pinnipeds a major link in 'the Bight's food. chain and
ecological balance. Although information on the role of pinnipeds
in the ecology of the Bight is limited, thei.r large food require-
ments indicate that they could provide important functions with
regard to maintaining species abundance levels through the food
chain. The unusually large population levels of pinnipeds (as
well as whales, dolphins, and seabirds) is indicative of the
region's high productivity rate which can be traced back to the
aforementioned upwelling phenomenon.

In general, the two most important pinniped concentration areas in
the Bight are on the western tip of San Miguel Island around Point
Bennett (see Figures E-6a,-d) and on the southwestern side of San
Nicolas Island (University of California, Santa Cruz, 1976). As
shown on Table E-2 however, Santa Rosa, Santa Cruz, Anacapa, and
Santa Barbara Islands also act as pinniped haulout and rookery

E-13

FIIGURE E-6a. Location of major breeding and haul Northern fur
out sites of four pinniped species (Callorhinus u
on San Miguel Island. Source:
University of Californ.ia, Santa
Cruz. Draft Final Report 1975- HARRIS POINT
1978. Marine Mammals and Seabird
Survey. Volume III Pinniped In--
RARE
vestigators Report. ... ROCK

RICHARDSON ROCK PRINCE
C5.3
N.MILES) ISLAND
CASTLE SIMONTON
OPROCK COVE .. .. ..
CUYLER
HARBOR
.......... .........
SAY COVE

.. . ... . ...... .

..............
.... ............ . .

..X
. .. . ....
%. ............... ... ....... ....... .......
..............
POINT . .... . .. ... . . ..
............
rri
X
I DENNEIT ---- - ..
X TYLER . ..... . ... .. X.
x: ..... .
BIGHT
4@b ..
JUDITH
ROCK

T .... CROOK POINT
NORTHWES
ROCKS

............
SPRINGSIDE X.
LEGEND
NW
X**
COVE
............ ...... *-Areas where at lea
X
...... an
.... ...............
imals have been
... ................
WE:T .... : ..*...,...................:...:..-. ..
..................
. ............... (the number of e'@
HE OLAND
X.
indicative of the
x
............................
WEST .3
of animals sighte(
COVE
...............
ADAMS X,
POINT
BENNETT **- ...... COVE
2
....... COVE
LANDIN
COVE 0
%* 2 KI
F
URE E

Ia CORMORANT 07LJ 1 4
ROCK

rFIGURE E-6b. Location of major breeding and California sea lio
haul out sites of four pinniped' (Zalophus californian
species on San Miguel Island.
Source: University of Cali-
fornia, Santa Cruz. Draft Final HARRIS POINT
Report 1975-1978. Marine Mam-
mals and Seabird Survey.
MARE
Volume III Pinniped Investiga- ROCK
tors; Report.
RICHARDSON -ROCK PRINCE
A 0
ISL H
N.IAILES) X
CASTLE SIMONTON
qIROCK COVE
CUYLER
00
HARBOR
X.
... . . .....
BAY COVE

...... ..
. . . ....
...................
X.,
............ .
......... ...... ............
. ...... ....
. ....... ........
................

.........
P INT 00 ..
0
BENNUT
TYLER .. .....
.................
.............. X. X
M BIGHT
-X
JUDITH
ROCK

CROOK POINT
NORTHWEST
ROCKS
X.I

.......... xx
SPRINGSIDE
LEGEND
NN
........... :: ......
.................
COVLA ...................
..............................
-Areas where at lea
........... ........................
animals have been
WEST 0
...................
...................
........ (the number of o's
HEADLAND
............................
ndicative of the
................. .......
WEST 0 of animals sighted
COVE 9 goo*
0,
ADAMS
POINT 0 """SOUT COVE
BEN
N
COVE
LA DI
COVE 0 r,
00
t?CORMORANT
ROCK

FIQURJEE-6c. Location of major breeding and Harbor seal
haul out sites of four pinniped (Phoca vitulina)
species on San Miguel Island.
Source: University of Cali-
fornia, Santa Cruz. Draft HARRIS POINT
Final-Report 1975-1978.
Marine Mammals and Seabird 0
MARE
Survey. Volume III Pinni- a ROCK
Ted Investigators Report.
............
RICHARDSON ROCK
PRINCE
. ........
(5.3 NAMLES) ISLAND
SIMONTON
CASTLE ........... ...
ROCK COVE
.. ...... . .. *"'%**'
- *201 CUYLER
...... .. .... 0 R
F 14ARD

..... ... . .. -
....... BAY COVE
......... ......
....... .

... ...........
... . ............................. ....... .....
X -

BE
...... LA
....... ..... ........

POINT
. . . . ....
..........
rn BENNETT ...
I TYLER ........... ..
0 SIGHT
.................. ............... .
.................
JUDITH
..........
.............
ROCK

NORTHWEST CROOK POINT
..........
ROCKS
... ..........

.... SPRINGSIDE
..................
................
.... .................... X
NW .. ................ LEGEND
.. ........................
COVE .................................
.................................
........ ...............
....... e-Areas where at least
.................
.... ........ .................
................. . animals have been si
WEST
HEADLAND ............ ......... (the number of 9's i
indicative of the nu
................
................
EST ....................
of animal
...........
..........
WCOVE s sighted)

POINT ADAMS
BENNETT SOUTH COVE
COVE
LANDIN
%4 COVE 0 r%mll
CORMORANT 1 4
ROCK

Location of major breeding and
.FIGURE E-6d. haul out sites of four pinni- Northern elephant-
ped species on San Miguel Is- (Mirounga Lnjustirol
land. Source: University
of California, Santa Cruz.
Draft Final Report 1975- HARRIS POINT
1978. Marine Mammals and
Seabird Survey. Volume X:':
MARE
III Pinniped Investigators ROCK
Report.
RICHARDSON ROCK
PRINCE
(5-3 XMILES)
ISLAND
..... ... .
CASTLE SIMONTON
ROCK COVE
CUYLER
....... HARBOR

BAY COV
.... ... .. .....

......... ....
............. .
..........

.. ..... ..
POINT 00 . ....
M BENNU
- ---------
T 9
814NT ....
:X
-4 ......
JUDITH
ROCK
64

NORTHWEST CROOK POINT
ROCKS

SPR(NGS(DE
LEGEND
COV
*-Areas where at le
.. ... ..........
............
WEST 0 .......
... ........ . animals have been
HEA .. (the number of e'
DL
indicative of the
WEST
of animals sightE
COVE 0
..........
POINT AD 3
BENNETT S TH C 9
COVE LANDIN
COVE
F

CORMORANT rim "I
ROCK 0

TABLE E-2. Pinniped rookery and hauil out areas of the study
area (University of California, Santa Cruz, 1976;
Resources, 1978).

Nameplace Species Present Activity
Richardson Rock (San Miguel Is.) California sea lion Breeding-pupping
Northern fur seal Breeding-pupping
Castle Rock (San Niguel Is.) California sea lion Breeding-pupping
Northern fur seal Breeding-pupping
Steller sea lion Breeding-pupping

Point Bennett Rock (San Niguel Is.) Guadalupe fur seal HauTout only

Point Bennet-.Adams Cove (San Miguel Is.) Northern fur seal Breeding-pupping
California sea lion Breeding-pupping
Northern elephant seal Breeding-pupping
Steller sea lion Breeding-pupping
Simonton Cove (San Miguel Is.) Harbor seal Brieding-pupping
r1orthern elephant seal 8reeding-pupping
Cuyler Harbor Area (San Miguel Is.) Harbor seal Breeding-pupping
Sandy Point-Blockhouse Beach Harbor seal Breeding-pupping
(Santa Rosa Is.)

Beechers Bay (Santa Rosa is.) California sea lion Breeding-pupping

Fraser Point (Santa Cruz Is.) California sea lion Breeding-pupping
Arch Rock East (Sant Cruz Is.) Harbor seal Breeding-pupping
Scorpion Anchorage (Santa Cruz Is.) Harbor seal Breeding-pupping

Kinton Point South/Morse Point Harbor seal 8reeding-pupping
(Santa Cruz Is.)

Gull Island (Santa Cruz Is.) California sea lion 8reeding-pupping*
Harbor seal Breeding-pupping

Anacapa Island California sea lion Breeding-pupping
Harbor seal Breeding-pupping

Santa Barbara Island California sea lion Breeding-pupping
Northern elephant seal Breeding-pupping
Harbor seal. Breeding-pupping

*The use of these areas as rookeries by California sea li,ons is
only speculative; however, all are definitely used as haul out
areas.

E-18

areas. Some of the more significant ecological information on
pihnipeds is summarized in Table E-3. This information indicates
th-at the island shelf waters probably provide important feeding
areas for the pinnipeds in the area. Surrounding island waters
also.provide 1) island-bred pups with their fi rst aquatic habitat
and feeding areas; 2) a source of refuge for hauled-out animals
startled by aircraft, nearshore boats, or land-based disturbance;
and 3) a buffer area against the impacts of ocean development and
use.,occurring greater distances from shore. Table E-4 shows the
seasons for different pinniped activities.

Although none of the six pinniped species are currently listed as
endangered or threatened under provisions of the Endangered
Species Act of 1973, the National Marine Fisheries Service has
expressed an intent .to consider the Guadalupe fur seal for listing
as an endangered species (Loughlin, 1979, personal communication).
Also, two species of pinnipeds, the Guadalupe fur seal and north-
ern elephant seal, are listed in the "Convention on International
Trade in Endangered Species of Wild Flora and Fauna" and in the
International Union for Conservation of Nature's (IUCN) "Red Book"
list of endangered and threatened wildlife. The Guadalupe fur
seal is shy, secretive, and rare; San Miguel Island is one of the
few areas in Southern California where it has been sighted in
recent years.

As mentioned above, whales and dolphins tend to be more transient
inhabitants of surrounding island waters. Because cetaceans
cannot haul out on island shores, they tend to be less dependent
than pinnipeds on habitats adjacent to the islands. Although
present information is inconclusive, available data has led some
marine mammal experts to think that dolphins might cluster over
submerged areas of high topographic relief such as ridges, banks,

E-19

TABLE E-3*,, Summary of ecological information for seals, sea
lions, and sea otters found in waters around San
1,1iguel, Santa Rosa, Santa Cruz, Anacapa, and Santa
Barbara Islands. (National Marine Fisheries Ser-'
vice, 1978; Woodhouse'et'al., 1977; Daugherty,
.1965; University of Ca7ifo-rnia, Santa Cruz, 1976.)

California iea lion Most abundant pinniped in Southern Cali-
(Zalophus californianus fornia Bight; range from British Columbia
into Mexico; northernmost established
rookery on San Miguel Island; breed in
June and July and disperse in Fall and
Winter; adult males migrate north after
breeding season while female and pups
move southward into Mexican waters; ma-
jor sites of activity in Southern Cali-
fornia Bight on San Miguel, San Nicolas,
Santa Barbara, and San Clemente Islands;
generally opportunistic feeders prefer-
ring squid, hake,.anchovy, other small
fish, and mollusks; feed in waters re-
latively near hauling grounds over island
shelves.
Northern elephant seal @argest and second most abundant pinniped
(ttirouncia angustirostris in Southern California- Bight; range from
Alaska to Mexico; numbers increasing;
breeding season from December through
March with breeding range from Point
Reyes to Baja California; 9 breeding
colonies including one on San Miguel
(the second largest) and one on Santa
Barbara; spend most of the year in the
water but haulout once to breed in
Winter and once to molt in Spring; feed
both near shore and in deep water on
squid, hake, sharks, skates, rays and
ratfish.

Northern fur seal Range from the Bering Sea to Mexico;
(Callorhinus ursinus) abundant in the northern part of their
range but scarce to the South; small
breeding population on San Miguel repre-
sents the southern breeding limit; San
Miguel population increasing; breeding
season begins in early Summer; pups
tended on shore through early Fall;
from Fall to Spring maintain an oceanic
existence rarely touching land; during
Winter found over the Santa Rosa Ridge
and San Nicolas Basin near Tanner Banks
and beyond the continental shelf; feed
on anchovy, saury, hake,.squid, and
other small fish; particularly sus-
ceptible to oil pollution.

E-20

TABLE E-3 Cont.

Harbor seal Eastern Pacific range from Bering Sea to
(Phoca vitulina Mexico; also in western Pacific and Atlan-
tic; breeding season from April to early
July; pups usually born on land but may
be born in water; pups nursed 4 to 6
weeks; pups have been observed on San
Miguel, Santa Rosa, Santa Cruz, Santa
Barbara, San Nicolas and Santa Catalina;
adults probably remain in Southern Cali-
fornia Bight area after breeding; greatest
Bight population density around northern
Channel Islands and in the Santa Barbara
Channel near Santa Rosa Island; feed
principally on fish, crustaceans, and
mollusks; apparently prefer relatively,
shallow warmer coastal waters; extremely
shy and secretive.
.Northern(Steller)sea lion Range from Bering Sea to California
Eumetopias jubatus Channel Islands in the eastern Pacific,
also in western Pacific; abundant in
Alaskan waters but rare in South Cali-
fornia; numbers have decreased precipi.-
tously for unknown reasons (possibly due
to temperature fluctuations) since
1930's in Channel Island area while
increasing in Alaska; breeding season
from late May to early July; feed on
clams, rockfish, squid, octopus,
flounder, and other fish and crusta-
ceans; indications that feeding may
be near land and in shallow (less than
600 ft. or 182m) water.

Guadalupe fur seal Range from northern Channel Islands to
(Arctocephalus townsendi Mexico; once abundant, hunting reduced
numbers to near extinction in early
1900's; now one of rarest pinnipeds
in Southern California; numbers appear
to be increasing; breeding season from
May to July or August; most sightings
of this species in the Southern Cali-
fornia Bight have been made on San
Miguel in May.

Sea otter Range'from Alaska to Baha California; a
(Enhydra lutris few individuals believed to be transient
males sighted off Anacapa and San Miguel;
California population (Enhydra lutris
nereis) almost decimateTVy_Wu_n_tfn_g7n
iTt-F-and 19th centuries but populations
now expanding from central California;
not migratory although long distance
wandering by young males reported;
in California it is believed (not
well documented) pups are born in
water-, rarely haul out of water;
feed primarily on benthic mollusks,
crabs and sea urchins but occasionally
take fish; diving for food limited to
about 120 ft. (36m) thus habitat is
primarily limited to areas within
120 ft. (36m) depths; prefer rocky
bottom and kelp habitat but also
found in sandy bottom areas.

E-21

Table E-4: Approximate times of1ptinniped activity in the study area.
(U. S. Geological Survey, 1976j

Species On Land Pupping Breeding Nursing
Northern fur seal May to about Late May to Late May to Late flay to
15 November mid-August late August about 15
November
Northern sea lion May throggh June June June to
November November.
A few may
nurse all
rn year
I
A.)
California sea lion All year June June to June to
July November.
A few all year
Northern elephant All year @Iate December January to Late-December
seal except when io-late. - mid-March to mid-flarch
feeding February

Harbor seal All year March April March to
April May flay
Guadalupe fur.seal A few all
year

aA few ma y be on land at any time,

plateaus, or island/mainland shelves (Evans, 1975). At least one
team of marine scientists has, suggested the hypothesis that the
biota of the. entire Southern California Bight ecosystem, (including.
pinnipeds, cetaceans, seabirds, benthic organisms and others)
might tend to concentrate over such high relief areas rather than
the relatively flat and' deeper plains and basin areas (University
of California,.Santa Cruz, 1976).

At least 27 species of cetaceans have been seen in the waters of
the study area. These waters may function as the home range of
the common- dolphin, Pacific white-sided dolphin, and the Pacific
bottlenose dolphin. Pilot whales also use the area as a feeding
ground; large concentrations of pilot whales have been sighted
feeding on squid (Patterson, 1979, personal communication,). The
Pacific right whale, one of the rarest of the great whales, has
occasionally been viewed in the Channel . Islands area. The study
site may be of considerable importance to the right whale both as
habitat and foraging area but further research appears necessary
to substantiate this assertion (Patterson, 1979, personal commu-
nication).

The entire eastern Pacific stock of gray whales migrates along the
North American coast and passes through the area twice each winter
(Nickerson, 1977; RESOURCES, 1978). Estimated populations range
as high as 10,000 to 12,000 (Patterson, 1979, personal communi-
cation). Furthermore, observations of gray whales with calves
close to the islands. indicate that the study site is one of the
prime focuses of returning calf migrations. Scientists have also
observed cows and calves "hanging out" in the kelp beds (Patter-
son, 1979, personal communication). One possible explanation for
this behavior may be that nearshore kelp beds offer protection
from strong seas and provide a resting spot for calves (Leather-

E-23

wood, 1979, personal communication).

The area is also important for several endangered species, includ-
ing the blue, fin, and humpback whale. Both blue and fin whales
have been observed over long periods of time in waters just
seaward of the study area (Patterson, 1979, personal communi-
cation). Local, fishermen have reported sighting "stationary" blue
whales during the early summer, which suggests that whales feed
nearby (Patterson, 1979, personal communication).

Table E-5 lists 10 of the more common cetaceans observed in the
study area, details information. on historical sightings, and,
.provides brief ecological notes.

In general, the large size, high mobili ty, and wide pelagic range
of these whales have discouraged compilation of more complete
ecological species accounts. It is clear, however, that toothed
whales and dolphins, like most pinnipeds, represent a major link
in the overall food chain within the study area and, due to their
apparent attraction to high relief areas, frequent island shelves.
Furthermore, it is probable that cetaceans play a significant role
in influencing relative species abundance levels of other marine
biota.

Another marine mammal in the waters around the northern Channel
Islands is the sea otter. Currently, this species is known to the
area only by occasional sightings of a few - individuals (probably
transient males) off the islands of San Miguel and Anacapa (Re-
sources, 1978). As noted in Table E-3, the sea otter rarely hauls
out, is limited to shallow (less then about 120 ft (37m)) coastal
waters, and is a voracious feeder on mollusks and shellfish.

E-24

TABLE E-5. Historical species accomts and ecological infonmtion for oetaceans sighted
over or adjacent to island shelvesoff San Miguel, Santa Rosa, Santa Cruz,
Anacapa, and Santa Barbara. (Daugherty, 1965; National Marine Fisheries Ser-
vice, 1978.)

Species Historical Sightings Historical Sightings Ecological Notes
around the Northern thrcugt-t the Southern
Channel Islands and California Bight and
Santa Barbara Island Beyond
Gray whale 14 sightings between East Pacific population Species summers in the northern waters and
(Fsochrichtius robustus) Jan. - Mar.; all around ranges frorR neaufo migrates south along the coast to Baja California
the northern Channel Sea to Baja Mexico; and the Gulf of California in Winter; feeds an
Islands; none sighted abundant in Channel benthic amphipods and invertebrates during sarmer,
during re t of the year. islands between Jan. fasts during Winter; calves born in Winter; listed
and mar.; scattered as "endangered"; numbers are increasing.
sightings remainder
M of the year.-
A)
Ln
Fin whale I sighting south of Worldwide in distri- Second largest whale; feeds on plankton (especially.
(BalenoPtera Physalus) Santa Fosa in the bution; found south euphausiids) and occasionally fish; rating and
Oct. - Dec. period. to California in calving season in Winter; calf weaned at about
Summer; more southerly 7 months; listed as "er4angered".
inWinter; scattered
sightings in Bight.
year round

lkwvback whale I sighting off Worldwide range except Noted for sound producing capabilitiesi migrates
(Mogaptera western Anacapa for polar pack ice extensively from high latitudes in Summer to
eangliae) Island between jan.- zones; between 1949 and continental and island coasts in low latitudes
mar. 1973, 20 recorded in Winter; a baleen whale; feeds on krill and
sightings in Bight. also anchovies and sardines wMen availablel
calving season from Oct. to mar.; listed as
-,ndangered-.

Killer Whale 5 sightings off Worldwide range; 29 Most comman in highly productive coastal watersI.-
(Orcinuss orca) northern Channel sightings in Bight known to lie off seal and sea lion rookeries
Islands; all sightings throughout tile year during pupping season to feed on artbials entering
between Jan. Sept. but mostly in cooler or leaving the water; usually found in groups of
months. 10 to 100; also feed on squid, dolphins, flatfish,
octopus and whales.

TABLE E-5 Cmt.

species Historical Sightings Historical Sightings Foological Notes
around the Northern throughout the Southern'
Channel Islands and California Bight and
SaLnta Barbara Island Beyond

Pilot whale (short 2 sightings off western Range t1irough North Travel in schools; feed on squid and schooling
finned) (Globicephala Santa Cruz island Pacific and North fish; appear to calve year round; prefers off-
macrorhynchiisY between Oct. and Dec. Atlantic; fairly shore waters but moves closer to land in search
abundant around Cali- of food.
fornia Channel Islands
year round but most
common in Winter.

Pacific white-sided 10 sightings over all Range north Pacific Occurs in schools of usually less than 100 animals;
dolphin (IA seasons cud off all South to Baja Califor- prefers continental shelf and slope areas; breeds
obliquidens;F92KN@ Islands. nia; sighted frequent- in Spring and Autumn; feeds on squid, octopus and
ly throughout the yea small schooling fish; concentrates in numbers in
in the Bight. San Miguel area in Summer months.

Dall's porpoise 15 sightings throughout Range east and west Usually found in groups of 2 to 20; feed on squid
(Plxxxk-noides dallii) the year and off all north Pacific; frequent and Small schooling fish at both mi&water and
islands; most common sightings throughout deep-,,@ater depths.
between Jan. - Mar. the year; most abun-
dant in Fall and Winter.

Ommon dolphin 9 sightings throughout Range worldwide in Congregate in schools of a few to several thousand;
(Delphinus delphis the year and off all temperate and tropical feed on anchovy, squid, hake, mackerel, sardine,
islands. waters; probably most sea bass, and lantern fish; rarely found in waters
cam= oetacean in Bight. less than 182m (600 ft.) but frequents deeper
ridges and Sea mounts; 2 mating seasons Jan.-April
and Aug.-Npv. and 2 calving seasons Mar.-My and
Aug. - Sept.

Northern right whale I sighting off south- Range temperate north Travels in schools of 100 to over 1,000; found
dolphin (Lissocielphis east Santa Rosa between Pacific; scattered in open ocean but observed most commonly along
borealis) Oct.-Dec.; I sighting sightings throughout continental slope, near ridges and submerged
south off Santa Cruz Bight,- mostly between plateaus, and close to islands and mainland; feed
between July-Sept. Oct.-Mr. on squid, lantern fish, and miscellaneous fish.

Hai rds Nkiked whale 6 animals observed in Range north Pacific Usually travel in tight schools of up to 30
(Berardius bairdii) 1970 south of Santa from Alaska to Southem .,animals; feed on deepwater fish and squid;
Cruz Island. California, only I migrations poorly known, rare as far south as
other sighting in Southern California.
Bight area over Tanner
Banks.

Because of its consumption of sea urchins, abalone, and other
shellfish, the sea otter is an important factor in determining the
abundance of other marine species and possibly even the type of
habitat (Woodhouse et al., 1977; Yellin, 1977). At least some
scientists have suggested that' the otter's consumption of sea
urchins, which graze on the attachment points of kelp, may in-
directly lead to an expansion of kelp beds (Yellin, 1977). (Kelp
beds, @as discussed in Section E.2.c., provide a special habitat
for many organisms in much the same manner as coral reefs.)

Rangin'g throughout the Southern California Bight and beyond, the
marine mam mals in the waters around.the islands affect the food
chain and natural ecosystem stabil* ity in a broad region. Mainland-
based coastal pollution and intensive littoral development have
(both directly and indirectly) reduced and in some cases elimi-
nated mainland haulout areas for- seals and sea lions here.
Therefore, the remaining populations on shorelines and in adjacent
waters provide an important indicator of broad environmental
health and conditions as well as an extremely valuable vestige of
marine wilderness and species distribution. Seals, sea lions, and
possibly whales and porpoise also provide an invaluable research
and public educational potential. -

Finally, marine mammals, particularly the migratory gray 'whale
(see Figure E-7), support recreational benefits of considerable
economic importance. As these whales travel along the shore,
charter boats carry paying customers in increasing numbers out for
closer observation. In some cases, whale watchers even charter
planes.

E-27

.......................... ..........
.................
.......... .... .............
... ..............
............... .......................... X
. ................. .......
LEGE

........................... . ..... ......
................
...............

...... .........
. ..............
..
Ar ..........
.......... . ........... .

... ......
N AW4VF1 . ...............
4C n.-
.4 CA
do

V,4m . ..........

5VD

rn
I
r') 49A
ca see
SAN M
NICOLAS

NrE
be

NO
7LMN" MILES

FIGURE E-7. Migration routes of the gray whale (Modified from Resources, 1978).

E.2.b. Marine Birds

The northern Channel Islands and Santa Barbara Island are a focal
point for one of the richest. resource areas for marine birds. in
the United States. This richness is based on both numbers and
species. diversity. Seabird concentrations occur not only.on the
fslands and offshore rocks themselves (which provide nesting
iabitat for nine of southern California's 12 species of breeding
seabirds) but also on the productive waters around the islands
)ver which many species forage for food. A recent study of
Southern California Bight marine avifauna (University of Cali-
fornia, Santa Cruz, 1976) collected baseline data on 64 species of
seabirds including nesting species, year-round visitors, summer
visitors, winter visitors, transients, and strays (see Table E-6).
Because of their highly mobile and migratory habits, probably all
of these seabird species appear at least occasionally around the
.northern Channel Islands and Santa Barbara Island.

The brown pelican is the only breeding seabird species found on
the Channel Islands which is listed as endangered due to low
population levels. Among the other endangered terrestrial species
currently or formerly found on the Islands are Beldings's savannah
sparrow, the peregrine falcon, and the southern bald eagle.

Of greatest significance to the proposed sanctuary are the large
number of marine bird species which use the relatively shallow
marine waters around these islands (see Table E-7). For example,
seabirds nesting on the northern Channel Islands tend to forage
near their rookeries and close to island shores. Limited tracking
and observation data, described more fully below, indicate that

E-29

TABLE E-6. The marine,avi.fauna of the Southern California Bight
(developed from University of California, Santa Cruz,
1976).

1. Nesting Species

Ashy storm-petrel (an Channel Islands) Pigeon g.uillemat (an Channel Islands)
Brown pelican (on Channel Islands) Xantus' murrelet (on Channel Islands)
Double-crested cormorant (on Channel Islands) Cassin's auklet (on Channel Islands)
Brandt's cormorant (on Channel Islands) Least terns Con'mainland only)
Pelagic cormorant (on Channel Islands) Caspian terns (an mainland only)
Western gull (on Channel Islands) Elegant terns (an mainland only)
2. Year-round Visitors .(do not breed on the Islands but can be expected any time of the
year)
California gull. Forster's tern Royal tern
Ring-billed gull Black storm-petrel Black-footed albatross

3. Summer Visitors

Least storm-petrel Craveri's murrelet Pink-footed shearwater
Red-billed tropicbird, Leach's storm petrel Sooty shearwater

4. Winter Visitors

Heermann's gull Short-tailed shearwater Glaucous-winged gull
Northern fulmar Manx shearwater Herring-gull
Common loon Fork-tailed storm petrel, Common murre
Arctic loon White-winged scoter Thayer's gull
Red-throated loon Surf scoter Mew gull
Horned grebe Red-breasted merganser Bonaparte's gull
Eared grebe Red phalarope Black-legged kittiwake
Western grebe Pomarine jaegar Rhinoceros auklet

S. Transients (pass through Southern California waters while migrating)
New Zealand shearwater Skuas
Brant Sabine's gull
Parasitic Jaeger Common tern
Long-tailed Jaeger Horned puffins
6. Strays (occur in small numbers but not considered part of Bight's avifauna)

.Red-necked grebe Laysan albatross
Ancient murrelet Cape petrel

E-30

TABIlE E-7. Marine. birds of the Southem California Bight sighted or reported near
northern Channel Islands and Santa Barbara Island (adapted fran Univer
of Californial Santa Cruz, 1976).

Species

Common loon Present Oct. - May; remain inshore near to island and mainland coasts; migrate north
(Gavia iminer) during Simner.

Arctic loon Present Oct. - June; sane nay remain during Summer; in Nov. 1975 they were observed throt
(Gavia arctica) out the Bight but in Jan. they had concentrated in protected inshore waters around northi
Channel Islands; mst abundant loon in Bight.

Red-throated loon Present Oct. - April; numerically dominant loon inshore along mainland coast but with sa
(Gavia stellata) nearshore island records; virtually absent offshore.

Horned grebe Present Nov. -'April; usually along mainland coast also present in small nunters around
(Podiceps auritus) northern Channel islands.

Eared grebe Present Sept. - June; move to inland nesting sites in latellinter; concentrate around
(Podiceps nigrioollis Channel Islands in mid-Meab.; out number other Grebes in Channel areea and constitute a si
ficant portion of nearshore avifauna.

Northern fulmar Present Nov. - June; appear to concentrate over Santa Barbara Channel, northern islands
(Fulniarus glacialis northern Patton Escarpient, Tanner, Cortes and Fortymile Banks6 and Coronado Escarpment.

Pink-footed shearwater Present year round but most abundant June to Sept.; second most abundant Shearwateri mosi
(Puffinus creatopus frequent around northern Channel Islands, along Santa Rosa-Cortes Ridge, in Santa Barbqar,
Channel, in San Nicolas Basin and east of longitude 1180 along U.S. -Maxican border.

New Zealand shearwater Ttansient species seen rarely Sept. - Nov-, sightings seen in 1975-76 survey, 4 to 7
(Puffinus bulleri) individuals were seen in Sept. near San Miguel Island; also seen in May.

Sooty shearwater Most abundant Bight shearwater; summer visitor, greatest concentrations around northern
(Puffinus griseus Islands, and over northern Santa Rosa-Cortes Ridge; may concentrate north and west of qSw
Rosa and San Miguel Islands in Sept. before beginning southward migration; Summer and Spi
feeling appears to be just west of San Miguel Island; remin closer to shore during upwe
season.

Fork-tailed storm petrel identified as a Winter visitor but sighted only an four occasions during 1975-76 survey;
(oeartodroma furcata) siting was directly over Osborn Bank near Santa Barbara Island in Nov.

I,each Is a toxin petrel Sumer visitor with peak mmibers in July; generally more than 16 rqm (30km) offshore over
(0ceanodroma leuoc)rhc)a) shallower bauks; also most numerous storm petrels in San Miguel Island and Cortez Bank
area ; prefer upmalling areas.

TAME E-7 Cmt.

Glaucous-winged gull. Present Oct. - May, appears to concentrate over San Miguel and Santa Rosa Island but also
Uaru glaucescens Nioolas, Santa Cruz, and Santa Barbara, occasionally wander offshore;.scavenge around pin
hauling c
grounds.

Western gull Present throughout year; in Spring and early mmar greatest numbers around breeding oolcm
UArus occidentalis) an San Miguel, Anacapa, San 0Woolas and Santa Barbara Islands and 5A to 16,2 rmi (10 to
offshore of these areas; move to southeast in late Sumer and early Winter.

lkxring gUll Present Nov. - April; mostly from Jan. - mar.; scattered along mainland and northern Chan
(I.Lrus argentatus islands in Jan. but mare on islands in March.

California gull Year round; numbers peak an mainland and offshore at Santa Rosa and Santa Catalina Island
(lams californicus) in January.

Mew gull Present Nov. - April, found along mainland beaches, at sea, and near the shares of the
(Larus canus) northern Channel Islands in Jan.

ileermann's WI Present June - Mar.; found infrequently in offshore waters, rather often on beaches of th
(Larus heermanni) Channel Islands, and commonly an mainland beaches.

Black-legged kittiwake Present Nov. - May; local concentrations northwest of San Migilel Island and southeast of
(Rissa tridactyla Anacapa in Dec.;nconlon on beaches but abundant offshore in Jan.

Common tern Near mainland coasts between April June, and Aug. Nov., am sighting reported near San
(Sterna hirundo) Cruz Island.

Royal tern Present Aug. - Feb.; more numerous among Channel Islands than mainland beaches; two major
('Phalasseus naximus) centration Areas in Bight, one of which is around nortlyarn Channel Islands.

Pigeon guillemot Oculnon during Spring and Sumer near nesting sites an San Miguel, Santa Rosa,.Santa Cruz,
(Cepphus columba capa, and Santa Barbara Islands; rarely mare than 2.2 nmi (4km) from share, present from
July.
Xantus' olurrelet Present in moderate to high densities near i-.n_g coolonies an Santa Barbara during Sqpqr
(riq4omychura hypoleuca common northwest of Santa Barbara island in Jan. - Feb.
Cassin's adlet Present throughout Bight; 1-1inter concentrations near San Miguel island, Anacapa Passage,
(Ptychorwrphus aleuticus) Santa Posa-Cortes Ridge, and near San Diego; Summer concnetrations near large breeding cqo
on San Miguel island.

I larned puffin Present May 7 June; possibly increasing numbers; seen during 1975 survey in small numbes
(Fratercula corniculata) of Santa Barbara Island.

TUfted Puffin Sighted rarely but most frequent in the vicinity of Santa Cruz Basin and offshore of San
0Mwlda cirrhata) Miguel Island during January.

TABLE E-7 Ccnt.'

Ashy storm petrel Appear to prefer offshore ridge areas; most common in northern Bight area, nests in northern
(Cceanodroma hcnmhroa) Channel Islands.

Brown pelican Year round with peak abundance Sept. - Dec. due to influx of individuals from Mexico; nest
(Pelecanus occidentalis) on Anacapa Island; areas of greatest concentration northern and central Channel Islands.
Double crested cormorant Almost exclusively on the' immediate Channel Island coastlines, particularly near known nesting
(Phalcrooorax auritus) colonies at San Miguel (Prince Island), Santa Barbara, and Anacapa Islands; greatest numbers
in Sept. and Winter months.

Brandt's cormorant Most abundant onshore and in nearshore waters; nesting colonies among the four northern Channe
(Phalacrocorax penicillatus Islands-particularly San Miguel island; occasionally seen offshore but return to islands
each day.

I Pelagic cormorant probably year round, aLu:)st totally restricted to the waters immediately around the northern

(Phalacrocorax pelagicus Channel Islands and Santa Barbara Island; rarely occurring offshorej breeding population on
Channel Islands.

Brant Transient between Oct. - Nov. and Mar. - April; present in large numbers in April during
(Branta bernicla) northward migration.

White-winged scoter Present Sept. - April; distributed throughout Bight with peak concentrations around northern
(Melanitta deglandi Channel Islands in Jan. - Feb.

Surf scoter Present Oct. - June; present in inshore waters of mainland coast and northern Channel Islam
(Melanitta perspicillata gradually decrease numbers from April - June; widely reported offshore (more than 2.7 nmi or
around certain islands in Nov.; concentrate near Santa Rosa island in March.
RiA-breasteduerganser Present Sept. - May; in fall concentrate along.mainland coast and coast of @anta Cruz Island;
(Mergus serrator) by Feb. cluster inshore arc" northern Channel Islands and P.M.T.C.; somewhat reduced con-
centrations in March.

Red J)halarope Present Aug. - May; scattered through inshore and offshore waters with moderate densities over
(Phalaropus fulicarius) and beyond Santa Rosa-cortes Ridge in Nov. - Dec.

Northern phalarope Present at scattered locations an" northern Channel Islands and San Pedro Channel in April -
(Lobipes lobatus) May; most numerous in waters inshore of the Santa Rosa-Cortes Ridge.

Paimakine jaegar Present Aug. - May; scattered in offshore waters between the Channel islands and the mainland;
(Steroorarius panarinus highest densities between Sept. Nov.; most conuon far out to sea over offshore banks and
ridges.

during the breeding season some species prefer to forage over the
island shelves which may vary from 3 to 6 nmi (4.8, to 9.6km). in
wi dth. The birds found in island breeding colonies may, there-
fore, be among those most dependent''on the waters around the
northern Channel Islands and Santa Barbara Island. If nesting
birds must use more distant feeding areas, the energy (food)
expended in travel to and from these more remote waters could
decrease the amount of regurgitated food available for chicks and
potentially reduce the number of successfully reared young.

The islands surrounded by the waters under consideration provide
rookery areas for 9 of the 12 species of nesting marine birds in
the Bight (see Table E-8 and Figures E-8, 9, 10, 11, and 12); the
remaining 3 species breed only on the mainland. The approximately
15,100 to 19,800 nesting pairs of seabirds on the northern Channel
Islands and Santa Barbara Island include the Bight's most impor-
tant rookeries. Table E-9 shows that in numbers.the San Miguel-
Prince Island comp lex is the most important rookery in the Bight
while Santa Barbara Island has the greatest number of breeding
species; the area is also the largest marine bird rookery in
southern California (U.S. Bureau of Land Management, 1979).
Anacapa Island supports the second largest number of seabirds
including a rookery for the endangered brown pelican. Colonies
found on Santa Barbara Island are the third largest in the Bight
and support the only U.S. rookeries for the Xantus' murrelets.

Although most of the 9 species found nesting on these islands are
known to have once bred on the mainland, intensive development
along most mainland coasts now restricts breeding habitat to
offshore islands (California Department of Fish and Game, 1979).
Reduction of habitat, along with other factors, has reduced
present populations of pelican, cormorant, and auklet to only a

E-34

Table E-8, Known marine,bird colonies located on the northern Channel
Islands and Santa Barbara Island. (Modified from: Univer-
sity of California, Santa Cruz, 1976; Resources, 1978; -Uni..;
versity of California, Irvine, 1930).

ESTIMATED
POPULATION
LOCATION BREEDING SPECIES 1975-1977

Castle Rock Pigeon guillemot 200
(San Miguel Is.) Brandt's cormorant 432
Cassin's auklet NC*
Pelagic cormorant 30
Xantus' murrelet 50

San Miguel Island Pigeon guillemot 400
Pelagic cormorant 62
Brandt's cormorant 84

Prince Island Western gull 1,160
(San Miguel Is.) Cassin's auklet 20,000
Brandtis cormorant 1,720
Pigeon guillemot 300
Double crested cormorant 40-80
Ashy storm petrel NC*
Pelagic cormorant 100

Santa Rosa Island Pigeon guillemot 250
Pelagic cormorant 10
Brandt's cormorant 400

Gull Island Cassin's auklet 138
(Santa Cruz Is.) Western gull 62
Brandt's cormorant 46
Pelagic cormorant 34

Scorpion Rock Western gull 200
(Santa Cruz Is.) Brown pelican 160

Anacapa Island Western gull 5,000
Brown pelican 152-834
Pigeon guillemot .8
Pelagic cormorant 2
Brandt's cormorant 2
Xantus' murrel et 2

Santa Barbara Island Double crested cormorant 24
(including Sutil Brandt's cormorant 240
Rock) Pelagic, cormorant 2
Western gull 1,600-2,400
Xantus' murrelet 2,000
Pigeon'guillemot 120
:*NC=No Count Available Brown Pelican 80-120

E-35

LEGEND
RICHARDSON ROCK Pigeon Guillemot HARRIS PT 00
%0 Pelagic Cormorant IFTY COVE
PT. BENNETT Brant's Cormorant HARE.COVE
9.6 km. % HARE ROCK
BAT COVE
CASTLE ROCK km P
SIMONTON COVE
CUYLER HARBOR
rn

SAN MIGUEL ISLAND

831'

PT. BENNETT- TYLER
BIGHT
JAITH ROCK

CROOK PT.

@FIGURE E-8. Distribution of nesting colonies on San Miguel Island (University of Calii

LEGEND
Western Gull -Brown Pel i can
Cassin's Auklet Pelagic Cormorant
WEST PT.
FRASER PT, Pigeon Guillemot Brant's Cormorant

BLACK PT. DIABLO PT. km

92436 CAVERN

COCHA PT.

@S
SMITA CRUZ ISLAND

GUE-L'-ISLAND
SANDSTONE PT.
BOWEN PT.

GULL IS.

JIGURE E-9. Distribution of nesting colonies at Santa Cruz Island. Distributions of Br
crested cormorants incompletely known. (University of California, Santa Cr

LEGEND
12 Brant's Cormorant
13 Pelagic Cormorant
Pigeon Guillemot

CARRINGTON PT.
BROCKW PT.

SANDY POINT SANTA ROSA ISLAND BEECHERS BAY
SKU NK PT.

01574 EAST PT.
CLUSTER PT.
FORD PT.

1
JA SOUTH PT.
km

FIGURE E-10. Distribution of hesting colonies on Santa Rosa Island. Dis-
tributions of Brandtis cormorant and pigeon guillemot incom-
pletely known. (University of California, Santa Cruz, 1976).

E-38

LEGEND
r_773 Uestern Gull

Brant"s Cormorant
WEST ANACAPA
DQ.uble-crested Cormorant

Brown Pelican EAST... .
930 ANACAPA
MIDDLE ANACAPA

WEST ANACAPA

EAST
930 ANACAP
MIDDLE ANACAPA
0

FIGURE E-11. Distribution of nesting colonies on Anacapa Island (Distribution of Brand
incompletely known). (University of California, Santa Cruz.,'- 1976.)

LEGEND
Western Gull

Xantus Murrelet
Pigeon Guillemot
Double-crested Cormorant
ED Brant's cormorant
Pelagic Cormorant

ARCH ROCK
5 SHAG ROCK AA
6 10 10
km

WEBSTER PT.

AN LANDING COVE

SANTA BARBARA -M

ISLAND qA

635

S.E. ROOKERY

UTIL IS. CAT CANYON

FIGURE E-12. Distribution of nesting colonies of seabirds on Santa Bar-
bara Island (University of California, Santa Cruz, 1976).

E-40

TAKE E-9. Numbers of seabird pairs nesting cn the California Channel
I
Islands in 1975 (University of California, Santa Cruz,
1976).

island species

ASP BP DC BC PC %1G PG 10 CA

1. San Miguel ? 42 31 + 140 ? ?

Castle Rk. 216 is + 40 ? +

Prince Is. + - 20-40 860 1 600 200 + 10,000

Richardson Rk. ? - - - -

2. Santa Rosa Is. ? - - 200 + + + ? ?

3. Santa Cruz Is. ? - - ? ? ? + ? ?

Gull Is. ? - - 23 4 31 ? 30

Scorpion Rk. 80 - ? - so .1 ? '?

4. rAbst Anacapa Is. ? 212 + 1 + ? ?

middle Anacapa Is. ? - - - - 1000 - ?

East Anacapa Is.. ? - - - - 3000 - ? ?

5. Santa Barbara Is. ? - 2 27 1 1162 60 ca.1060 ?

Suti-I Is. ? - 8 93 - ? 20 ?

Shag Rk. ? - - - - ? ? ? ?

6. Santa Catalina Is. 7 - - - - ? - ? ?

Bird Rk. ? - - - - 25-30 - ?

Ship Rk. ? - - - - - - ?

7. San Nicolas Is. ? - 365 - 720 - ?

S. San Clemente Is. ? - 12 - ? ? ?

Castle Rk. ? ? - ? ?
Bird Rk. (N4 Harbor) 31 -

Symbols: not present; ? possibly present, but not found; + preserrE, but no estimate
of numbers obtained.

ASP = Ashy starry petrel Pr. = Pigeon guillemrt
BP - Brown pelican 101 = Xantus' ru=elet
DC = Double-crested cormorant CA = Cassin's auklet
BC = Brandt's cormorant PC = Pelagic connorant
M = Wastern gull

E-41

fraction of their former numbers. Two other marine species which
nested in the Channel Islands 75 years ago (the tufted puffin and
common murrelet) no longer nest there. As noted above, the brown
pelican is listed as endangered on the U.S. Fish and Wildlife
Service's Endangered Species List. In addition to seabirds, two
land-oriented species also designated as endangered (the bald
eagle and. the peregrine falcon) once nested on the northern
Channel Islands but have not been observed in the area for several
years. These two species, although known to feed along beaches
and over waters very close to the coast, are not true seabirds.

Although distribution and movement vary between species and time
of - year, seabirds' like marine mammals, tend to concentrate over
areas of high bottom relief including ridges, island shelves, and
plateaus, During summer, for example, the brown pelican, western
gulls, and Cassin's auklets in the Bight are foun d in greatest
numbers northwest of San Miguel Island, in the eastern end of
Santa Barbara Channel, close inshore around all eight islands, and
in waters overlying the northern Santa Rosa-Cortes Ridge and Santa
Cruz Basin (University of California, Santa Cruz, 1976).

As mentioned above, nesting birds have been observed to forage in
waters close to their rookeries, usually within several miles of
shore. For example, the three species of cormorants, pelican,
Xantus' murrelet, and pigeon guillemot were predominantly within 6
nmi (10km) of their colonies while Cassin's auklets concentrated
between 6 to 15 nmi (10 to 25km) offshore. (University of Cali-
fornia, Santa Cruz, 1976). Radio telemetry studies on the move-
ment s of radio-banded Xantus' murrelets and western gulls at Santa
Barbara Island and transects for Cassin's auklet at San Miguel
Is land and Xantus' murrelet at Santa Barbara Island also demon-
strate patterns of movement close to island shores. The relative

E-42

importance of the waters near the northern Channel Islands 'and
Santa Barbara Island for all species of marine birds is indicated
by the large number of individuals sighted there as compared to
the other more southern Channel Islands (see Table E-10).

Seabirds also tend to feed in the kelp bed canopy. Kel p, as
discussed below in Section E.2.c, grows principally on rocky
bottom areas shallower than 100 ft (30m). The kelp canopy pro-
vides a resting and foraging ground to. many seabirds (California
Department of Fish and Game, 1979). For instance, the great blue
heron uses the surface kelp as a platform from which it hunts.
The pigeon guillemot swims within the forests for its prey. The
brown pelican plunges after fish in clear water between the canopy
growth. Cormorants also feed about the kelp. Gulls of many
species and sea ducks use the kelp canopy and clear water between
as resting areas. Some examples are:

Larus occidentalis Western gull
Larus californicus California gull
Larus philadephis Bonaparte's gull
Melanitta deglandi White-wing scoter
Melanitta perspicillata Surf scoter
AythzA affines Lesser scaup

Marine birds as a predatory group are one of the most important
food chain consumers in the' Bight along with pinnipeds, cetaceans,
and man. Although their principal food sources are poorly known
and vary by species, squid and small schooling fish such as
anchovies, sardines, and saury probably predominate. Estimates of
annual consumption are not available, but as a major predator at
the top of the. food chain, their importance in maintaining a
bal ance in the Bight's species diversity and abundance is un-

E-43

Table E-10 Sightings of all species cmbined'(total individuals)
cn and near Channel Islands and, beacbes, April 1975
through March 1976. Dash.indicates area not surveyed
or survey inomTplete (University of California, Santa
Cruz, 1976).

Location Apr--Jun 75. Jul-Sep 75 Oct-Dec 75 Jan-Mar 75
SAN ffG-UEL ISLAND
Richardson Rock 102 233 179 93
West 1427 .1313 1365 810
South 304 194 372 216
East 1846 894 1616 755
North 130 272 245 .281

SANIA ROSA ISLAND
West 289 188 1563 633
South 80 116 613 2756
East 437 -653 626 1136
North 691 822 734 546

SANTA CRUZ ISLAND
West 163 247 749 186
South 230 442 783 1454
East 375 .356 928 173
North 582 448 .632 502

ANACAPA. ISLAND 1865 -- -- 7482

SAN NICOT-AS ISLAND
Northwest 140 587 1756 1513
Southwest 69 25 78 95
Southeast 37 0 1608 944
Northeast 127 477 302 416

SANTA BARBARA ISLAND 1187 .597 2141 813

SANTA CATALINA, ISLAND
Northwest 11 63 .103 852
Southwest 84 40 120 1171
South 48 13 .24 94
East 43 54 34 1620
Isthmus, 56 65 41 1096

SAN CLEMENTE ISLAM
Northwest 303 571 790 2141
West Central 66 130 611 579
Southwest 18 42 161 107
Pyramid Cove 10 29 40 0
East 30 0 0 16

E-44

doub'tedly significant.

The shallow island shelf waters surrounding the northern Channel
.Islands and Santa Barbara Island provide significant feeding areas
for the largest concentrations of seabirds in the Southern Cali-
fornia Bight. From an ecologic point of view, this concentration
of top predators represents a significant. factor determining the
Bight's trophic (food) pathways. The breeding colonies of seabirds
on the islands represent remnants of former ranges that once
included mainland areas. Now, however, most mainland breeding
colonies south of Point Conception have been destroyed (California
Department of Fish and Game, 1979).

The marine feeding areas in waters surrounding these rematning
rookeries provide significant food sources to support these
breeding colonies. The large concentrations of marine birds also
afford exceptional research opportunities, particularly for the
study of ecologic pathways related to the birds, as well as an
important resource for ornithologists and nature lovers.

E.2.c. Fish and Plant Resources

Marine fish resources, finfish, invertebrates, and plants, are
discussed below under two groupings: nearshore species (found in
waters shallower than 180 ft (55m) and offshore species (found in
water of greater depths). The outer margin of the nearshore zone
approximates the depth at which the island shelf plunges down a
steeper slope to the deeper offshore basins, plateaus, and sub-
merged ridges. In most cases, the division between the two zones
is 3 to 6 nmi (4.8 to 9.7km) from shore.

E-45

California's nearshore fish assemblage (i.e., fish favoring the
island and mainland shelves) has been found by Horn (1974) to
include some 213 species, or about 44 percent of all species
reported by Miller and Lea,(1972) to occur in all southern Cali-
fornia waters' (U.S. Bureau of Land Manage ment, 1979). Thi s
diversity (Figure E-13) is at least partly due to the convergence
!near the northern Channel Islands of two major biogeographic
regions. A detailed list of.all fish in the island shelf area of
the northern Channel Islands and Santa Barbara Island has not been
,compiled.

The California Department of Fish and Game (1979) has identified
fish species of recreational and commercial interest that occur
off each of the northern Channel Islands and Santa Barbara Island
(see Appendix 2). Among the more notable finfish are the rock-
fishes and surfperches. Among the invertebrate and plant species
are the abalones (red, black, white, pink), rock scallops, Cali-
fornia sea mussels, piddocks, sea urchins, lobster, bay mussels
and kelp. The most frequently occurring shellfish on the island
shelves are the bivalves Parvilucina tenuisculpta and Tellina
carpenteri' (U.S. Bureau of Land Management, 1979). Two of the
most prominent nearshore marine habitats are the kelp bed/rocky
bottom areas and the sand flat areas. Of these, kelp beds are the
most important island shelf habitat in terms of diversity and
abundance of fish species.

In southern California kelp beds only grow on rocky bottom areas
with depths between 9 to 284 ft (3 to 86m). Greatest abundances
occur between about 25 to 100 ft (8 to 30m).

E-46

OCEANIC ZONAL MOIR OF SPECIES SHARED WITH NORTHERN TEMPERATE ZONE
ZONE SUBDIVISION 10 2d 30 40 50

ALASKAN
JUNEAU

BRITISH
COLUMBIAN

110REAL CAPE FIATTINY

PACIFIC OCEAN
OREGONIAN

CA FIE MENOCICINO

CENTRAL
CALIFORNIAN
-29%

POINT CONCEPItON

NORTHERN Son Diego

CENTRAL A
TEMPERATE EUGENIA

SOUTHERN

CASO SAN LUCAS

FIGURE E-13. Diversity of fish species along the Pacific coast
(North and Hubbs, 1968).

E-47

Kelp beds are found throughout the region, around all the Channel
Islands and along the mainland coast (Figure E-14). The U. S.
Bureau of Land Management (1979) identifies the abundant kelp beds
off the island's shores as a major reason behind its (BLM's)
conclusion that island waters represent one of the most importa nt
of southern California's marine habitats. They describe this
vital resource as follows (U.S. Bureau of Land Management, 1979):

"About 40 percent of all the kelp beds in the Southern
California Bight occur around the Channel Islands.
These kelp beds are some of the most highly developed
submarine forests in the world. Over 800 plant and
animal species are known to be-associated with these
kelp beds including many valuable sport and commercial
species."

Kelp beds (see Figure E-15) offer sessile, resident, and transient
marine life protection, food, and special benthic (in holdfasts)
and pelagic (stipes, fronds, and canopy) niches. Southern Cali-
fornia kelp beds harbor some 125 fish species although perhaps
only 20 or 30 are common (Quast, 1968). Ebeling et al. (In
process) reports that most fish species prefer either the bottom
or canopy zones, bypassing the intermediate depths.

Particularly important to repopulation rates, many kelp bed fishes
such as the kelp bass and some rockfish show little seasonal
movement. Ebeling et al. (In process) cite sources which state
that adults of kelp bed fish may spend most of their lives within
an area o f but a few hundred square yards. Ebeling et al . (In
process) also suggest that northern Channel Island kelp bed fishes

E-48,

v2O- 3a

LEG

Kelp Beds

sAv7,4 BAR84
RA IIV CONTOU

A", N MUEL A N
ISLAN

-x- KAND
SAM 1108W-@

% NTA

f /A

FIGURE E-14. Distribution of kelp beds in the northern Channel
Islands and Santa Barbara Island region (U. S.
Bureau of Land Management, 1979). too

Sea Surface

Kelp@-bed canopy

Y,
-11V
ilz 4i,

Bundl@
stipd

Holdfasts

1P.

FIGURE E-15. Underwater diagram of a kelp.bed (North and
Hubbs, 1968).

E-50

tend to have a higher fish density and diversity than do mainland
beds. They attribute this "island effect" to habitat differences
such as clearer water, more continuous high-relief rocky bottom,
and perhaps more fish food on the island shelves.

Many of the fish species found in more open waters over island
sand flats and in offshore pelagic areas beyond the island shelves
are presented in Appendix 2. In these areas, the small schooling
species such as the northern anchovy, Pacific saury, sardine,
mackerel, and squid are particularly important because of their
vital.role in the marine food chain. The nutrient rich waters fed
by regional upwellings support exceptionally abundant populations
of these species which in turn are fed upon by other fish, the
seabirds, marine mammals, and humans. The abundance of these -fish
is undoubtedly a significant factor supporting the large concen-
trations of marine mamm als and seabirds in the area.

The northern Channel Islands' surrounding marine waters are. also
habitat for the hydrocoral Allopora californica. With an incom-
plete sampling record, it is difficult to call this a rare or
endangered species; however, the species is presently known in
only 12 locations in Southern California. The U.S. Bureau of Land
Management (1979) cites this finding as. a reason for identifying
these southern California offshore islands as one of Sobthern
California's most important marine habitats.

In general, the fish resources around the northern Channel Islands
and Santa Barbara Island include a species" array representative of
the high diversity of fish found throughout the Southern Cali-
forda Bight. As indicated in commercial and recreational catch
statistics maintained by the California Department of Fish and
Game (discussed more completely under fishing and plant harvesting

E-51

in Section E.3-c.), many of these species are found in abundance.

E.2.d. Intertidal Organisms

The intertidal habitats on the northern Channel Islands and Santa
Barbara Island include primarily rocky shorelines with some
scattered sandy beaches. This is in contrast to the mainland
shoreline which is only 20 percent rocky (U.S. Bureau of Land
Management, 1979).

Rocky intertidal shorelines are an important marine habitat zone
in southern California. Describing these areas, the Southern.
California Ocean Sciences Studies Consortium (1974) states that
"...the intertidal area of a rocky coast is considered to have the
greatest diversity of plant and animal life of any ecological
area. Few major habitats so clearly show richness and variety of
1 i fe. A variety of marine organisms characterize this habitat,
including encrusting abalone, barnacles, and limpets, several
species of attached marine algae, starfish, sea urchins, tidepool
fish, foraging shorebirds, and marine mammals (see Table E-11).

Sandy beaches extend over a much smaller stretch of the island
shorelines and provide habitat to fewer marine oganisms; never-
theless, qui.te a few species occur in this habitat, including
burrowing clams, amphipods, isopods, and other invertebrates. The
area provides an important feeding habitat for several species of
shore birds. Marine mammals using the upper beach for haulout
purposes must pass through the area when moving from the water to
shore.

E-52

TABLE E-11. Examples of'intertidal -species of the northern
Channel Islands and Santa Barbara Island
(California Department of Fish and Game, 1979).

Chloraphyta - green algae
Enteramorpha spp. C0qghgeh alis
'Urospora w=nskioldii curr
:a

Phaeophyta - brown algae
Pachydictyon coriaceum I anus
Taonia lennebackariae enMta
Eisenia arborea Pelvetia fastiiata

Phodcphyta - red algae
Porn ella californica ';I ltis furcata
AcroMaetium bart-Adense T, flac,ida
Acrochaetium M-Ma rineara
Helminthora stricta
Gelidium rocusttum Callithamnion rupicolum
Bossiella californica Endocladia muricata

Porifera - sponges
Esperiopsis originalls Leuconia heathi
Isociona lithophoenix Rhabdodermella nuttingi

Coelenterata - hydroids, sea anemones, etc.
Abietinaria aqmhora Plwularia alica
Aglaor-henia struthionides Synthecium cyclindrun
Anthopleira elwantissina Epiact:Ls prolifera

Arv,elida - worms
Arabella irioolor Sabellaria californica
Nereis PeI0qNica SaIrmcina tribranchiata

Echinodermata - starfish, sea-urchins, sea cucumbers,. brittle stars, etc.
Astrometis sertulifera Patiria miniata
Pisaster ianteus Pisaster ochraceus
stronvlocerLtratus franciscanus Cucumaria lubrica
Strongy ocentratus purpuratus Anphipholis suamata
Anurouci aeguali siphanis Daherdmania claviformis
Archidistom psanmim

Mollusca - liarets, snails, octopus, etc.
Littorina scutulata
-california Acanthina spirata
digitalis Tegula funebralis
Collisella acabra Cypraea spadioes
risaurella voicana Mytilus californianus
Haliotis cracherodii Haliotis fulgers
Littorina Planaxis Chama pellucida
Octopus birmculatus

E-53

TABLE E-11 Cont.

Arthropoda barnacles, crabs, isopods, amphipods, shrimps, etc.
Hyale freguens Alpheus clamator
Cirolana harfordi Cancer rani
UOccidentalis Pachygrapsus crassioes
Crao raMMuM- Pagurus hirsutiusculus
Salanus glandula Mitella polynvs
tintinnabulum

Osteichthyes - boney fishes
s violaceus (monkeyface eel)
aurora (reer surfperch)
t I Tn-Y-deri (fluffy sculpin)
Xiphister atropurpureus (black prickleback)
Gibbonsia elegans (spotted kelpfish)
Gibbonsia metzi (striped kelpfish)
Gixella niciricans (opaleye)
ClirKttus recalvus (bald sculpin)
Xererpes fucorum(rockweed gunnel)

Aves - shore birds
Haematopus palliatus frazari (American oystercatcher)
Haematopus bachmam (black oystercatcher)
Aphri melanocephala (surfbird)
Arenaria melanocephala (black turnstone)
Heteroscelus Incanus wandering tattler)

Pinnipeds - seals and sea lions
Zalophus californianus (California sea lion)
Phoca vitulina (harbor seal)
Mirounga angustirostris (northern elephant seal)

SANDY INTERTIDAL HABITAT

Mollusca. - clans
Tivela. stultorum Olivella biplicata

Arthropods - Crabs, amphipods, isopods, etc.
Alloniscus eonvexux Orchestoidea californiana
Lepidope californica Lophopanopeus heathill
Emerita analoga
Aves - shore birds
Squatarola squatarola. (black-hellied plover)
Limosa fedoa (marbled godwit)
Mmienius PR0qieopus (whimbrel)
Catoptrophorus semipolmatus )willet)
Crocethia alba (sanderling)

E-54

Because the northern Channel Islands are remote and thus, until
recently, subject to little human disturbances,. the island inter-
ti dal areas include some of the best representative areas in
southern California. Mainland intertidal areas, which are mo re
easily accessible to the public and used intensively as areas for
specimen collecting, are typically in poorer condition than
comparable island areas.

E.2.e. Cultural and Historic Resources

Cultural and historic resources located in the marine waters
surrounding the northern Channel Islands and Santa Barbara Island
include underwater archaeological sites and artifacts and ship and
aircraft wrecks. No extensive onsite inventory of the cultural.
and historic resources of the study area has yet been conducted,
although Science Applications, Inc. (1978) conducted a thorough
survey of the relevant literature. for the Southern California
Bight for BLM.

Numerous archaeological and paleontological resources exist on the'
land areas of the northern Channel Islands and Santa Barbara
Island (U.S. Bureau of Land Management, 1978c). It has been
determined with an acceptable degree of accuracy that sea levels
were as much as 180 ft (55m) lower during previous eras of geo-.
logic time (Science Applications, 1978). Since known prehistoric
sites on land document the presence of man in the Channel Islands
area during these eras, it is generally thought that the exposed
areas of the continental shelf were extensively inhabited (Science
Applications, 1978). The potential exists, therefore, that
undiscovered archaeological sites are present in the submerged

E-55

.lands of the study areas. .The BLM literature survey (U.S. Bureau
of Land Management, 1978c) mapped three zones of different proba-
bility levels for the presence of cultural resources. The zone of
highest probability was the area from 0 to 330 ft. (0 to .100m) in
depth, where all known sites have been discovered. Medium and low
probability zones 330 to 485 ft (100 to 150m) and deeper than 485
ft (150m) respectively are less likely to contain significant

resources.

The discipline of underwater archaeology is relatively new and has
not yet been extensively applied in the study area. As a result,
most of the information which is currently available concerning
underwater sites identified within the study area is based on the
reports of amateur collectors and sport divers. The location and
value of identified sites are depicted on Table E-12 and Figure E-
16.

Due to natural hazards and prevailing current and weather pat-
terns, the seas around the northern Channel Islands have been
highly prone to shipwrecks throughout history. Such wrecks are of
interest to historians as time capsules representing the period in
which they sank and of interest to sport divers as marine habitat
and curiosities. Science Applications, Inc. (1978) identifies 573
shipwrecks and 9 aircraft wrecks covering a period from approxi-
mately 1540 to the beginning of World War II in the Southern
California Bight.

E-56

Table E-12. Shipwrecks recorded around the northern Channel Islands
and Santa Barbara Wand (U. S. Bureau of Land Management,
1979c) .

ID NO. NAME VESSEL TYPE CAUSE DATE OF SINKING

San Miguel Island

167 1 Comet Schooner stranded 8/30/11 Simonton
194 1 Cub a St. Scr. stranded 9/8/23
415 1 J. M. Colman Schooner stranded 9/3/05
411 a J. F. West Schooner sunk 1898
444 a Kate & Annie sunk 1902,
661 a Pectan
1029 1 Unk. Galleon sunk 1801
1068 a Watson A. West Schooner stranded 2/23/23

Santa Rosa Island

17 1 Aggi Steel 4-mast sunk 5/2/15-
199 1 Dora Bluhm Schooner stranded 5/25/10
192 1 Crown of England St. Scr'. sunk 11/7/1894
101 a Blue Fin Oil Scr. stranded, 9/3/44
68 a. Aristocratis sunk 1949
335 a Goldenhorn Barkentine stranded 9/12/1892
1026 1 Unk. Wreck

Santa Cruz Island

99 1 Black Dolphin Barkentine st@anded ? dynamited
154 1 City of Sausalito Oil Scr. burned 12/11/41
82 a Babina Gas Scr. burned 31/3/23
393 a International No . 1 Barge stranded 9/13/18
571 a Nancy Lee sunk 1946
888 a Thornton sunk 1910
1113 a Yukon Barge sunk 1/6/38

Anacapa Island

671 1 Pinnacle
760 1 San Francisco Oil Scr. burned 10/31/49
86 a Balboa Oil Scr. burned 1/18/49
260 a Equator 011 Sc r. sunk 7/2/49
467 a Labor Gas Scr. sunk 10/2/24
1008 1 Diesel sunk ?
1098 1 Winfield Scott St. side wheel stranded 12/2/1853

Santa Barbara Island

13 a Adriatic, Oil Scr. sunk 12/28/30
Fed.207 1 Dante Aleghieri II Gas Scr. sunk 11/30/38
253 a Emperor Oil Scr. sunk 7/15/32

E-57

30* 120, 3W I

LEGE

UNDERWATER ARCH
SHIPWRECKS AND

BANS
Tm A CLASS I- SIGNIF
:4 CLASS It- MODE

0 CLASS III-milm

ECLASS IV- UNDET
SANIrA
All

CONTOUR

R"k

biki"I rffll@u A
ISLAW A *Ap
rLO A LAMA CRUZ

SUM
ISLAND
rn

NTA
XYLL AU

NAUTICAL MILES

-FIGURE E-16.' Known fiarine Cultural Resources. -8*8 RA10

E.3 Human Activities

E.3.a. Introduction

The northern Channel Island's proximity,to one of the most heavily
urbanized areas along the United States' west coast exposes the
surrounding waters to many different (and often competitive). types
of human activities. The following section describes the scale
and intensity of the major area uses including oil and gas explor-
ation and production, commercial and sport fishing, kelp-harvest-
ing, commercial shipping, military operations, scientific- re-
search, and recreation. Wherever possible, uses are identified on,
a site-specific basis and discussions of both current patterns and
future trends are incorporated.

E.3.b. Oil and Gas Activities

Offshore oil and gas development began in the United States in the
State tidelands of the Santa Barbara Channel in 1896. The first
leases in State tidelands were sold in 1950. Development of the
Federal OCS lands within the Channel began in 1966 with the sale
of one drainage tract to allow development of a known field
(Carpinteria) in federal waters. In 1968, the first Federal lease
sale was held in the Channel. Federal development in the Channel
continued with OCS Lease Sale #35 in 1975 and Lease Sale #48 in
June 1979. BLM plans to hold two additional sales in the Southern
California Bight (which includes the Santa Barbara Channel) in the
next five years; Sale 68 in 1982 and Sale 73 in 1983. Significant
milestones in the history of oil and gas development in the Santa
Barbara Channel and in the vicinity of the northern Channel
Islands are summarized on Table E-13. Appendix 3 briefly reviews
stages in the OCS oil and gas development process.

E-59

TABLE E-13. Milestones in Santa Barbara Channel and the Northern
Channel Islands Area Oil and Gas Developwent.

Date Event

1896 First offshore developnent occurred in the Santa Barbara Channel.
1950 California grants first leases in State tidelands of Santa
Barbara Channel.

1966 State lands in Carpinteria field (state portion) leased.
C-1 1966
First federal lease in Carpinteria field (federal portion).
1968 Additional federal leases in the Santa Barbara Channel.
1969 Santa Barbara Oil Spill at Union's Platform A in the Dos
Cuadras Field.

1975 CCS.Lease Sale #35.

1978-1979 DES and FES on proposed Lease Sale #48.

1979 Lease Sale #48 held."June 29.

1982 Lease Sale #68 proposed for Southern California (including
Santa Barbara Channel) in July, 1982
1983 Lease Sale #73 proposed for California.

Approximate oil and gas reserve's have been determined for the
major outer continental shelf basins (National Oceanic and A tmo s-
pheric Administration, 1980). The Santa Barbara region contains
an,estimated 1.50 billion barrels of oil and 1.70 trillion cubic
feet of gas.. The U.S. Geological Survey (USGS) has ranked this
area- seventh among twenty-one offshore basins for the size of its
reserves. It is estimated to hold 3.9% of. the total energy
equivalent-of oil and gas resources calculated to be found on the
outer continental shelf. In terms of resource potential over@ the
current 5-year OCS oil and gas leasing schedule, the Santa Barbara
area was ranked third by industry and sixth by USGS (U.S. Depart-
ment of the Interior, 1979c). The nearby Los Angeles and Ventura
Basins, which together contain about the same amount of acreage as
the proposed sanctuary, have -proven reserves of 9 billion barrels
of oil (Tell, 1980, personal communication). Industry projections
indicate that the Channel area could,produce as much as 400,000
barrels'of oil per day by the mid-to-late 1980s, about 5 pe rcent
of the total domestic supply (Magee, 1980, personal. comm uni-
cation).

Table E-14 shows estimates of the magnitude of recoverable reser-
ves i n the Southern California Bight. These estimates are an
important factor in determining areas likely to be developed, as
well as the amount and types of facilities to be used in the area.

Figure E-18 shows existing leases around the northern Channel
,Islands and Santa Barbara Island and the operators of these
leases, relevant tract numbers are shown on Figure E-19. Until
now, most of the oil and gas activity in the area has occurred in
the State tidelands and on those OCS leases closest to the main-
land. Production platforms in the Channel area are shown on Table

E-61

TABLE E-14. Estimated oil and gas reserves for currently leased
tracts in the Southern California Bight (tracts
leased in 1966, 1968, OCS Sale #35, and OCS Sale-#48).
(Meekins, 1980, personal communication; data based on
open file report dated January 1979.)

Oil Gas
(million barrels) (billion cubic feet)
Reserves*

Total Southern California Bight: .695 1575

Undiscovered Resources**

Total Southern California Bight: 394 1295
Santa Barbara Channel: 152 @516
Santa Rosa Plateau: 10 45
Santa Barbara Island: 15 15

*Reserves are defined as known technologically recoverable quantities
of hydrocarbons.

**Undiscovered resources are defined as those quantities of oil and
gas which are reasonably expected to occur in existing favorable
geographic settings but arecompletely undiscovered, and which after
discovery can be expected to be produced under present technology.

E-62

.......... ........ .. ........
-:jkA' ........................
40
Tra
................
................... .............. ....

............... ...........
.................
M Tra
......... .....
.................. ........ Sal
%.............
..... ... ........ ... . . ......
.. ......... ...... %.............
SAN AMUIX

.......... .
. ... ........

Jib ........

.... ........

......... ............
...... ..................
.... ............
.................

04
SES

SAN
NICOL-4S

46
0 =15
11) N-MILES

FIGURE E-17. Tracts withdrawn from OCS Sale #48 by the Secretary of Interior. (Also s
E-19 forwithdrawn tracts in the vicinity of the northern Channel Islands
Department of Interior, 1979a.

I of 34r

LEG
%

7,
C001v MI-Parcels, of
t; sum Leasing in
Expired or
Federal Le
... -Leased Fed
OCS P" Le
... ... ... X-Tract

.. ... ... ....
Sale 48
Interior

'y OP
_J %char*- Z,
A ARCO
R@LA P,;;N.
MIGuEL CCHEVRO
AND ANACAEA- TAPI--
LSL CRUZ I
sum ChCHAMPL
MAM,
CoCONTIN
rn
E EXXON
N
[M MOBIL
,J Cf
t

4- 11/1
T
t

21 ZV
ICAL Mk[S.5
0
FIGURE E-18. Existing leases and operators, and tracts offered in
ARAIV
Sale #48, in the northern Channel Island area (U. S.
Bureau of Land Management, 1979 (Visual #1); Adams,
1979, personal comunication; U. S. Geological Sur-
vey, 1975 (flap 1-974); California Office of Planning
and Research, 1977; U.-S. Department 0
f Interior,
1979a; and Oil and Gas Journal,', 1979a.

W.- e4j
LE(

0
0 a Tracts

3
182MIS - 0 27026029
0 L- --'@ -.6 -
044042043 4
234 253 06
07C 249 227 226 7 b?6
% 9- 17 -f- - oe CONTC
;;U[2:i3t@C19 va Z17-1 216 2"..5
Fla"
S 09 2TT 12 211 09i 21 209
vwv
168 16S 098 io 10 20 20
206
%
10
% 108
N MCAAL ANACAPA
AND
B"m CFAM

-MLAW

rS, -
m

.24' 245
1/j
%

113 H4
eu 95
Is
NAUTICAL W11 is

FIGURE E-18a. Tracts leased in Lease Sale #48. (Oil and J1 9
2 k QEYAR
Gas Journal, 1979).
@23 7

&Y
'3 f

all.
LEG
X <A
%
0 29
Wj_
0 -3S.Hil
'108 1 @0_1
24
0
Parcel
3 04 W7 9 Ole
Identi
Ids 83 182 6181 0 027 02ROZ9
J'@J'\_N 241 t 046
W1 @433 a IM W034037468 039 401041104Z 043 o4 4? - 64oisu-
05 7 60 061 0-M z,3B Z34, 06323 33
0521054054 055 9% 057
6 06 Q Z2 761
s 6806910 b73 _P 229 227 Z26 08
- - CONTOU
17 0-99 218 ?161215 Lf
78 79 os 082 083LOt4..

2
%
..6 04 10Z 206 6 20 204
91, t
-A, 67 .1L
.."! 08
L
ISLAND ANACAPA
SAMM CRLIZ
UJLAMU
s
sum
um
_'JOLASOL'"'
rn
all

Jf
- N .
%1@_
NJ?
'@4 12' 250 2 1 1@
113 04
NAUTICAL MILES 15
2t 14 Z__ k

FIGURE E- 19. Existing OCS-Pacific numbers (186-291) and all tract
T
numbers originally proposed for Sale #48 (002-119) N
E H' 29 FRAPEIARX.V
in the northern Channel Island area (U. S. Bureau of
A,
Land Management, 1979 (Visual #1); Adams,,-,, 1979,
personal communication; U. S. Geological Survey'.
4L
1975 (Map 1-974); California Office of Planning and
Research, 1977; and U. S. Department of Interior,
1979a).

E-15; all of these are on tracts either in State waters or on OCS
leases on the mainland side of the Channel. Platform Grace, once
installed, will be the furthest platform offshore (approximately
10 nmi or 18.5km) and the closest to the northern Channel Islands
(approximately 8 nmi or 14.8km from the tip of Santa Cruz Island).
Several exploratory wells have been drilled close to the northern
Channel Islands. Tracts on which wells have been drilled and the
number of wells drilled per tract are shown on Table E-16.

Two plans for exploration on leases near the northern Channel
Islands have recently been approved by the USGS and certified as
consistent with California's coastal plan by the California
Coastal Commission (CCC). The CCC found Chevron's exploration
plan to drill four wells on tracts 204, @208, 209, and 215 (in the
Santa Clara Unit) to be consistent with Californials Coastal Pl-an
on December 12, 1978 (California Coastal Commission, 1978). The
most southerly of Chevronis proposed wells lies approximately 8
nmi (14.8km) north of the Anacapa Islands (Chevron, 1978). On
March 23, 1979, the CCC also found Exxon's exploration plan to
drill up to 15 exploratory wells from tracts 222, 223,
230,231,232, and 238 in the Santa Rosa Unit to be consistent with
the coastal plan (California Coastal Commission, 1979). The
southern tip of tracts 222 and 223 are approximately 6 nmi
(11.1km) from Santa Cruz Island.

E-67

Table E-15. Platforms in the Santa Barbara Channel area (U. S. Bureau of Land Management,
1979 (Visual No. 1); U. S. Geological Survey, 1975 (Map 1-974); Resources 1978;
Adams, 1979, personal communication; and Califbrnia Office of Planning and
Research, 1977).

PLATFORM NAME UNIT 'TRACT OPERATOR

State Waters

Hope Carpinteria PRC-3150 Chevron
Hazel Summerl and PRC-1824 Chevron
Heidi Carpinteria PRC-3150 Chevron
Hilda Summerland PRC-1824 Chevron
Holly South Ellwood PRC-3242 Arco
Helen Cuarta PRC-2206 Texaco
Herman Conception PRC-2725 Texaco
rn Rincon (Artificial Island) PRC-1466 Arco

00 Federal Waters

Union A Dos Cuadras P-0241 Union
Union B Dos Cuadras P-0241 Union
Union C Dos Cuadras P-0241 Union
Hillhouse Dos Cuadras P-0240 Sun
Henry (Planned) Carpinteria P-0204 Sun
Houchin Carpinteria P-0166, Phillips
1bgan Carpinteria P-0166 Phillips
Grace (Planned) Santa Clara P-0217 Chevron
HD ndo Santa Ynez P-0188 Exxon
Gina (Planned) Hueneme P-0202 Union

TABLE E-16- Number of wells drilled on .existing leases, all or
partially within 6 nmi (11.11an) ofthe.northern
Channel Islands and Santa Barbara Island (also.see
Figure E-22). (Adams, 1979, personal communication;
U.S. Bureau of Land Management, 1979 (Visual No. 1);.
U.S. Bureau of Land Management, 1978a).

Tract island Of Wells Operator Future status-

167 San Miguel 1 Expired or Terminated
168 San Miguel 0 Expired or Terminated
169 San Miguel 1 Expired or Tenydnated
170 San Miguel 1 Expired or Terminated
172 San Miguel 0 Expired or Terminated
174 San Miguel 0 Expired or Terminated
175 San Miguel a Expired or Terminated
176 San Miguel 2 - Expired or Terminated
177 San Miguel 0 - Expired or Terminated
178 San Miguel 0 - Expired or Terminated
179 San Miguel 1 - Expired or Terminated

243 Santa Rosa 0 ?
244 Santa Rosa 0 Chevron ?
245 Santa Rosa 0 Chevron ?
246 Santa Rosa 0 Chevron ?
,247 Santa Rosa 0 OX000 ?

200 Santa Cruz 0 Expired or Terminated
201 Santa Cruz 0 Expired or TennInated
206 Santa Cruz 0 Expired or Terminated
210 Santa Cruz 0 Chevron ?
211 Santa Cruz 0 Expired or Terminated
.212 Santa Cruz I Expired or Tenninated
213 Santa Cruz 0 Expired or Terminated

198 ArAcapa 0 Expired or Terminated
199 Anacapa 2 Expired or Terminated
202 Anacapa 4 union Development
203 Anacapa 4 uraah Exploratc=y Drilling
204 Anacapa 1* Chevron Exploratory Drilling
205 Anacapa 2 Chevron, Exploratory Drilling
208 Anacapa. 1* Chevron Exploratory Drilling
269 Anacapa 1* Chevron Exploratory Drilling
215 Anacapa 1* Chevron Exploratory Drilling

289 Santa Barbara 1 Mobil ?
290 Santa Barbara 0 Mobil ?
291 Santa Barbara 0 Mobil ?

Chevron's exploration plan for exploratory wells P-0204-1, P-0208-2, P-0209-2
and P-0215-2 was recently approved by USGS. The plan ,as certified as
consistent with California's coastal plan by the California Coastal
Ccrmission on December 12, 1978.
? As Yet undetermined

E-69

E.3wc. Commercial and Recreational Fishing and Plant Harves@io

Harvesting of living marine resources (see,also Section E.2.c,.) by
commercial and recreationalfishermen and kelp harvesters current,
ly represents the most intensive human use occurring over the
shelves Adjacent to@the northern Channel Islands and Santa Barbara
Island. Depending on the species sought, commercial fishermen use
gill nets, purse seines, traps, trawls, and other assorted gear
while recreational fishermen typically use their hands, hook and
line or sometimes spear guns. Commercial fishermen may seek any
of a large variety of species which are of little interest to
recreational fishermen. However, commercial and recreational
fishermen may compete with each other for a few species such as
rockfish and abalone.

Catch statistics maintained by the California Department of Fish
and Game (DFG) indicate that for the marine sanctuary study area,
the greatest commercial fishing catch by weight-occurs north of
Anacapa Island in the Santa Barbara Channel (see Figure E-20).
The tonnage of fish taken from these waters is typical of near-
shore southern California coastal waters. The weights are well
below those off San Pedro, the most productive commercial fishing
.area in the Southern California Bight; however, while much of the
tonnage landed in San Pedro consists of migratory schooling fish,
due to the extensive shallow water island shelf areas, the island
waters are major southern California producers of species such as
abalone, sea urchin, and rockfish.

In addition to the fish and shellfish fisheries, the northern
Channel Island waters and those off Santa Barbara Island support
southern California's most productive kelp harvests, In 1978, the
kelp beds around the northern Channel Islands produced over 24,000
wet tons (22,000 metric tons) of kelp while the beds around Santa
Barbara Island produced 1,867 wet tons (1,600 metric tons) (Cali-

.E-70

3W Nr

LEG

3 to 9 atilt

I to 4 0111
7
WWI
SAUM 200 to 9" th
101) to I" th

S to 99 thous

loss than S

. ..... .... CONTOU
. ...........

li@ CRUZ
x
IMAM
X

(L@@

Z.,
7
Y

NAUTICAL WE
MILT-

FIGURE E-20. Mean annual commercial fishlandings (1970 to 1974)
around the northern Channel Islands and Santa Bar-
bara Island by 10x1O winute statistical area
(California Department of Fish and Game, 1975; U. So
Bureau of Land Management, 1979).

fornia Department of Fish and Game, .1979). Kelp is harvested by
specially designed ships, kelp cutters, which cut off and scoop up
the top 4 ft. (1.3m) (depth of cut is limited by law) of the kelp
while leaving the remainder of the plant alive and intact. Rapid
growth of up to a foot or more per day under extremely favorable
conditions permits several annual kelp harvests (California
Department of Fish and Game, 1971; North and Hubs, 1968).

Kelp harvesting has occurred for almost 30 years around the
northern Channel Islands althQugh harvesting around Santa Barbara
Island has only been started recently (Trabert, 1979, personal
communication) . The industry uses almost all of the well-
developed kelp bed areas. Table E-19 illustrates fluctuations in
landings between 1974 and'1978.

One of the major kelp harvesters, Kelco, uses small, single engine
aircraft to survey the condition and size of kelp canopy so that
kelp harvests can be scheduled after optimum regrowth of kelp
vegetation. These craft operate at altitudes of approximately 500
ft. (152m) and move to within a quarter nmi (0.5km) of the Channel
Islands (Trabert., 1979, personal communiction).

The species and total catch of fish landed by commercial fishermen
may vary significantly from year to year (see Table E-17). For
example, between 1971 and 1975, annual sea urchin harvests rapidly
expanded from zero to several million pounds as this new regional
fishery developed. Conversely, lobster catches declined steadily
over the same period. Comparable trends in the landings of other
species such as abalone and rockfish are less clear. Table E-18
lists the species caught most abundantly around the northern
Channel Islands and Santa Barbara Island during 1975 (the most
recent year for which comprehensive statistics were compiled).

E-72

TABM E-17. camarcial fish landings for selected species caught off the northern Channel Islands
and Santa Barbara Island between 1971 and 1975 (developed from California Department
of Fish and Game, 1979).

Weight in 1000 lbs.

1971 1972 1973 1974 1975
northern Santa northern Santa northern Santa northern Santa northern Santa
Channel Barbara Channel Barbara Channel Barbara Channel Barbara Channel Barbara
Sp@_f ies Islands Island Islands Island Islands Island Islands- Island Isla-nds Island

Abalone;

Black 56.5 0.9 780.3 6.4 1251.3 18.1 718.4 15.7 454.1 48.7

Red 488.5 44.6 386.3 87.9 297.7 39.2- 268.9 95.4 250.7 124.6

Green 3.6 0.9 1.5 1.3 2.1 0.1 2.5 - 1.7 0.2
m
'4 Pirik 102.8 6.0 97.1 21.1 118.5 2.9 140.1 19.1 124.6 31.1

All Others 0.2 - 0.1 0.7 0.8 0.1 1.1 0.2

Sea Urchins - -- 911.8 1679. 6 - 2604.3 -

14ol)s ter 23.9 2.5 32.6 15.7 19.2 7.9 12.4 9.8 10.7

Pacif ic Witita 314 22. 346 34 760 20 60 101

Jack Mackerel 274 1110 50 732 26 130 146 1138 344 66

W)rffiern Anchovy - 148 2200 - 2804 436 2150 50 1302 6@

Market Squid 434 22 -530 82 1844 44 2170

Rockf ish 126 - 244 - 340 - 180 - 214

Swordfish - 16 - 4 12 - 20 - 30.

-All Wier finfish 944 40 1602 74 3044 20 3120 54 4370 66

'IMAL 2771 1 1390 1 5762 976 768 10,327 1548 1 11,839 409
30
::@44
10 11
05

Table E-18. 1975 commercial . fish landings by species (in 10 x 10
minute blocks) around the northern Channel Islands and
Santa Barbara Island. Note: Block numbers refer to
numbered areas shown on, Figure E-20. Only species with
landings in excess of 10,000 lbs. (4,500kg) are listed.
(Based on statistics from the California Department of
Fish and Game.)

Month of
Island/ Weight Greatest
Block Species (in lbs.) Catch

ANACAPA ISLAND

684 Northern.anchovy 5,932,650 Dec.
Sea urchin 209,624 Jan..
Bluefin Tuna 198,850 Aug.
Bocaccio 168,969 Oct.
Rockfish 147,045 May
English sole 81,765 Mar.
Petrale sole 16,490 Sep.
California halibut 11,284 Jul..
Sablefish 10,321 Oct.
20 other species 24,272 ---
Total for Block 0

707 Sea urchin 406,704 Jun.
Northern anchovy 194,300 Oct.
Swo rdf i sh 20,733 Aug.
3 other species 4,207 ---
Total for Block

SANTA CRUZ ISLAND

685 Market squid .1,080,648 May
NDrthern anchovy 718,600 Jan.
Jack mackerel 123,500 Sep.
Sea urchin 67 513 May
Rockfish 22:585 Jun.
18 other species 41,997 ---
Total for Block 2,054.843

686 Sea urchin 372,605 Dec.
Market squid 356,200 May.
Bocaccio 32,742 Dec.
21 other species 32,871 ---
Total for Block 7

E-74

Ta.416 E-18 Cont.

687 Market squid 936,525 May
Sea urchin 78,639 Jan.
Pink abalone 10,542 Oct.
18 other species 28,799
Total for Block

708 Sea urchin 134,265 Dec.
Pink abalone 40,808 Oct.
Red abalone 26,732 Mar.
Swo rdf i sh 26,603 Sep.
Black abalone 10,452 Oct.
10 other species 4,977 ---
Total for Block 243,837

709 Sea urchin 224,206 May
Jack mackerel 173,455 Sep.
Bluefin tuna 96,035 Jul.
Market squid 71,829 Jun.
Pink abalone 46,181 Apr.
Red abalone 25,318 Jul.
Swordfish 18,620 Aug.
13 other species 13,722
Total for Block 669,366

SAN MIGUEL ISLAND

690 Black abalone 319,959 Jul
Sea urchin 225,423 Jan:
Red abalone 116,336 Jan.
Rockfish 71,576 Nov.
Yelloweye rockfish .47,520 May
Bocaccio 31,713 Nov.
26 other species 56,336
Total for Block 868,863

713 Jack mackerel 48,000 Jan.
7 other species 12,571
Total for Block 60,571

SANTA ROSA ISLAND

688 Northern anchovy 584,300 Oct.
Spot prawn 23,713 Jul.
Rockfish 16,194 Apr.
Market squid 14,844 Jun.
16 other species 36,481 ---
To,tal for Block

E-75

TaUle E--18 Coht.

711 Sea urchin 970,038 Apr.
Black abalone 62,119 Sep.
Bluefin tuna 57,391 Jan.
Rockfish 49,595 Jul .,
Red abalone 35,305 Jun.
13 other species 30,506
Total for Block I,ZU4,954

712 No species over
10,000 lbs.
12 species reported 31,037

SANTA BARBARA ISLAND

744 Swordfish 11,832 Nov.
3 other species 11'9852 ---
Total for Block ZJ,684

745 Swo rdf i sh 2,386 Jul.
No other species
reported ---

764 Jack mackerel 66,500 Nov.
Bluefin tuna 22,165 Aug.
4 other species 3 422
Total for Block

765 Swordfish 13,739 Oct.
Rockfish 12,599 Jul.
8 other species 20,841 ---
Total for Block 47,179

E-76

Among the'species taken from the area in the greatest amounts were
the jack mackerel, northern. anchovy, market squid, bocaccio, sea
urchin, abal one, and rockfish,, the latter three being mainly
limited to the island shelves.

Although commercial fishing occurs throughout the year around the
northern Channel Islands and Santa Barbara Island, individual
fisheries may vary seasonally. For example, 1975 DFG data show
that squid were taken most frequently in spring while the northern
anchovy was fished primarily during the fal 1 and wi nter. Sea
urchin, rockfish, and abalone* were taken throughout the entire
year. Compared to the northern Channel Islands, fisheries around
Santa Barbara Island were generally less productive and dominated
more by open water pelagic fish species.

Commercial abalone divers, through the Abalone Association and the
Abalone Seeding Association, sponsor an abalone mariculture
hatchery in Santa Barbara. Abalones are cultivated for future
restocking; the seeding association has a monthly planting at San
Miguel Island, near Cuyler Harbor (Pirog, 1979, personal communi-
cation).

Recreational fishing is a major use of the fish resources around
the northern Channel Islands and Santa Barbara Island. Although
some fishermen seek tuna, albacore, marlin, or swordfish in the
deeper waters seaward of the island's slope, most recreational
fishermen, particularly those on commercial partyboats, are
attracted to the nearshore island shelf waters, especially the
areas over kelp beds. According to partyboat fishing statistics
compiled by the California Department of Fish and Game (1979),

*The commercial taking of abalo6e is prohibited during the months of
February and August.
E-77

rockfish, kelp, and sand bass are the species caught in greatest
abunda nce, supplemented by regular takings of a variety of other
species (see Tables E-19, E-205 E-21 and Figure E-21). Spo rt-
divers collect lobster, abalone, and other invertebrates.

Recreational fishermen visit offshore waters either as passengers
on commercial partyboats or on private pleasure craft. Waters
toward the center of the northern Channel Islands chain, primarily
,off Santa Cruz and Santa Rosa Islandsi are most heavily frequented
by partyboats (see Figure E-22). Although statistics on the
concentrations of private fishing boats are not available, most
private boats probably fish the north side of Anacapa and Santa
Cruz Islands (Ono, 1979, personal communication).

Most visitors to northern Channel Island waters leave from harbors
on the mainland side of the Santa Barbara Channel, including
Oxnard, Ventura, Port Hueneme, Santa Barbara, and Gaviota, some 14
to 42 nmi (25 to 75km) from the northern Channel Island waters.
Visitors to Santa Barbara Island waters come primarily from more
southerly ports in the Los Angeles area or from Santa Catalina
Island. Based on California Department of Fish and Game partyboat
statistics for 1975, most recreational anglers fish during the
warmer months of June through September, but year-round activities
persist at a lower use level.

E.3.d. Commercial Shipping

Due to the study area's location near a major shipping route and
the presence of active oil and gas leases, commercial vessels
regularly navigate the Santa Barbara Channel region. Furthermore,
numerous proposed. projects, some of which are imminent, will add

E-78

TABLE E-19. Yelp harvests off the northern Channel Islands and Santa
'L
Baxbara Island between'1974 and 1978 (California Department
of Fish and Gam, 1979)-.

(weight in wet Tons)
Area 1974 1975 1975 1977 --- 9=78

Northern Channel Tsland 19,858 11,538 5,535 15,304- 24,588
(San miguel, Santa Rosa
Santa-Cruz, Anacapa)

Santa Barbara Islard 1,861

Tbtal 19,858 11,538 5,535 15,304 26,455

TABLE E-20. Commercial passenger fishing vessel catch in nurber of fish
for the northern Channel Islands between 1970 and 1974.
(California Department of Fish and Game, 1979).

Species 1970 1971 1972 1973 1974

Rockfish 337,820 215,906 358,641 436,486 303,425
yelp and sand ba= 67,061 109,679 94,875 74,352 58,925
H&lf3=n 319 93,305 32,782 34,012 3,613
Cali ornla sheephead 7,474 9,755 9,626 14,369 7,051
Ocean whitefish 5,972 4,933 7,373 7,171 4,092
Lirgcod 5,387 4,569 5,940 6,248 5,872
Cabe 1,217 1,754 1,526 1,037 490
Boni@@ 11,529 40 3,539 5,343 582
Flatfish' misc. 1,132 488 976 1,816 737
CalifoQa hlib-t 1,622 643 859 1,228 303
All Others 2,220 5,856 5,071 3,048 4,409

Total, 441,743 466,928 511i208 585,310 389,498

TABLE E-21. Camercial passenger fishing vessel catch in number of fish
for Santa Ba3tera Island between 1970 and-1974 (California
Department of Fish and Gc-m, 1979).

Species 1970 1971 1972 1973@ 1974

Rockfish 65,674 39,809 48,729 68,858 66,026
Felp and Sard bass 2,614 191 10,774 6,098 250
Ocean whitefish 2,408 1,431 729 1,890 358
Falfrmon 939 27 1,374 3,352 so
Sheephead 1,657 S93 2,417 309
Flatfish, misc.* 317 185 91 11275 3S4
Bonito 1,704 0 27 64 40
Sculpin 102 178 243 19 113
LiMcod 93 75 79 122 56
Cabezon 16 12 87 66 10
All Others 291 6 343 1,506 + 35

Total 75,815 42,505 64,893 85,489 67,631

includes halibut + predaninately. Pacific rmckerel

E-79

1220 121* .1200

SANTA BARDARA
/%A

MORE THAN 500,000

MONICA
340 250.000 499.9911 S!L. CR SANTA

...........
100,000 249.999

50,000 - 99.999

SANTA
PARDA A:
MA

rn 10,0 00 49,999
141C S

33* LEME TE

Ilto 210 30 .."TANNE a
NAUTICAL MILES .0AH 9
C OR.T i't.
0 25 30
b_
KILOMETERS *at SHOP

FIGURE E-21. Cumulative density of partyboat fish landings between 1973 and 1975 (Ca
of Fish and Game Marine Sport Catch Studies as presented in U. S. Burea
ment, 1979).
AL 1A

1220 1210 1 19P

10N., .$AN T ABARBARA
MORE tHAN 200,000

100.000 199,999 11 ..... .
S .1A EL UJI., '@i: -, , @@ -
TA MONICA
ROS SAN
Vz/7,727MM
50,000 - 99,999

25,000- 4io' )99

10'0 0 0 - 24, 999 .1.1 SAMTA
BARBARA .11
a t4. AN LINA
ROCK

M 1,000 - 9.999
.3 100

-330 EMENTE

0 10 20 30
L
NAUTICAL MILES
C Qxr4
0 25 50

KILOMETERS
BISH OP

FIGIURE E-22. Cumulative density of anglers fishing from partyboats: in the southern
.fleet (California Department of-Fish and Game Marine Sport Catch Studie
U. S. Bureau of Land Management, 1979).

to the , overal 1 1 evel of shi ppi ng.

A Traffic Separation Scheme (TSS) established by the Coast Guard
runs Just north of, and roughly parallel with, the northern
Channel Islands. It approaches to within 2 nmi (3.7km) of Anacapa
in the east end of the Channel and is about 20 nmi (35km) from San
Miguel Island in the west end of the Channel (Figure E-23). The
TSS is used by many commercial vessels travelling between northern
Pacific ports (e.g., Alaska, San Francisco, and Seattle) and those
situated in southern California, as well as by traffic using the
Panama Canal or heading to and from Indonesia and other western
Pacific ports. Large vessel traffic (i.e., vessels larger than
100 gross tons) has been estimated to pass through the Channel at
a rate of 6.5 vessels per day in a northbound direction and 5.5
vessels per day in southbound direction .(McMullen, 1977).

Another Channel area survey, conducted by the Coast Guard at Port
Hueneme and assisted by radar data collection procedures, reported
a daily average traffic load of nine large vessels (300 feet or
longer) heading north within, or closely paralleling the TSS
(Cherney et al., 1978). This study also recorded a daily combined
average of seven medium (100-299 feet long), small (less than 100
feet long), and tug-in-tow vessels en route along the TSS in a
northerly direction. 'In addition, an averge daily load of 32
vessels (incuding vessels of all sizes) were observed crossing the
lanes from one side of the Channel to the other. The majority of
these were probably linked to service/supply boat activity between
Port Hueneme and offshore oil and gas platforms and associated
facilities.

E-82

1206 30'

LEGE
Vessel

fill

CONTOUR

P"ch

W N Mo In,
Sit IC
CR=

sum gam-

% NWTA N
AL)

-Az
V@;l AAJIICAL MILES
2rilix ?

J"P
FIGURE E-23. Vessel Traffic Lanes a RAIJ

The 'most common cargo aboard ships transitting the study area
appears to be petroleum products, both crude and refined. In
1976, these products accounted for approximately two-thirds (66
percent) of the total cargo (by weight) received at or shipped
from Long Beach Harbor, Los Angeles Harbor, and Port Hueneme --
the three major ports closest to the study area (U. S. Army Corps
of Engineers, 1976). In order of decreasing tonnage, the pre-
dominant petroleum products handled at these ports were crude
petroleu m, residual fuel oil, and distillate fuel Commodities
such as fresh fruits and nuts, limestone, basic chemicals, coke,
iron, steel, nonmetallic minerals, and lumber made up much of the
remaining non-petroleum related cargo passing through these ports.

Although precise traffic log counts are not kept, it is reported
that the majority of vessels passing within or close to the study
area are of foreign registry (Bannon, 1979, personal communi-
cation).

The waters around the northern Channel Islands are also used by
ships servicing offshore oil and gas lease tracts in the immediate
Channel region. Because there is currently limited onshore
pipeline capacity from the Channel area to Los Angeles Basin
refineries, most offshore production must be transported either by
tanker or barge or both.

In the future, vessel traffic in the Channel is likely to increase
both as a result of new southern California offshore oil produc-
tion and the realization of a number of external projects now. in
the planning stages. As many as 40 new round trips per month can
be expected as a result of offshore Santa Barbara Channel oil

E-84

production if pl atform-to-shore pipol ines are not constructed
(California Office of Planning and Research, 1977). Specifically,
this increase would consist of new production from the South.
Ellwood, Summerland, and Carpinteria State offshore fields, and
the Santa Ynez, Santa Clara, and Hueneme Units. However, the
recent approval of an oil and gas pipeline system by the South
Central Coast. Regional Commission should significantly lower the
number of projected tanker and barge. vessels transitting the
Channel (California Coastal Commission, 1979b). Tanker traffic
can also be expected to increase as a result of exploration and
development of other OCS Sales #35 and #48 leases.

Projects not originating in the Santa Barbara area may also lead
to increased vessel traffic in the Channel.

However, there is a possibility that current levels of vessel
traffic in the Santa Barbara Channel due to the transport of
Alaskan oil will decrease. Tankers carrying Alaskan crude now
pass through the Channel at a rate of about 183 per year (Stark,
1979, personal communication). Congressman Lagomarsino (R.,
Calif.) has introduced a bill in the House of Representatives
which would prohibit vessels transporting Alaskan oil from using
routes through waters lying shoreward of the Channel Islands (HR
1056, 96th Congress 1st. Sess., 1979). This legislation is
currently pending before the Coast Guard subcommittee of the House
Merchant Marine and Fisheries Committee. In addition, President
Carter has officially approved the Northern Tier Pipeline Com-
pany's project to build a west-east crude oil transmission system
for Alaskan oil (Turnbull, 1980, personal communication). The
proposal involves a marine terminal at Port Angeles, Washington,
and 1,491 miles of new pipeline to a terminal at Clearbrook,
Minnesota. The project is currently being evaluated by several

E-85

federal regulatory agencies and the State of Washington. Co n-
struction time is estimated to be 2 years (Oil and Gas Journal,
1979b).

A project which might increase Santa Barbara Channel tanker
traffic involves shipment of Naval Petroleum Reserve oil. Pur-
suant to the Naval Petroleum Reserves Production Act of 1976,
facilities will be acquired or constructed to ship not less than
350,000 barrels per day of crude oil from Elk Hills, California to,
unspecified marketing terminals.

One transportation option being considered would involve piping
this oil to Port Hueneme and then transferring it by tanker to
market. Tankers bound for Pacific coast destinations north of
Port Hueneme such as San Francisco would have to enter the Channel
shipping lanes. If this option were put into operations, an
estimated 207 additional northbound vessel trips per year could be
expected through the Channel (U. S. Bureau of Land Mangement,
1979).

Another proposed project which might add to the present level of
commercial shipping in the Santa Barbara Channel is the construc-
tion of a liquified natural gas (LNG) terminal and gasification
plant in southern California. To date, a variety of sites have
been proposed and considered by the California Coastal Commission
(CCC), the California Public Utilities Commission (PUC), and the
Fede ral Energy Regulatory Commission (FERC). A final decision has
not as yet been made. The site at Point Conception, preliminarily
approved by the PUC, would result in little if any additional
traffic in the study area -- LNG tankers would approach no closer
than 20 nmi (37km) from San Miguel Island. A site further south
at Oxnard, which is currently favored by FERC (which has permit-

E-86

tin@ authority along with PUC) would result in a steady flow of
tankers through the Channel The CCC has suggested alternative
offshore siting options near the northern Channel I-slands, how-
ever, neither the PUC, FERC, nor the applicant have seriously
considered them (Reese, 1979i personal communication).

Finally, the Space Shuttle Vehicle System at Vandenberg Air Force
Base, when i 'n operation, will also lead to increased vessel
traffic. Barges transporting expendable external tanks will be,
moved from Port Hueneme through the Channel to Vandenberg. Ten
round trips per year by barge are expected (U. S. Bureau of Land
Management, 1979). Also, boosters recovered after launch in an
impact zone southwest of Point Arguello are likely to be towed
across the Channel, thus adding to the region's traffic.

E.3.e. Military Operations

The United States Navy and Air Force conduct a wide range of
military operations in the general southern California Bight area.
All of these operations are strictly controlled whether on sea or
in the air, and all require that extensive danger zones be free of
non- participants in order that the conduct of an operation may
safely proceed. Current operations include air to air, air to
surface, surface to air, and surface to surface missile launch,
bomb drop exercises (inert bombs with spotting charges), aerial
mining exercises, and some submarine activities in the hydrophone
array area south of Santa Cruz Island. Additional military
operations planned for the near future are those in conjunction
with the Air Force Space Shuttle Vehicle Flight System. The Navy
maintains a weather station on San Miguel Island. ND permanent
personnel stay on the island in connection with the station,,but
occasionally personnel visit the station by helicopter to check
equipment.

E_'87

Bomb drop exercises in the area at San Miguel Island are conducted
against a target buoy in ocean waters approximately 1 nmi (1.8km)
south of the eastern tip of the island. Light attack aircraft
f rom the Naval Air Station, Lemoore, California are the primary
users of this facility. The present rate of these operations is
approximately 200 times a year, with an average of five aircraft
per flight--a total 'of 1,000 individual sorties peryear. Planes
making the bombing runs cruise at an altitude of 12,000 ft (3063m)
and descend to an altitude of approximately 2,000 ft (606m) when
dropping practice bombs. A surface danger zone extends 3 nmi
(5.6km) from the shoreline of the eastern half of San Miguel
Island. Prior to the conduct of bomb drop exercises, boaters are
advised to remain. clear of this area (U.S. Department of Navy,
1979, personal communication).

San Miguel Island has not been intentionally struck by ordnance
items for many years. Occassionally, however, missile danger
zones may overlie the island, forcing evacuation of personnel for
the duration of such activities.

A practice aerial mine range is maintained by the Navy in
Beecher's Bay on the northeast side of Santa Rosa Island and in
the channel area between Santa Rosa and Santa Cruz Islands. The
mines used are inert and consist of a mine casing filled with sand
and concrete. The altitude of aircraft involved in mine laying
operations is often as low as 200 ft (61m). Mine recovery by
divers occurs approximately once each month. This activity
requires the presence of recovery craft for a period of approx-
imately three days.

E-88

The Navy maintains an undersea hydrophone array extending south
from the east end of Santa Cruz Island for a distance of approx-
imately 10 nmi (18.5km). The facility is operated by the General
Motors Corporation, Delco Division, and is used for acoustic
measurement purposes approximately 50 times a year (Scruggs,,1979,
personal communication) .

As noted, a future Air Force use of the area involves the develop-
ment and operation of the Space Shuttle Vehicle System. Approx-
imately twenty operation flights are planned for the system and
will be launched for Vandenberg Air Force Base on Point Conception
(beginning in December, 1982, and extending over an eight year
period), although only seven or eight polar orbit flights will
pass directly over" the Island shortly after takeoff. Flight
profiles indicate that the launch vehicle would be between 160,000
and 180,000 feet (48,480 to 54,500m) as it passes over the study
area (Pfeiffer, 1979, personal commun-ication). Overpressures felt
on the islands will vary widely, however, depending on the angle
of inclination chosen upon launching.

As part of the space shuttle system a splashdown area to the west
and southwest of San Miguel Island is planned for the recovery of
space shuttle booster rockets. Most. returning shuttles will
approach the study area at altitudes ranging from 80,000 to
100,000 feet (24,200 to 30,300m) along a reentry path passing.
near, and for one return orbit directly over, San Miguel Island.
Overpressures of variable intensity (1 1/2-2 pounds per square
foot) are projected to resemble aircraft sonic booms in these
cases (Pfeiffer, 1979, personal communication). The towing of
spent booster rockets by barge from Port Hueneme to Vandenberg AFB
is also envisioned and is addressed in Section E.3.d. above.

E-89

E.M. Research

Because of the exceptional abundance and condition, of marine
birds, marine mammals, fish and intertidal populations (see
Section E-2), the marine ecosystem surrounding 'the northern
Channel Islands and Santa Barbara Island provides an especially
valuable natural laboratory for investigating species interactions
with other marine life and with their environment. These natural
attributes have encouraged extensive scientific oceanographic
research by government and university groups. Many research
institutions located throughout the southern California area have
conducted (see Table E-22) or funded (see Table E-23) scientific
investigations in the area.

.E .3.g. Recr eation

Water-based recreational activities in the northern Channel
Islands and Santa Barbara Island region are pursued by three often
interrelated user groups: pleasure boaters (sail and power); SCUBA
divers and spearfishermen; and those interested in photography and
nature study (e.g., marine bird and mammal observers). Although
the dominant means of recreational access is by boat, charter
aircraft overflights also provide a form of access which appears
to be increasing in popularity (Coffin, 1979, personal communi-
cation). For a discussion of sport fishing see Section E.3.c.

The attractiveness of the northern Channel Islands as a desti-
nation for recreationists is generally on the upsurge; still there
is currently no indication that congestion among recreational
users is a problem. Natural controls upon public accessibility

E-90

Table E-22. Major research.organizations which have or are likely to
conduct marine related scientific investigations on the
coastal ocean enviroment in southern California

University of California at
Santa Cruz*
Irvine*
Berkeley*
San Diego*
los Angeles*
Santa Barbara*

Scripps.Institute (part of the University of California and.San Diego)

Santa Barbara Museum of Natural History

California State Colleges (atLongBeach and Fullerton)

California Institute of Technology

Los Angeles County Museum

Planning Research Corporation

Point Reyes Bird observatory

San Diego State College

University of Southern California*

Allan Hancock Foundation

Hubbs Seaworld in San Diego

California Department of Fish and Game

U.S. Bureau of Tand Management

National Marine Fisheries Service

National Park Service

Sea Grant Universities
L

E-91

TABLE E-23. Examples of research funding entities with potential or
demonstrated relevance to the northern Channel -Islands and
Santa Barbara Island waters.

FEDERAL GOVERNMENT

1. Department of Interior

a) U.S. Bureau of Land supports environmntal baseline studies as well
Management as special studies on hydrocarbon/heavy metal
pollution; supported sea and air surveys of
marine MaMals and seabirds in the southe=
California Sight.

b) U.S. Fish and Wild- supports research on sea otters in southern
life Service California as well as migratory birds and
endangered species.
c) National Park Service has supported research on resources of the Ownel
Islands National Monument; will Conduct biannual -
source inventories in the Channel Islands National Park.
2. Department of Commerce

a) National Marine supports research concerning marine mammals
Fisheries Service (including seals and sea lions on San MiTel),
fishery resources.and endangered marine species.
b) office of Sea Grant supports a full range of warine related research
through its system of Sea Grant colleges

c) Office of Coastal supports research and monitoring-atmarine sanct-
Zone Managarent uaries as uell as coastal management concerns

d) Office of Environ- supports a full range of oceanographic and
mental Data Service climatological data collection, analysis and
archiving functions.

3. Enviromental Protection supports studies and monitoring of pollutant
Agency levels in coastal and pelagic marine organisms
and environments.

4. National Aeronautics and supports oceanographic research utilizing tele-
Space Administration metric and remote sensing capabilities of air-
craft and satellites.

5. marine Mammal Commission supports research pertaining to conservation and
protection of marine mammls including abundance
and distribution studies, ecological studies,and
biological studies.

6. National Science Found- supports a variety of pure and applied marine
ation science and .engim projects

7. Department of Energy supports research and monitoring of marine
pollution levels in coastal and pelagic marine
organisms and environments.

8. Department of Defense
a) U.S. Air Force supporting research an the effects of the spa
shuttlets supersonic boans on marine mammal and
seabird 1ife in the northern Channel Islands.
b) Office of Naval supports bioacoustic and biomedical research on
Research marine mammals as well as other marine studies.

c) Naval undersea center supports bioacoustic research on marine mammals.
adn Other Units

STATE GOVERNMENT

1. California Department supports research concern1n; state fisheries as
of Fish and Game game species maintains sport and commercial
fishing statistics, conducts monitoring research.

2. California Coastal supports research related to coastal water resource
Commission and use management.

E-92

most notably lengthy boat travel distances from the mainland and
occasionally adverse weather conditions are matched by as yet
fairly strict landing permit controls.

Together these controls favor rather sparse activity densities.
This is not to say, however, that future recreational trends in
southern California might not alter the activity patterns around
the northern Channel Islands over the long run. Regional water-
oriented leisure demands already appear to be exceeding supplies
available along the mainland coast and Santa Catalina Island to
the south (California Department of Parks and Recreation, 1979).
Consequently, it is possible that the Islands will increasingly
function as an 'goverflow" destination for the greater southern
California region.

Another potential stimulant to the growth of water-based recrea-
tional activities is the rising popularity of the Chanhel Island
National Monument (i.e., Santa Barbara and Anacapa Islands) for
public visits. The National Park Service's (NPS) policy encour-
ages tightly-monitored visits, while at the same time cautioning
the public (in preventative fashion) against overuse. This
popularity may increase with the recent creation of the Channel
Islands National Park, which includes Santa Cruz, Santa Rosa, and
San Miguel Islands as well as Santa Barbara and Anacapa Islands.
However, the law establishing the Park states that the Park "shall
be administered on a low-intensity, limited-entry basis" and that
in recognition of the special fragility and sensitivity of the
park's resources, it is the intent of Congress that the visitor
use within the park be limited to assure negligible adverse impact
on the park resources" (P.L. 96-199). In light of this mandate,
it seems unlikely that recreation levels will rise significantly.

E-93

Most private boaters frequenting waters surrounding the Channel
Islands are either en route to activities on the islands or
engaged in activities such as diving, fishing, or casual nature
observation. A smal 1 percentage of users is comprised of
"through"- boating parties destined for other points along the
California coast. Many of these tran.sients often frequent pass-
ages separating Santa Cruz, Santa Rosa and Anacapa Islands (Figure
E-24) (U. S. Bureau of Land Management, 1979). While extensive
data on vessel types and seasonal use densities are unavailable,
it is also probable that these parties occasionally make island
stopovers, if only to seek shelter within approved overnight
mooring areas (e.g., San,Miguel's Tyler Bight and Cuyler Harbor).

Many recreationists visit the Channel Islands National Monument.
En route, *they often partake in nature observation and occasional
diving. Other boaters travel to nearshore zones merely to enjoy
the islands' scenery (from on-board) or the exhileration of a
day's rel axation at sea. In the absence of detailed boater
surveys, however, there is no way of differentiating between
levels of private passive boaters, multi-activity boaters (i.e.,
divers/nature observers),' and those solely concerned with reaching
the monument islands for other , land-based pursuits. The most
popular staging points for private vessels with destinations on or
around the northern Channel Islands are situated along the coast
between Point Conception and Point Mugu. They include Santa
Barbara, Ventura, Oxnard, Gaviota, Goleta, and Port Hueneme (U. S.
Bureau of Land Management, 1979).

E-94

Xr W

All
LEGE
:4

Seaward

Ccymonl
Routes

SAWA
&V44
CONTOUR

7 1;
-ii,2
C"do
-Ilink Pdcm UWW
MIGOL
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ALJ

6.
NAUTICAL MILES

FIQURE E-24. Recreational boating concentrations and access
routes around the northern Channel Islands and RAJO
Santa Barbara Island (U. S. Bureau of Land Manage-
ment, 1979).

Whereas private recreational boaters are apt to cruise throughout
the northern Channel Islands region and can partake of diving
and/or nature watching in innumerable@ nearshore locales, the
.majority of visitors to the Channel Monument Islands of 'Anacapa.
and Santa Barbara now arrive on commercial pay-as-you-go charters.
For example, one publicly-licensed common carrier operating out of
Ventura to Anacapa (and a few other island destinations nearby)
carries most of the total visitor traffic to the monument. Day-
long, as well as overnight, camping drop-off/pick-up arrangements,
are provided throughout the year, reaching their peak activity
season (6 trips per day) between June and September (Duthie, 1979,
p.ersonal communication). Although@aimed at conducting visitors on
guided tours of the monument islands of Anacapa and, to a lesser
extent, San Miguel and Santa Cruz, this service also facilitates
en route nature observation. Boat captains regularly seek out
gray whale pods during their northward (Jan.-March) migrations in
the Santa Barbara Channel to observe and photograph (Connelly,
1979, personal communication). In the course of approaching
Anacapa (west end) and Santa Cruz (north side), moreover, boats
regularly pass at a. safe distance from sea lion rookeries for
similar purposes. Until recently, when they were restricted by
California Department of Fish and Game's Ecological Reserve
regulations for West Anacapa, such observational forays reportedly
also included observations of brown pelican nesting grounds
(Connelly, 1979, personal communication).

While the brunt of commercial boat visits by recreationists to the
northern Channel Islands are centered upon Anacapa Island, more
recently a special permit process has also been initiated for
restricted tours (i.e., small ranger- accompanied) of San Miguel
Island,(which the NPS manages in league with the Department of the
Navy). On Santa Cruz Island, having assumed majority ownership in
late 1978, the California Nature Conservancy hopes to expand

E-96

public visits as -well, relying mostly upon commercial charter
services such as- the one currently in operation (Grumbine, 1979,
personal communication). The management plan which the National
Park Service must develop for the Channel Islands National Park
may change recreational patterns around the Islands but must by
law administer visitor access to the Park on a low-intensity,
limited entry basis (Whelen, 1980, personal communication).

Along the passive pleasure boating and nature observation, near-
shore water zones around the northern Channel Islands and Santa
Barb.ara Island are frequented by divers and spearfishing enthu-
siasts. Despite rather cold year-round water temperatures
(normally necessitating wet suits), visual clarity is of such good
quality, and protected cove shallows and kelp beds so numerous,
that both SCUBA and limited snorkeling activities thrive here.
The presence of substantial stocks of lobsters and abalone also
serves to attract many participants to this recreational use
sector (Duthie, 1970, personal communication).

As inventoried by the California Governor's Office Task Force on
the Offshore Continental Shelf, some 25 skin and SCUBA diving
sites are evident in the northern Channel Islands, including 7 off
Santa Cruz, 3 off Santa Barbara and 5 off each of Anacapa, Santa
Rosa, and San Miguel (California Office of Planning and Research,
1.977) (see Figure E-25).

Both party boaters and commercial charter operators engage in or
facilitate diving activities, but there is as yet little informa-
tion on their proportional contributions to total user demand or
quantified areal concentrations. One "open" charter boat operator
from Santa Barbara, for example, regularly transports paying SCUBA
divers to San Miguel (Wilson Rock, Richardson Rock and Prince

E-97

3W 1! a-

LEGE
"JM

Popular Div

4%
4, -
vd

-CONTOUR

F1 I_d@
F=k
C"be
k kMM
Nh 1>
MA AN
LAf
emu otim
4Q 11111@"
CWH tat"

m
1
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%

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-Id
97

FIGURE-E-25b Popular skin and SCUBA diving sites (Office of
Planning and Research, 1977).

Island), Santa Rosa (Talcott Shoals), 'and Santa Cruz (Gull Island
and Smuggler's Cove) (Duthiet 1979, personal communication). In
these areas, most dives occur well within one-quarter mile of
shore, and frequently in kelp beds. An estimated 50 percent of
these recreationists carry spear guns on board and take both
lobster, and abalone. This particular operator 'indicated few, if
any. concerns @ about user congestion, a ain highlighting the
.4 9
abundance of both open water space available in general and
quality diving sites.. Local diving clubs from communities along
the mainland coast and elsewhere generate most of this operator's
business (Duthie, 1979, personal communication).

Although not strictly marine-based, recreational flying is also a
growing leisure pastime in the Santa Barbara Channel (Coffin,
1979, personal communication). Airports such as a county facility
situated in Santa Barbara function as the primary staging points
for this activity. Presently, two charter firms' in the nearby
mainland coastal region offer offshore overflights. Nature-
watching during the gray whale's north and southward migration
season is reportedly the most popular motive (90 percent) behind
the demand for plane trips; a much smaller proportion of users
charter aircraft purely to enjoy the unique scenic vistas provided
by the offshore area's mar ine/island environment (Coffin, 1979,
personal communication).

One of the charter companies, Santa Barbara Aviation, reports that
they receive approximately 6 or 8 requests per month for flights
in and around the Channel for nature observation (Glendinning,
-1979, personal communication).

E-99

The peak season for recreational overflights lasts from April
through September; and given the evidence of widening public
interest in this activity, the frequency of charter services is
likely to increase (Coffin, 1979,.personal communication).

E-100

F. ALTERNATIVES

F.a. INTRODUCTION

Section F discusses six alternative actions for NOAA to take
Tegarding the area under consideration. The first alternative
pres ented is the possibility of not designating a sanctuary but
instead relying gn the existing system of controls. Alternative 2
is NOAA's preferred alternative, namely the designation of a
marine sanctuary with the controls set forth in the draft desig-
nation document and proposed regulations in Appendix 1. Alter-
natives 3 through 6 include several different boundary, regula-
tory, and management options. These alternatives are discussed in
comparison to the preferred alternative. Table F-1 summarizes the
boundaries and controls considered for designation alternatives 2
through 6.

F.1 STATUS QUO ALTERNATIVE

F.I.a. INTRODUCTION

An alternative to designating a marine sanctuary is to rely solely
on the State and Federal authorities currently in effect. This
section sets forth the existing controls in the area under consi-
deration and the environmental consequences of relying only on
current control s. The following section (F.l.b, Existing Manage-
ment Authorities) includes a brief description of each of the
authorities now in effect in the study area. Some readers may
prefer. to review Table F-1 and Figure F-1a which provide an

F-1

TABLE F-1. Summary of boundary, activity regulation, and management alternatives for a marine -sanctuary
designation excluding the status quo alternative.

A] ter- Oil and Gas Seabed
native Boundaries activities Vessel Disturbing marine mamma i s
Discharges alterations traffic and birds by overflights.@
2 6 nautical miles No operations on new leases. Prohibif ex- Prohibit To the extent con- Prohibit below 1000
pref.) around the northern Require best state of the cept for vessel within 2 sistent with int. feet within I mi
Channel Islands and Art oil spill contingency cooling waters, nini of the law., rohibit of the Islands, except,
Santa Barbara plans. etc. Islands. Nessell in the trade to land on the Islands
Island of carrying cargo or -and to.survey kelp beds.
servicing offshore
Installations W/in
I nmi of the Islands
.except to land.

3 6 nautical miles No operations on new leases. Same as Prohibit Require vessels 'to Prohibit below 1000
around the northern No new rigs or platforms alternative within the stay in VISS's. feet within I nmi of
Channel Islands and except on existing leases 2. sanctuary. Prohibit vessels in the Islands and below
the trade of carry- 500 feet in the
Santa Barbara entirely in the sanctuary.
Island Require best state of art Ing cargo or ser- sanctuary, except to
oil spill contingency plans. @vicing offshore land on the Islands and
installations w/in to survey kelp beds.
I nmi of the Is-
4 The entire Santa No operations on new leases Same, except Prohibit lands except to Same as alternative 2.
Barbara Channel within 6 nod of th6 Islands. within 3 mni within 2 land.
and 12 nautical Require best state of art of the mainland. nmi of the
miles around the oil spill contingency plans. Islands. Same as alternative
northern Channel No structures in VTSS's. 3.
Islands and Santa
Barbara Island.

5 3 nautical miles No operations on new leases. Same as alternative Relying on existing
beyond the terri- Require best state of art 2. authorities.
torial sea around oil spill contingency plans.
the Islands.
6 The entire No operations on new leases Same as alternative Require vessels to
Channel exclu- within 6 nmi of the Islands. .2.
ding State waters Require best state of art' -stay in VTSS's.
and 12 nautical Oil spill contingency plans.
miles around the No structures in VTSS's..
northern Channel
Islands and Santa
Barbara Island.

TABLE F-1, cont.

A] ter- Historical Fishing & Plant Research/ Hi I i tary
native firearms resources Harvesting Education Activities Management
2 Prohibit removal Rely on the Allow. Issue Allow military Monitor resources and consult with
and damage. Seek California permits for activities necessary other authorities. Establish Sanc-
listing under Department of some research for national defense tuary Information Center. Maintain-
the National Fish and Game or education to or emergency. NOAA register of research projects. Enc-
Historic Preser- and the Pacific conduct activities will consult with ourage scientific research. Promote
vation Act. fishery manage- otherwise prohi- the Department of awareness of sanctuary resources.
ment Council. bited. Defense concerning Compile an inventory and map histor-
specific activities. ical resources. U.S. Coast Guard.
National Park Service, National Marine
Fisheries Service, and CDFG will en-
force sanctuary regulations.
3 Prohibit Same Rely on CDFG Same as alter- Same as alternative Same, but establish research zones.
use, except and PFMC. native 2- 2.
for
military
-n operations.

4 Same Rely on CDFG Same Same OCZM will coordinate management by
and PF11C existing authorities and establish -a
Channel Sanctuary Management Advisory
Committee. Otherwise same as al.ter-
native 2.

Rely on PF14C. Same Same OCZM will coordinate and seek memo-
randa of understanding regarding con-
sistency with the State. The U.S.
Coast Guard, National Marine Fisheries
Service, and possibly National Park
Service will enforce sanctuary regula-
tions. NOAA will not compile an inven-
tory or map historical resources;
otherwise same as alternative 2.

Rely on PFMC. Same Same OCZM will coordinate and seek memo '
randa of understanding,regarding
consistency with the State. The
U.S. Coast Guard, National Marine
Fisheries Service, and possibly
National Park-Service, will enforce
sanctuary regulatiqns. NOAA will
not compile an inventory ormap
historical resources; otherwise
same as alternative 4.

Managed Resources management Authorities
and Activities
Federal Authorities state Authorities
AA CAA aWMM ESA ECMA MBTA MWA NIPA OCSU OPA PMR PWSA SSVS AQCA ASBS CAA I IPR FGC HCRPA OGS WQCA

Resource Protection

1. Marine Mwmuls Ews COC,. DFG DFG
NMFS
FM
2.. Marine Birds EWS FWS OCC DFG DFG
3. Fish/Shellfish NMFS DFG DM-
4. Research NPS NMF5 PnIC WRCB PFMC
5. RecreaU&@_ NPS USCG 00C
6. 111 s to H q7- -9f ;�- - - NPS DFG
cultural HCIRS JCRS

Activity Management

1. Oil and Gas
Development
-n -@-Exploration & EPA COE OOC SLC
Development
--PlatEorm EPA USGS
BIA OOC sic
Placenent CUE USGS
-Pipelines COE
BLM
OOE USCS
COE
--Water EPA WFCB OCC WFIM
Discharqes
-Air EPA USGS ARB
Di@charges ocff
2. Fishing
NKS DFG PFMC
P"C DFG
EPA EPA USCIG USCG ARB IDFG WRCP
4. Military NPS Navy Air DFG DFG
Operations Force
Research FVS
ITFr. DFG

6. Recreation NPS DFG

FIGURE F,I. Existing Federal and State management authorities as they relate to resources and activities.

TABLE F-la. Abbreviations of Authorities and Agencies

Abbreviations of Authorities

Federal

AA - Antiquities Act; 16 USCS461-469i
CAA - Cl;aw Air Act, 42 USC 557401-7642
CIA - Clean Water Act; 33 USC 551251-1376 -
ESA - Endangered Species Act; 16 USC 551531-1543
FCMA - Fishery Conservation and Management Act; 16 USC 51801-1882
MBTA - Migratory Bird Treaty Act; 16 USC 55703-711
KIPA - Marine Mammal Protection Act; 16 USC 51361-1407
HPA - National Historic Preservation Act; 16 USC SS470-470n
CCSIA - Cuter Continental Shelf-Lands Act; 43 USC SS1331-1343
CPA - oil Pollution Act of 1961; 33 USC 51001-1016
MR - Pacific Missile Range; U.S. Navy
PWSA - Ports and Watertmys Safety Act; 33 USC 51221-1227
SSVS - Space Shuttle Vehicle System; U.S. Air Force
RHA River and Harbor Act of 1899; 33 USC 403 Sec. 10
State

AOCA Air Quality Control Act; California Health and Safety Code,
39000-42708
ASBS Areas of Special Biological Significance; California Water Code
513260
CCA California Coastal Act; California Public Resources Code 527000
ER Ecological Reserves; California Fish and Came Code S1580
FOC Fish and Came Code, California Fish and Game Code, California
Administrative Code, Title 14
HCRPA - Historical and Cultural Resources Protection Act; California Public
Resources Code �5000
OGS - oil and Gas Sanctuaries; California Public Resources Code S6870
KA - Water.Quality Control Art; California Water Code 513000

Abbreviations of Agencies

Federal

BIM - Bureau of Land Management - Department of the interior
COE - Army Corps of Engineers - Department of Defense
EPA - Environmental Protection Agency
FWS - Fish and Wildlife Service - Department of the interior
HqCRS - Heritage Conservation and Recreation Service - Department of the Interior
C - Marine Mammal Commission
NJFS - National Marine Fisheries Service - Department of Commerce
NPS - National Park Service - Department of the Interior
PE`C - Pacific Fisheries Management Council; Joint Federal-State
USCG - United Sq@ates Coast Guard - Department of Transportation
USGS - United States Geological Survey - Department of the Interior

State

ARB - Air Resources Board
CCC - California Coastal Commission
DFG - Department of Fish and Came
ERC - Historic Resources Commission
PFYC - Pacific Fisheries Management Council, (Joint Federal-State-Private Body)
SLC - State Lands Commission -
WRCB - Water Resources Control Board
__36qj

F-5

overview of the -authorities in the area before proceeding to
Section F.1.c, which describes the environmental consequences of
relying on the existing regulatory structure.

F.1.b EXISTING MANAGEMENT AUTHORITIES

F.Lb.i. STATE AUTHORITIES

The State's jurisdiction in the area under consideration extends
three nmi (5.6km) miles offshore from the mean low tide line.
State authorities range in approach and scope from broad regional
management programs such. as the California Coastal Act to laws
intended to control specific threats or protect specific re-
sources. The authorities with broad. jurisdiction are described
first, followed by those addressing a specific threat or resource,
respectively.

The California Coastal Act of 1976 (CCA) (Cal. Pub. Res. Code 30000-
et seg. (the CCA)

The California Coastal Act of 1976, Cal. Pub. Res. Code 30000 et
seg. (the CCA), the foundation of the California Coastal Manage-
ment Program, establishes a comprehensive set of specific policies
for the protection of coastal resources and the management of
orderly economic development thoughout the coastal zone. The Act
defines the coastal zone as the land and water area of the State
extending seaward to the outer limit of.the State's jurisdiction,
including all offshore islands, and extending inland generally
1,000 yards from the mean high tide line. In significant coastal
estuarine, habitat and rec'reational areas it extends inland.to the

F-6

first major ridgeline or five miles.from mean high tide, whichever
is less.

Activities@ in State waters must comply with. the policies esta-
blished by the CCA. In addition, seaward of State jurisdiction,
Federal activities directly affecting the coastal zone and activi-
ties which require a Federal license or permit must be conducted
in a manner consistent with these policies to the maximum extent
practicable.

Provisions of the CCA which address activities or concerns rele-
vant to the, consideration of a marine sanctuary include:

Article 4, Section 30230, granting "special protection
to" areas and species of special biological or economic
significance and requiring uses of the marine environment
tobe carried out so as to maintain biological productivity.
Article 4, Section 30233, limiting dredging and filling in
coastal waters to situations where "there is no feasible
less environmentally damaging alternative and it is related
to specific listed purposes."
0 Article 5, Section 30240, protecting sensitive habitat areas
against "any significant disruption of habitat values" and
against impacts from adjacent development which would
Issignificantly degrade" the area.
Article 7, Section 30262, regulating oil and gas development.

The CCA establishes the California Coastal Commission (CCC) and
six temporary commissions to implement the Act granting the CCC
permit authority until such.times as local governments adopt local
coastal plans (LCP) approved by the Commission. The Southern

F-7

Central 'Coastal Commission is currently superv,ising the pre-'
paration of local coastal programs which will include the study

area.

The Local Coastal Plans for Ventura and Santa Barbara Counties
will only marginally affect Anacapa, Santa Barbara, and San Miguel
Islands, because these lands are currently owned by the Federal
government (Stanley, 1979, personal communication, and Berry,
1979, personal communication). Santa Cruz and Santa Rosa Islands,
although included in the newly created Channel Islands National
Park, will be affected by the LCPs however, since Park acquisition
of these lands will take time (Whelan, 1980a, personal communi-
cation).

In ocean areas, the California 'Coastal Commission will continue
(after approval of local coastal programs) to be the permitting
agency and will be responsible for certifying consistency for
Federal activities. Local governments, with jurisdiction over*
areas affected by OCS activity, are invited by the CCC to parti-
cipate in the public hearing(s), CCC deliberations, and to present
determinations of whether OCS activity is consistent with the
local coastal plan.

To facilitate early containment of an oil spill', the Commission
has required several lease holders (For example, Exxon on Tracts
222, 223, 230, 231, 232, and 238) to have certain oil spill
containment and cleanup equipment, beyond that required by the
USGS's OCS Order #7, on drillships or within 15 minutes of the
site at all times:

F-8

1) 1500 feet (424m) of open ocean containment boom and a boat
capable of :deploying the boom, 2) one oi.1 skimming device capable
of open. ocean use, and 3) fifteen bales of oil sorbent material,
Coastal Commission policy, for reasons of navigation safety and
environmental protection, holds the placement of. drillships in or
within 500 meters of sea lanes established by the U. S. Co ast
Guard to be inconsistent with the Coastal Act.

Finally, the California Coastal Act requires the Commission to
designate "Sensitive Coastal Resource Areas" which must then be
acted upon by the Legislature within two years. The Commission,
however, has preliminarily determined such designation 'may be
unnecessary in view of the existi,ng mechanisms available through
the local coastal planning process.

Ecolo2ical Reserves (California Fish and Game Code �1580 et Lej.,
Cal. 14 Admin. Code �630 et seq.)

The. California Department of 'Fish and Game (DFG) has established
ecological reserves in the ocean waters and tide and submerged
lands surrounding San Miguel, Santa Barbara, and Anacapa Islands
from the mean high tide line seaward 1 nmi (1.8km) (see Figure F-
2).

Within these reserves, the California Department of Fish and Game
has the authority to prohibit any activity which may harm the
resources including specifically fishing, collecting, swimming,
boating, aircraft, and public entry (California 14 Administrative
Code �630(a)). General regulations provide that "no person shall
disturb geological formations or archaeological artifacts or take

F-9

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lp
FIRRE F-2. Ecological Reserves.

or disturb any bird or nest, or eggs, thereof, or any plant,
mammal, fish, mollusk, crustacean ... or any other form of plant or
animal Tife in an ecological reserve" (California 14 Adminis-
trative Code �630 (a) (1)). These activities are, however,
permitted by the Department of Fish and Game in particular reser-
ves or in certain a reas of particular reserves pursuant to speci-
fic regulations.

Boating is permitted in the San Miguel Island Reserve, except.
between Judith Rock and Castle Rock (Figure F-3) wher 'e all boat
entry is prohibited within 300 yards (270m) of shore. However,
boats may approach the Island between Judith Rock and Castle Rock
to a distance of 100 yards (91m) , from shore during the periods
from March 15 through April 30 and October I through December 15.
Persons who have been issued permits by the DFG to take sea
urchins within the Point Bennett area or to dive for abalone may
enter the 300 yard (270m) area between Judith Rock and Castle Rock
for the purpose of fishing for abalone and sea urchins during the
same periods. The DFG may rescind permission for boats to enter
within 300 yards between Judith Rock and Castle Rock if it finds
that impairment to the marine mammals of the Island is imminent.
Boats traveling within 300 yards (270m) of the shoreline of the
Island must operate with a minimum of noise and not exceed speeds
of five miles per hour (14 California Administrative Code
�630(b)(28)(C)) (Edgerton, 1979, personal communication). Over-
night anchoring of boats, however, is permitted only at Tyler
Bight and Cuyler Harbor. Furthermore, landing is allowed only by
permit and only at the designated landing beach in Cuyler Harbor.
Access to offshore rocks and islands within the reserve is allowed
only by permit (California 14 Administrative Code �630(b)(28)(0).

F-11

I MILE BOUNDARY LIN@
H" Ty COVE

NAME COVE
"ARE Noce[

GAT COVE

300 YARDS BAY POCIt
.............
Lt NOC IR? PRINCE
SIMONTON COVE A..
ING
BOAT ANCHOR
VYL94 HARMON and LANDING
ZZLD@SED T'O
ALL ENTR@.:-*-: ... . ... ........
SAY COVE
MAY FT.

ILAII
NETT BEACH
TVLfIt
...... ..... .......
919)(T
-T .........

T
:-O-C-11 N
BOAT ANCHORI

CA 009 IT,

kilometr@9

FIQUR.E F-3. San Miguel Island Ecological Reserve

In the San Miguel Island Ecological Reserve, swimming and diving
are permitted in areas where boating is authorized (California 14
Administrative Code �630(b)(28)B)). Fishing from shore or in
areas closed to boating is prohibited. Recreational fishing from
boats is permitted in other areas of the reserve. Commercial
fishing, except using hook and line gear or pursuant to abalone,
lobster or sea urchin permits, is only allowed pursuant to a
special permit (California 14 Administrative Code �630(b)(28)(A)).

The most direct resource protection in the Anacapa Island Ecolo-
gical Reserve is a brown pelican fledging area estab lished off the
north shore of West Anacapa Island (see Figure F-4). Entry i s
prohibited during breeding season, March 1 to May 31 (California
14 Administrative Code �630(b)(31)(E)).

Boating, swimming and diving are otherwise allowed within the
Anacapa Island Reserve (California 14 Administrative Code
�630(b)(31)(A)). No nets or traps may be used anywhere within 450
ft (135m) of the island. Harvesting of kelp is prohibited within
the reserve except by special permit.

'A "natural area" has been established off the north shore of East
Anacapa Island from which it is unlawful to take any native plant,
fish, wildlife, aquatic organism or disturb any natural geological
feature (California 14 Administrative Code �630(b)(31)(B)). Zones
have been established off the southeast shore of the West Anacapa
Island and the north shore of Middle Anacapa Island where taking
of invertebrates from the mean high tide line to a depth of 2D ft
(6.1m) is prohibited (California 14 Administrative Code
�630(b)(31)(C)) (see Figure F-4). Commercial and sportfishing are

F-13

--CLOSED TO ALL ENTRY NATURAL AF
CH I - MAY 31 WING OF Af
.. ......... OR GEOLOGH
20 FATHOMS
120 FT.)

..........
,6
..........................................
0 FATHOMS
......................... .............
...............
.............
:::;::: (60 F T.)
............. ...............................................
............
........... ... ..................
20 FOOT
............. INVERTEBRATE
CLOSURE
(DAY U311
............... ...........A
EAST
FISH

CAI ROCK
20 FOOT
INVERTEBRATE
CLOSURE

I MILE BOUNDARY LINE 0 S

F!qUR.E F-4. Anacapa Island Ecological Reserve

allowed elsewhere in the reserve.

Boating, swimming, sport and commercial fishing,, and diving are
generally' permitted within the Santa Barbara Ecological Reserve
(Califoitnia 14 Administrative Code �630(b)(32)(A)). Within an
area off, the east shore of the Island, extending from the mean
high tide line to a depth of 20 ft (6.1m) no invertebrates may be
taken and no nets or traps may be used (California 14 Adminis-
trative Code �630(b.)(32)(B) and (C) (see Figure F-5).

DFG personnel and facilities for enforcement of ecological reserve
regulations consist of ten wardens and four boats. In addition to
the ecological reserves, these personnel and facilities are
responsible for enforcement of all of the Fish and Game Code and
regulations for San Luis Obispo, Santa Barbara, and Ventura
Counties. The four boats are: a 50-foot patrol boat with a small
skiff on board, a 20-foot skiff, and a 17-foot skiff. The level
of enforcement effort is dependent to a large extent on unpre-
dictable weather conditions. Trips are made daily, weather
conditions permitting, to Anacapa Island with the 50-foot patrol
boat, the only boat large enough to cross the Santa Barbara
Channel, manned by two wardens. Whenever possible, the patrol
boat will then move on to other islands. Occasionally, stakeouts
wil.1 be made for specific targets when violations are suspected
(Martin, 1979, personal, communication).

A cooperative agreement was established between the Department of
Fish and Game and the National Park Service (NPS) for the enforce-
ment of California Fish and Game regulations in these reserves.
The agreement was initiated to fully utilize the on-site enforce-
ment capabilities of the Park Service, in terms of both personnel
and faci-lities. Pursuant to this agreement, the seven Park

F-15

1/2

Miles
X@ I MILE BOUNDARY LINE
Kilometres

ARCH VT.

Oft. DEPTH
INVERTEBRATE
CLOSURE, NO
WEAST2111 PT. NETS OR TRAPS

.... ......... . ......
...........
.............

......... . . . ...
... . ... ......
..............
.. ........ ..
....... ...
. . ......
. .. ......... ....

...........

.........

X
. . . . . . . . . . . .

13LAND

FIQURE F-5. Santa garbara Island Ecological Reserv'e.

F-16

Service rangers associated with the Channel Islands National
Monument were deputized as Department of Fish and Game-wardens and
conduct patrol operations within the reserves. Regular joint
training meetings have been conducted by the DFG to keep NPS
personnel abreast of changes in DFG regulations and policy (Co-
operative Agreement between California Department of Fish and Game
and U. S. National Park Service, 10/78; Johnson, 1979, personal
communication; and Martin, 1979, personal communication). This
cooperative agreement will probably be extended and expanded in
light of the creation of the Channel Islands National Park
(Whelen, 1980b, personal communication).

Fish and Game Code (Chapter 14, Administrative Code)

The Cal.ifornia Department of Fish and Game, under the Fish and
Game Code (and Chapter 14 of the Administrative Code), regulates,
and manages a wide variety of activities affecting the fish and
game resources found in the land and water areas under State
jurisdiction. Specific Department of Fish and Game programs,
other than ecological reserves (discussed above), of relevance to
the study area include management of sport and commercial fishing,
and plant harvesting, protection of endangered species, protection
of migratory birds, . coordination of the oil spill contigency
plans, and restriction of overflights.

--Sport and commercia 1 fishing and kelp harvesting management
(California Fish and Game Code �7100 et se

F-17

Jhe De partment of Fish and Game regulates sport fishing through
license and bag limit systems. A sport fishing license is requir-
ed for the taking and possession of fish for any non-commercial
purpose (California Fish and Game Code �7100). Sport fishing of
spiny lobster is restricted to collection by hoop nets or hand,
and clam, mollusk, and crustacean collection are limited to the
period between one-half hour before sunrise to one-half hour after
sunset (California Fish and Game Code �7256, 7290, and 7332). The
Code does not specify bag limits for these resources.

Commercial -fishing is also governed by a licensing system. Ev ery
person who operates or assists in using any boat or gear to take
fish for profit must procure a license (California Fish and Game
Code �7580); party boat operators must get special licenses
(California Fish and Game Code �7920 et @Lej.). Vessels used in
commercial fishing operations must also carry a Department of Fish
and Game registration number (California Fish and Game Code
�7880). Fishing reports, described in Sections 8010 et must
be supplied by buyers, processors, and anyone else who receives
fish from fishermen. These reports form the basis of Department
of Fish and Game statistics used in formulating fishery management
policies. Species near the northern Channel Islands and Santa
Barbara are subject to the seasonal, size, and catch restrictions
listed in Table F-2.

Under the Submerged Lands Act of 1953 (43 USC �130(c)), California
has jurisdiction over kelp within state waters as a seabed re-
source. Generally, a license is required to harvest kelp for
profit (California Fish and Game Code �6650). As with other
commercial fisheries, a record book must be maintained (California
Fish and Game Code �6652).

F-13

TABLE F-2. Catch restrictions for species of commerical fish
in the northern Channel Islands area (references
are. to the California, Fish And Game Code).

Catch restrictions for species of commercial fish.in the northern
Channel Islands area (references are to the California Fish and
Game Code)

Sardines Catch limited to 20,000 tons (or other 0FG
allowance) of the spawning population
(Section 8150.7).

Anchovies Restricted according to the PFMC plan.,

Lobster Fishery open between the first Wednesday in
October and the first Wednesday after March
15 (Section 8251). Lobster permit required
(Section 8254.7). Size restrictions exist
(Section 8252).

Crab Fishery op en between the second Tuesday in
November and June 30th (Section 8276).

Abalones Fishery open each month but February and
August (Section 8300). Abalone permit re-
quired (Section 8306). Size limits exist
(Section 8304). Abalone diving permits
exist and are limited in number (Sections
8306.1 and 8306.4). Black abalone taking
within one mile of Santa Cruz and Anacapa
Islands prohibited with some exceptions
(Sections 8307.5, 8307.6).

Clams, Molluscs Fishery open year rou6d (.Sections 8340 and
8341).

Scallops Illegal to sell or purchase (Section 8345).

Saltwater and Kelp bass, sand bass, and spotted bass may
Anadromous fish be sold (Section 8372); yellowfin and blue-
fin tuna may be taken at any time (Section
8374); bluefin tuna must exceed 7 1/2 lbs
to be marketed (Section 8375); albacore and
skipjack may be taken any time (Section 8376
and 8378); white seabass, barracuda, and
yellowtail not less than 28 in. in length may
be taken by hook and line any time (Section
8382).

Mackerel Catch limited as stock is enhanced (Section
8388.3).

California halibut May be taken any time (Section 8391).

Swordfish May be taken any time (Section 8394).

F-19

Through a cooperative agreement recently reached between the
Department of Fish and Game and the National Marine Fisheries
Service, officials of both agencies may enforce each other's laws
(see discussion below).

--Endangered species (California Fish and.Game Code �2050 et @ej.).

The California Department of Fish and Game maintains a list of.
rare and endangered species. It is unlawful within the state to
take or possess any listed species. "Taking" is defined (Cali-
fornia Fish and Game Code �2050 et se ) in a manner analogous to
the interpetation under the Federal act (see below). Listed
species found in the study area are the Guadalupe fur seal, the
California brown pelican, the California least tern, the light-
footed clapper rail, and the Belding's savannah sparrow.

--Protection of Migratory Birds (California Fish and Game Code �355
et @ej. and 3500 et seq.

In accordance with the Migratory Bird Treaty Act, California has
provided protection for migratory birds, their nests and eggs by
fixing areas, seaso ns, and hours plus bag and possession limits by
species for migratory game birds (California Fish and Game Code
�356). The peregrine falcon, brown pelican, California black rail
and clapper rail, California least tern, light-footed clapper rail
and southern bald eagle (California Fish and Game Code �3511) have
all been accorded "fully protected" status, which protects these
birds from taking except as authorized for scientific research.

F-20

--Oil Spill Contingency Plans (California Fish and Game Code �5650 et

@Lej-

It is unlawful to "deposit or permit any petroleum to pass into
the waters of the State" (California Fish and Game Code �5650).
The California Department of Fish and Game together with an
Interagency Committee coordinates the State's oil spill contin-
gency plan. Because Federal law preempts State regulation of oil
spill cleanup operations, the State's role is that of observer,
assistant, and advisor--w.ith the important exception that the
State. has veto power over the use of chemical agents in State
waters. In practice, State Department of Fish and Game personnel:
1) investigate all spills in State waters and many spills in
Federal waters; 2) monitor, assist, and advise Federal and indus-
try cleanup operations; and 3) maintain liaison between various
government agencies and industry.

--Overflights (California Fish and Game Code �10501.5)

The California Department of Fish and Game prohibits overflights
below 1000 ft (305m) over San Miguel, Santa Barbara, and Anacapa
Islands.

Water Quality Control Act (California Water Code �13300 et M.)

The Porter-Cologne Water Quality Control Act is designed to
enhance and maintain water quality in the waters under the juris-
diction of the State. The State Water Resources Control Board and
the nine regional water quality control boards have primary

F-21

authority for regulating water quality in California.

The Water Quality Control Plan, for Ocean, Waters of California
(1978), which sets standards for water quality characteristics for
ocean waters within State jurisdiction, places particular emphasis
on maintaining water quality in Areas of Special BiologicaI
Significance (ASBSs). The State Water Resources Control Board has
designated ASBSs in the waters around the northern Channel Islands
and Santa Barbara Island to a distance of 1 nmi (1.8km) offshore
or to the 300 ft (90m) isobath, whichever is greater.

To be classified as an ASBS, an area of ocean water must be
considered to contain biological communities of such extraordinary
value that no risk of change in their environments resulting from
human activities can be considered acceptable (California Water
Resources Control Board, 1976). Dischargers must ensure that
their wastes are discharged a sufficient distance from designated
ASBSs to assure that the natural water quality conditions within
the area are not affected. This is accomplish ed H. e., adminis-
tered) by Regional Water Quality Control Boards (RWQCBs) which,
via a permit procedure, set waste discharge restrictions upon:

a) elevated temperature wastes;

b) discrete, point source sewage. or industrial
process wastes; and

c) non-point source wastes such as, but not limited
to, storm water runoff, silt, and urban runoff.

F-22

ASBS designations have no impact on vessel wastes, dredging
control, or dredge spoil deposition because the California Ocean
PI an, of w hich ASBS's are a part is not applicable to ' those
activities.

RWQCBs are responsible for integrating ASBS designations into
their area-wide basin plans which outline waste discharge prohi-
bitions and restriction. A routine ASBS reconnaissance survey
conducted by the SWRCB provides RWQBs with detailed resource
information as.well as data on existing or future activities apt
to threaten their environmental quality. ASBS surveillance and
monitoring is the responsibility of RWQCB� which ensure compliance
with discharge regulations in the broader context of basin-wide
enforcement. Should either an actual discharge violation or a
threat therefore become apparent, the regional board is empowered
with specific administrative procedures and remedies to enforce
compliance (see California Water Code, Section 13300).

Though the primary intent of the designation is to protect marine
life from waste water discharges, petroleum discharges into an
ASBS are also covered (California Water Resources Control Board,
1976). Several. study stations for the worldwide Mussel Watch
Program, coordinated domestically by, the U. S. Environmental
Protection Agency, have been established within these ASBSs.
Mussel watch stations are located in the shallow waters off Santa
Barbara, Santa Cruz, and Anacapa Islands and two stations each
have been established off San Miguel and Santa Rosa Island (Cali-
fornia Water Resources Control Board, Annual Report, 1978). This
program involves periodic tissue analysis of collected mussels as
indicators of pollution levels. The establishment of these
stations provides no special management of or protection for the
research value of the se sites, but does provide some information

F-23

for monitoring purposes

Regulation of Offshore Oil and Gas Development Activities,
Cunningham-Shell Tidelands Act, as Am6nded(California Public
Resources Code �6850 et lei.)'

Leasing of state submerged lands (extending from the mean high
tide line seaward, 3 nmi (5.5km) for oil and gas development
activities and regulation of these activities is the responsi-
bility of the State Lands Commission. Both the State Lands
Commission and the Coastal,Commission regulate these activities to
ensure that they proceed safely and that marine resources are
adequately protected. In this regard, the State Lands Commission
enforces requirements similar to those of the United States
Geological Survey concerning blowout prevention, drilling prac-
tices, production procedures, pollution control , and oil spill
prevention, containment and cleanup (see below).

In order to protect sensitive resource areas, the California State
Legislature may designate Oil and Gas Sanctuaries in which petro-
leum development is prohibited within submerged lands. Oi I and
gas sanctuaries have been established in the waters-around the
northern Channel Islands. The sanctuaries extend from the mean
high tide line seaward three nautical miles (California Public
Resources Code S6871). Although leasing is normally excluded from
the sanctuaries, if underlying oil and gas deposits might be
drained by wells located on adjacent Federal lands, thereby
threatening the State's proprietary interest in the resource, the
State Lands Commission may open up the affected sanctuary areas
for a drainage sale. The waters around Santa Barbara Island have
not been declared an oil and gas sanctuary.

F-24

Control of Oil Discharges from Vessels (California Harbors and Naviga-
tion Code 5133)

The California Harbors and Navigation Code generally applies to
the activities of vessels operating in state waters. One of its
purposes is to prevent the activities of vessels from adversely
affecting the marine environment. To achieve this purpose., the
discharge of oil from any vessel in the state's navigable waters
is prohibited except in cases of "unavoidable accident, collision,
or stranding" (California Harbors and Navigation Code �M).

Any person who intentionally or negl-igently causes or permits any
oil to be deposited in the waters of the State is liable for
cleanup costs and subject to a $6,000 civil penalty (California
Harbors and Navigation Code �151).

Air Resources (California Health and Safety Code �3900 et lei.).

The California Air Resources Board (ARB) is charged with the
maintenance and enhancement of the ambient air quality of the
State. The ARB has set air quality standards designed to meet
National Ambient Air Quality Standards and delegated their imple-
mentation to local Air Pollution Control Districts (APCOs). The
northern Channel Islands and Santa Barbara Island are located
partly within the Santa Barbara County Air Pollution Control
District and partly within the Ventura County Air Pollution
District.

F-25

Generally, offshore oil and gas development facilities located
.within state waters must both obtain a permit from the appropriate
APCD and meet ARB emission standards.

Emissions from tankers which dock at onshore facilities located in
California are also considered together with those of the related
onshore facility. As with,onshore oil and gas development facili-
ties, the total emissions l,evel of the tanker and the related
onshore facility must meet standards set by the ARB as implemented
by the appropriate APCD. Unlike other offshore facilities,
however, neither the A RB nor an APCD has authority to issue
permits solely for tanker emissions AStamey. 1979, personal
communication)

Preservation of Historic Resources (California Public Resources Code
�5020.4)

Preservation of representative and unique archaeological,
paleontological, and historical sites in the land and water areas
of the State is the responsibility of the California Historical
Resources Commission. The Commission evaluates and makes recom-
mendations to the State Historic Preservation Officer on nomi-
nations to the National Register pursuant to the National Historic
Preservation Act (see below). The Commission also recommends
State regist.ration of sites as landmarks and points of interest to
the Public Resources Department which is responsible for main-
tenance of registered sites (California Public Resources Code
S5020.4). Registration as a point of interest qualifies a site
only for the placement of informational signs. Landmarks, along
with properties listed on the National Register and city or county

F-26

registers or inventories., become eligible for "qualified historic
property" status for which special protection may be afforded by
the Commission (,California Public Resources Code. �5031). At
present, no sites within the study,area have been registered as
either landmarks or points of interest (Berry, 1979, personal
communication).

Underwater State Parks

In order. to protect special marine resources and water-based
recreational values in ocean waters within State jurisdiction and
to expand coastal park units beyond the water's edge, the Cali-
fornia Department of Parks and Recreation has established an
Underwater Parks Program (California Department of Parks and
Recreation, 1979). As a result of a recently initiated underwater
.park study, underwater parks are being considered near San Miguel,
Santa Cruz and Santa Rosa Islands (Kelly, 1979, personal communi-
cation), but at present, there are no underwater parks in the
study area.

F.1.b.ii FEDERAL AUTHORITIES

Except where specified otherwise, Federal authorities apply
throughout the entire area under consideration. The major ex-
ceptions are management of petroleum and fishery resources, which
fall under State Jurisdiction within three nautical miles (5.6km)
of the shore.

F-27

Fishery Conservation and Management Act (FCMA) (16 USC �1801 et

The FCMA provides for the conservation and management of all
fishery resources in the zone between three and two hundred
nautical miles (5.6-370km) offshore. In the Channel Islands area,
this authority is vested in the Pacific Fishery Management Council
(PFMC). The National Marine Fisheries Service (NMFS) is charged
with establishing guidelines for and approving those fishery
management plans (FMPs) prepared by the PFMC for selected fisher-
ies within its jurisdiction. These plans will determine the
levels of commercial and, sport fishing consistent with achieving
and maintaining the optimum yield of each fishery.

The PFMC has already completed a man'agement plan for anchovy and
is currently preparing plans for groundfish and jack mackerel--all
of which are found in the study area. The final anchovy FMP
(Pacific Fishery* Management Council, 1978a) proposes several
fishing area closures, but none in the study area. Four different
fishing seasons were proposed in the plan, some of which would
prohibit fishing during important times of the life cycle of
marine mammals and birds. A final decision on the preferred
season is pending. The draft FMPs for groundfish (PFMC, 1978b)
and jack mackerel (PFMC, 1979) address limitations on catch but do
not consider closures. Although the FMP for groundfish is only in
a draft stage, it does appear possible that the final FMP may aim
to protect intertidal spawning grounds and kelp bed habitats such
as those found in the study area, which are vital to the survival
of lingcod, bocaccio, and numerous rockfish.

F-28

The FCMA also applies to marine plant. life. Therefore, the
harvesting of kelp beds in Federal waters, such as Osborn Bank,
south of Santa Barbara Island, could be regulated. No such pl an
is now being developed.

Benthic continental shelf fishery resources located outside state
waters, such as abalone, lobster, crabs, sea urchins, and corals,
are within the jurisdiction of the PFMC, the NMFS and the Bureau
of Land Management (BLM) pursuant to the Outer Continental Shelf
Lands Act (see below).

Endangered Species Act (16 UCS S�1531-1543)

The Federal endangered species program provides protection for
listed species of marine mammal .s, birds, and fish in both State
and Federal waters. The U. S. Fish and Wildlife Service (FWS) and
NMFS determines which species need protection; FWS maintains a
list of endangered and threatened species. The most significant
protection provided by the Endangered Species Act is,the prohi-
bition on taking. The term "take" is defined quite broadly to
mean "harrass, harm, pursue, hunt, shoot, wound, kill, trap,
.capture, or collect or attempt to engage in such conduct" (16 USC
�1532(14)). Fish and Wildlife Service regulations interpret the
term harm to include significant environmental modification or
degradation and acts which annoy listed species to such an extent
as to significantly disrupt essential behavior patterns (50 CFR
17.3).

F-29

The Endangered Species Act also provides, for the protection of
endangered species and their habitat by establishing a consul-
tation process designed to insure that projects authorized, funded
or carried out by Federal agencies do not jeopardize the continued
existence of endangered of threatened species, or "result in the
.destruction or modification of habitat of such species which is.
determined by the Secretary (of the Interior or Commerce) to be
critical" (16 USC �1536.).' Critical habitat areas for endangered
species are designated by the U. S. Fish and Wildlife Service and
the.National Marine Fisheries Service. The 1978 amendments to the
'Act establish a Cabinet level committee authorized to exempt
Federal agencies from compliance with a determination by the
Secretary of the Interior through an elaborate review process
should an irreconcilable conflict occur. No critical habitat has
been designated in the study area at this time.

Several species of marine mammals found in the waters around the
northern Channel Islands and Santa Barbara Island are listed as
endangered or threatened species. These include: 1) sea otter,
2) gray whale, 3) fin whale, and 4) humpback whale. The blue
whale, sei whale, and sperm whale, all of which have been sighted
elsewhere in the Southern California Bight, bu t not immediately
around the northern Channel Islands, are also listed as endangered
species.

Species of birds listed under the Endangered Species Act are found
in the waters around the northern Channel Islands including: 1)
California brown pelican, 2) light-footed clapper rail, and 3)
California black rail, (44 CRF 3636, 1/17/79).

F-30

Marine Mammal Protection Act (MMPA) (1 6 USC �1361 et

The MMPA applies to any person subject to the jurisdiction of the
United States in both State and , International waters. It is
designed to protect all species of marine mammals. While the MMPA
allows States to petition for the return of m anagement responsi-
bility over marine mammals, California has done so only with
regard to the sea otter and that petition was later withdrawn.

Provisions of the Act are implemented by the Department of Com-
merce, National Marine Fisheries Service (NMFS), which is respon-
sible for whales, porpoises, and pinnipeds other than the walrus,
the Department of Interior, U. S. Fish and Wildlife Service (FWS),
which is responsible for all other marine mammals. An independent
Federal body, the Marine Mammal Commission, advises these imple-
menting agencies and sponsors relevant scientific research. The
primary management features of the Act ;include: (1) a moratori . um
on the "tak.ing" of marine mammals; (2) the development of a
management approach designed to achieve an "optimum sustainable
population" (OSP) for all species or population stocks of marine
mammals; and (3) protection of populations determined to be
"depleted".

The MMPA defines "take" quite broadly to include "harass", hunt,
capture, or kill any marine mammal" or to attempt to engage in
such conduct (16 U.S.C. Sec. 1362(13), emphasis added). The term
has been interpreted to encompass both intentional and negligent
acts, including the operation of motor boats, which result in the
disturbing or molesting of marine mammals (50 CFR 18.4; 50 CFR
216.3).

F-31

The MMIPA provides for limited ' exceptions to the moratorium.
Pursu ant to these exemptions, marine mammals in the Channel
Islands area may be taken for scientific research, for public
display, and incidental to commercial fishing operations, under
specifically authorized permits. Similarly, stranded or debili-
tated marine mammals may be taken for the protection and welfare
of the marine mammal or for the protection of the public health
and welfare.

The Secretaries of the Interior and Commerce may also waive the
moratorium on taking for particular species or populations of
marine mammals under their jurisdiction provided that the species
or population being considered is at or above its determined
optimum sustainable population. No such waiver, however, has been
granted concerning any marine mammal found in the area under
consider'ation.

Secondly, the Act directs officials to seek "an optimum sustain-
able population (of -marine mammals)" (16 USC �1361(6)). Optimum
sustainable population (OSP) is defined to mean "the number of
animals which will result in the maximum productivity of the
population or species keeping in mind the carrying capacity of the
habitat and health of the ecosystem of which they form a consti-
tuent element" (16 USC �1352(9)).

Marine mammil species whose population is determined to be deplet-
ed receive additional protection (16 USC �1362). During the
moratorium no permit may be issued for the taking of a marine
mammal determined to be depleted unless the taking is for scienti-
fic research purposes. Seven species of marine mammals in or near
the study area (the fin whale, the humpback whale, the gray whale,
the blue whale, the southern population of sea otter, the sperm

F-32

whale, and the sei whale), are treated as "aepleted" based on
their listing as endangered or threatened species under the
Endangered Species Act.

Migratory Bird Treaty Act (MBTA) (16 USC 5�703 et @@J

In the northern Channel Islands area, hunting for migratory birds
other than species of ducks, geese, coots, gallinules, and doves
is generally prohibited throughout the year, pursuant to the
Migratory Bird Treaty Act which implements international conven-
tions with Great Britain and Japan. Each convention establishes a
It close season" during which no hunting is permitted, which for
migratory birds other than game birds is year round. The essen-
tial provision of the Act makes it unlawful except as permitted by
regulations "to hunt,. take, capture ... any migratory bird, any
part, nest or egg" of any bird protected by the Convention (16 USC
�703). The California Department of Fish and Game has supple-
mented this authority with its own regulations (see Fish and Game
Code discussion, above).

Clean Water Act (.CWA) (33 USC �1751 et

It is the goal of the CWA to restore and maintain the chemical,
physical, and biological integrity of the nation's waters. Waters
in the territorial sea, the contiguous zone, and in the ocean
beyond are subject to varying requirements under the CWA.,

F-33

The CWA's chief mechanism for preventing and reducing water
pollution is the National Pollutant Discharge Elinimation System
(NPOES), administered by the Environmental Protection. Agency
(EPA). Under the NPDES program, a permit is required for the
discharge of any pollutant from A point source into navigable
waters (which include State waters, the contiguous zone, and the
ocean). Within California State waters, EPA has delegated NPDES
permitting authority to the State government.

Since oil, and gas development resulting from Federal lease sales
will occur outside State waters, an NPDES permit from EPA will be
required for discharges associated with this activity. EPA's
decision to grant a NPDES permit for offshore oil and gas develop-
ments is based primarily on the effluent guidelines shown in Table
F-3 (40 CFR �435). Other conditions beyond these guidelines can,
however, be imposed by the Regional Administrator on a case-by-
case basis. For instance, special conditions for NPDES permits
have been applied to several leases from OCS Sale No. 35 in the
vicinity of Tanner and Cortes Banks, a hard bank community south-
west of the northern Channel Islands. To protect the bank re-
sources, discharges of drilling mud are not allowed over the
banks.

The CWA prohibits the discharge of oil and hazardous substances in
such quantities as may be harmful (33 USC �1321(b) (3)), except
discharges outside the territorial sea permitted by the Inter-
national Convention for the Prevention of Pollution of the Sea by
Oil, 1954 (see Oil Pollution Act below). When such discharges do
take place, the National Contingency Plan (NCP) for the removal of
oil and hazardous substance discharges (33 USC �1321(c); Executive
Order 11735, Aug. 3, 1973), which is designed to minimize the

F-34

TABLE EPA Effluent Guidelines and Standards for Far Of fshore*
oil and Gas Extraction Facilities (40 CFR Pt'435).

Effluent limitations

Oil and Grease
Pollutant Maximum for Average of Resi dual
parameter any I d, daily values chlorine, mini-
waste source milligram for 30 consecu- mum for any 1
per liter tiVe days shall d, milligram
not exceed, per liter
milli-gram
per liter

Produced Water-!- 72 48 NA,
Deck Drainage ------ No discharge. No discharge NA
of'free oil of free oil
Drilling muds ------ (1) NA
Drill cuttings---- (1) NA
Well treatment---- (1) NA
Sanitary: 2-
M10 ------------- NA NA I
1191M3 ------------ NA NA NA
Domestid ---------- NA, NA NA
Produced sand ------ - (1) NA

No-discharge of free oil.
.2Minimum of 1 mg/l and maintained as close to this concentration as
possible.
.3 There shall be no floating solids as a result of the discharge of
these wastes.

NOTE: MIO means facilities continously manned by ten (10) of more
persons. M91M means facilities continously manned by nine (9)
or less persons or intermittently manned by any number of per-
sons*

beyond 3 nmi.

F-35

impacts on marine resources, will take effect. The Coast Guard,
in cooperation with EPA, administers the, Plan, which applies to
all discharges of oil in the contiguous zone and to activities
under the OCSLA. As a result of a memorandum of understanding
between the Secretaries of Transportation and the Interior,
however, the OSGS has exclusive authority to institute measures to
abate the source of pollution (United States Departments of the
Interior and Transportation, Memorandum of Understanding,
(8/16/71)). The NCP establishes the organizational. framework
whereby oil spills are to be cleaned up. To carry out the
national plan, regional plans have been established; the Coast
Guard has issued such a plan for Federal Region 9 which encom-
passes the northern Channel Islands and Santa Barbara Island.
Under the plan, Coast Guard personnel are to investigate all
reported offshore spills, notify the party responsible (if known)
of his obligation to clean up the spill, and supervise the cleanup
operation. The Coast Guard retains final authority over the
procedures and equipment used in the cleanup. If the party
responsible for the spill does not promptly begin cleanup opera-
tions, the Coast Guard can hire private organizations.

Permits from the Army Corps of Engineers, which are based on EPA-
developed guidelines, are required prior to filling actions,
discharging dredged materials within three miles of shore (33 USC
�1344), or the transportation of dredged material for the purpose
of dumping it into ocean waters (33 USC �1413) (see discussion of
the Ocean Dumping Act below.)

Finally, the CWA requires noncommercial craft to comply with
marine sanitation regulations issued by EPA and enforced by the
Coast Guard (33 USC �1322).

F-36

Ports and Waterways Safety Act, as amended (PWSA) (33 USC �1221)

The Ports and Waterways Safety Act (PWSA), as amended by the Port
and Tanker Safety Act of 1978, is designed to promote navigation
and vessel safety and the protection of the marine environment.
The PWSA applies both in State waters and in high seas out to 200
nmi (370km).'

The PWSA authorizes the U. S. Coast Guard to establish vessel
traffic services and systems for ports, harbors and other waters
subject to congested vessel traffic. In the Santa Barbara
Channel, the U. S. Coast Guard has established a Traffic Separa-
tion Scheme (TSS) consisting of two one-mile wide vessel traffic
lanes, with a two-mile separation zone.

The lanes are designed to prevent vessel collisions by separating
vessels going in opposite directions. The TSS has been officially
recognized by the Intergovernmental Maritime Consultative Organi-
zation (IMCO), and appears as recommended traffic routes on all
navigation charts of the area.

The TSS, which applies to commercial ships other than fishing
vessels, is violated when a ve ssel is in a designated lane but
moving in the wrong direction. Violators are subject to flag
state enforcement if their violation occurs outside the three mile

territorial sea. If a violation occurs within the territorial
sea, the U. S. may take enforcement action. The use of the TSS as
established is mandatory for vessels proceeding to and from the
Los Angeles/Long Beach area.when the vessel is in the vicinity of,

F-37

and traveling in the general direction of, the TSS. Al 1vessel s
not using a TSS should avoid it by as wide a margin as possible.
Outside the traffic lanes, vessels may proceed. in any direction
consistent with good seamanship.

In addition to vessel traffic control, the Coast Guard regulates
other navigation and shipping activities related to vessel design,
.construction, and operation designed to minimize the likelihood of
an accident and reduce vessel source pollution.

The 1978 Amendments establish a comprehensive program for regul-
ating the design, construction, operation, equipping, and manning
of all tankers using U. S. ports to transfer oil and hazardous
materials. These requirements are, for the most part, in agree-
ment with protocols passed in 1978 to the International Convention
for the Prevention of Pollution from Ships, 1973, and the Inter-
national Convention on Safety of Life at Sea, 1974 (33 USC �1221).

The,1978 Amendments also require the U.S.C.G. to conduct a nation-
wide study on the need for Port Access Routes (PARs) and to
designate such routes as necessary to reconcile competing uses and
protect marine resources. If a PAR is established in the sanc-
tuary study area, the Secretary of Transportation, through the
Coast Guard, could make its use mandatory by all vessels pro-
ceeding to or from the Ports of Los Angeles and Long Beach via the
Santa Barbara Channel. The PAR study results may reveal that the
existing TSS is inappropriate and dictate a modification of its
location. The PAR study is actively considering all of the
various uses of the waters, including marine sanctuaries, which
may be affected by the designation of a PAR. A notice of proposed
rule making incorporating the recommendations made in the study is
scheduled for publication in the Federal Register in July 1980.

F-38

The USCG is also vested with the primary responsibility for
maintaining boater safety, including the tasks of conducting
@routine vessel inspections and coordinating rescue operations.

Oil Pollution Act of 1961 (33 USC S�1001-1016)

The Oil Pollution Act of 1961 (which implements the International
Convention for the Prevention of Pollution of the Sea by Oil of
1954) regulates discharges of oil or oily mixtures from. vessels
with the exception of tankers of less than 150 gross tons and
other vessels of less than 500 gross tons. With the e.xc eption of
discharges from machinery space bilges, tankers subject to the act
may not discharge oil, or oily mixtures unless they are 50 nmi
(93km) from the nearest land and. the total quantity of oil dis,-
charged does not exceed 1/15,000 of the total cargo capacity.
Discharges from other vessels regulated by the act, and discharges
from the machinery bilges of tankers, must be made as far as
practicable from land and may not have an oil content of more than
100 parts per million. In addition to the above requirements, a
discharge by any vessel regulated by the act must be made while
the vessel is en route and the instantaneous discharge rate must
not exceed sixty liters per mile.

Clean Air Act (42 USC �7401 et se
in.)

The Clean Air Act (CAA) sets general guidelines and minimal air
quality standards on a nationwide basis in order to protect and
enhance the quality of the nation's air resources. States are
responsible for developing. comprehensive plans for all regions
within their boundaries. Thus, as noted above, discharges of air

F-39

pollutants within California State waters are subject to the
control of the California Air Resources Board.

Beyond State waters, -EPA Region IX, relying on an EPA Office. of
General Counsel's opinion, has asserted that the new source and
prevention of significant deterioration (PSD) provisions of the
CAA apply to new sources on the OCS that can adversely affect air
quality over the United States (EPA Office of General Counsel
Opinion (4/18/78)). These regulations would supplement DOI OCS.
atr quality regulations. The new source and PSD provisions apply
only to stationary sources which emit, or could emit, at least 100
tons per year of any air pollutant. Exxon's platform Hondo in the
Santa Ynez Unit north of the northern Channel Islands (which
includes an oil processing plant) is an examp le of such a major
facility near the sanctuary study area.

Outer Continental Shelf'Lands Act (43 USC �1331 et seg.)

The Outer Continental Shelf Lands Act, as amended in 1978 (OCSLA),
establishes Federal jurisdiction over the mineral resources of the
Outer Continental Shelf (OCS) beyond three nmi (5..6km) and gives
the Secretary of Interior responsibility for managing OCS mineral
exploration and development. The Secretary's responsibility has
been delegated to two bureaus within the Department: the Bureau of
Land Management (BLM) and the U. S. Geological Survey (USGS).

BLM has overall responsibility for leasing OCS lands. In the
Santa Barbara Channel, lease sales have been held in 1966, 1968,
1975 (Sale #35), and 1979 (Sale #48).

F-40

In unique or special areas, the BLM' may impose special lease
stipulations designed to protect the specific geological and
biological resources found in those areas. These stipulations may
vary from lease tract to lease tract and sale to sale.

In the FEIS on Sale #48 (U. S. BLM, 1979), BLM has recommended
seven lease stipulations (see Appendix 5), three of which are of
particular importance to resource protection.

Stipulation Number 3 concerns the protection of cultural re-
sources. if surveys indicate. the possibility of a,cultural
resource, the lessee shall: (1) locate all structures so that they
will not adversely affect the resource or (2) establish to the
satisfaction of the U. S. Geological Survey Area Supervisor either
that no adverse effects will result from the operation or that the
potential cultural resource suggested by the survey does not
exist. Stipulation No. 5 requires prevention, to the maximum
extent possible, of harm to newly discovered areas of special
biological interest including: (1) areas containing rare eco-
systems; (2) areas of abundant numbers and/or high diversity of
species; (3) areas containing species of limited regional distri-
bution; (4) areas critical to the life cycle of species; and (5)
areas which are protected by fishery management plans as singu-
larly important to a species (U.S. Bureau of Land Management,
1979). Stipulation No. 4, which only applies to tracts 001-108*
(see Figur6s E-19 and E-20), in the Santa Barbara Channel, con-
cerns protection of commercial trawl grounds from subsea comple-
tion systems and pipelines.

F-41

The USGS is charged with approving plans for exploratory drilling
and development and supervi.sing OCS operations. Several types of
regulatory authority are used by USGS in carrying out the latter
responsibility. These include enforcement of regulations pursuant
to the OCSLA (30 CFR Part 250) and the stipulations applicable to
particular leases discussed above. . In addition, OCS Orders have
been issued by the USGS to supplement regulations in particular
regions. Twelve such Orders have been issued for the Pacific
region and three more are under review (see Appendix 6). These
Orders apply to various aspects of the day-to-day drilling and
production operation, including:, (1) marking of platforms and
structures; (2) general drilling well procedures; (3) testing of
blowout preventers; (4) charatteristics and use of drilling muds;
(5) plugging and abandonment of wells; (6) contingency plans; (7)
oil spill pollu tion equipment; (8) oil spill reports; (9) sub-
surface safety devices; (10) pollutfon and waste disposal; and
(11) design and maintenance of oil and gas pipelines.

The USGS also issues Notices to Lessees and Operators when clari-
fications, corrections, or additions to OCS Orders and Regulations
are necessary. These notices have the same status as. OCS Orders
and Regulations and are used to keep lessees and operators inform-
ed of USGS's requirements (see Appendix 6).

*Note that tracts 088-108 were withdrawn by the Secretary of
.the Interior from Sale #48 (U.S. Department of Interior,1979).

F-42

Certain provision-s of the 1978 OCSLA Amendments are of importance.
If the Secretary of -the Interior determines that continued OCS
operation threatens 11 serious, irreparable, or immediate harm or
damage to life, including fish and other marine life" or the "the
marine, coastal or human environment, such operations may be
suspended (16 USC W34 (c)(1)). In addition, if it is found that
regul atio n s, lease provisions, or exploration and development
plans, are violated by the lessee, the lease may be cancelled and
forfeited (16 USC �1334 M).

Finally, the DOI, through the USGS, is developing regulations to
control air emissions occurring on the OCS that significantly
affect a State's air quality. , According to Proposed Rule 30 CFR
Part 250 (43 Fed. Reg. 27449 (5/10/79)), activities on the OCS
will not be approved if they prevent any State from achieving or
mainta*ining national ambient air quality standards (NAAQSs) or if
they will cause significant deterioration of onshore air quali ty.
The DOI proposes to require lessees to include in their explor-
ation, development, and production plans specific information
concerning emissions and their effects on coastal areas.

Other agencies within DOI-including the FWS, NPS, and HCRS--are
consulted on various potential impacts from OCS development
including necessary stipulations pursuant to Secretarial Order No.
2974 of Auaust, 1978.

In addition to DOI, both the Army Corps of Engineers (COE) and the
U. S. Coast Guard (USCG) have some responsibility over OCS mineral
development. COE is responsible for ensuring, through a permit
system, that OCS structures including pipelines, platforms, drill
ships, and semi-submersibles do not obstruct navigation or
national security (43 USC $1333 (M. USCG ensures that struc-

F-43

tures on the OCS are properly marked (43 USC �1333 (e)).

Marine Protection, Research, and Sanctuaries Act (33 USC S�14101-1444)

Title I of the Marine Protection, Research and Sanctuaries Act
(MPRSA), also known as the Ocean Dumping Act, regulates the
dumping of materials into the territorial sea (i.e., State
waters), The contiguous zone and the ocean beyond. EPA regulates,
through the issuance of permits, the dumping of all materials
except dredged materials; COE exercises authority over the dumping
of dredged materials.

Five dredge material disposal sites have been established in the
Southern California Bight, with the closest one to the Channel
Islands being near Port Hueneme, about 16.6km (9 nmi) from Anacapa
Island. No ocean dumping of non-dredged materials has occurred in
the Bight since 1972. Prior to 1972, munitions, toxic wastes, and
radioactive materials were dumped in the vicinity of the Channel
Islands, but more than 18.5km (10 nmi) from the Islands. The
nearest disposal site for drill muds and cuttings under consider-
ation currently by EPA is located at 320 55N, 1190 17'W, over 40
nmi (74km) beyond the proposed sanctuary.

Fish and Wildlife Coordination Act (16 USC 661-667e)

The Fish and Wildlife Coordination Act authorizes the Secretaries
of Commerce and the Interior to cooperate with Federal, State,
public, and private agencies to conserve and develop fish and
wildlife resources and their habitats and directs that Federal

F-44

agencies conducting or licensing any project' that impounds,
diverts, channels or otherwise controls or modifies any body of
water shall consult with the appropriate Secretary and the head of
any State agency exercising administration over the resources.
Reports received are made an integral part: of the, administrative
record.

National Historic Preservation Act (16 USC �470)

The National Historic Preservation Act (16 USC �470) allthorizes
the Secretary of the Interior to maintain a national register of
"districts, sites, buildings, structures, and objects significant
in American history, architecture, archaeology, and culture".
Sites have been listed on the National Register which include or
are composed entirely of ocean waters and submerged lands within
state waters or on the-Outer Continental Shelf (Lebovich, 1979
personal communication). No sites in the area under consideration
are listed on the National Register at the present time.

Any Federal agency conducting, licensing, or assisting an under-
taking which may affect a site listed on the National Register
must provide the Advisory Council on Historic Preservation a
reasonable opportunity to comment on the action (16 USC �470f).
The criterion applied by the Council is whether the undertaking
will change the quality of the site's historic architectural,
archaeological or cultural character (36 CFR �800).

National Parks and Recreation Act of 1978, as amended (P.L. 96-199)

Channel Islands National Pa rk

F-45

The National Parks and Recreationa 1 Act of .1978, as amended in
1980 established the Channel.Islands National Park, which includes
the northern Channel Islands and Santa Barbara Island and the

waters within one nautical mile of the Islands. The Park
Service's jurisdiction in the water area of the Park is adminis-
trative rather than regulatory. The statute further prohibits the
acquisition by the Secretary of the Interior of any lands, waters,.
or interests within. the Park currently owned by the State of
California. No provisions of the statute shall affect the rights
and jurisdiction of the State of California within the Park,
including the submerged lands and waters within the Park bound-
aries.

The Secretary of the Interior must devleop a natural resources
study report for the Park in cooperation with the Secretary of
Commerce and the State of California within two years of the
enactment of this Act. Within three years of the Act, the Secre-
tary of the Interior shall prepare a comprehensive general manage-
ment plan for the Park, which will take into account recreational
and other human use of the Islands. The law directs the Secretary
of the Interior to manage the Park on a low-intensity, limited
entry basis.

The 1980 amendments to the National Parks and Recreation Act
deauthorize the Channel Islands National Monument, which was
established pursuant to the Antiquities Act by Presidential
Proclamation No. 2281 in 1938 (52 Stat. 1541).

F-46

Under these previous authorities, the National Park Service (NPS)
had responsibility for managing the Channel Islands National
Monument which included Anacapa and Santa Barbara Islands. Until
May of 1978, the, National Monument also included the waters
surrounding the two islands out to one mile (63 Stat. 1258
(2/9/49)). Authority over these submerged l'ands was returned to
the State in United States v. California (11 ERC 1651 (1978)).

The NPS Statement for Management for the National -Monument de's-
cribed a 1 and cl assi f i catio ry scheme creati ng Natural - Zo nes whi ch
are to remain largely unaltered by human activity. Most impor-
tantly, West Anacapa Island was designated an "Environmental
Protection Subzone," for the protection of the Brown Pelican, and
East Anacapa and the Arch Rock Group are "Outstanding Natural
Features Subzones" (National Park Service, 1976). The Statement
for Management for San Miguel and Prince Islands established
Natural Zones similar to those designated in the Monument (NPS,
1978).

Of greatest relevance to the resources of the study area have been
NPS management policies concerning visiting. Except for boat
access via certain areas off San Miguel Island where entry is
restricted by the Navy (see below), the NPS controls visitor
access to San Miguel, Anacapa, and Santa Barbara Islands as well
as the activities of visitors. Prohibition of or restrictions on
visitor ingress and egress to and from certain parts of the
isl.ands managed by the NPS tend to discourage other activities
which could harm the marine resources found in the waters adjacent
to those areas. Such activities include boat anchoring, fishing
with nets, swimming, diving, and collecting of artifacts. In
addition, restrictions on visitor access and the activities of
visitors protect the living marine resources of the study area,

F-47

most importantly marine mammals and birds, by preventing 'potential
di sturb ance. Most important in this regard is,the Environmental
Protection' Subzone established on West Anacapa Island for the
protection of the Brown Pelican rookery (NPS, 1976).

Visits to the islands managed by the NPS generally have been
controlled by a permit system, through which the number of visi-
tors, length of stay, and time of visit may be restricted. Severe
restrictions are place d on visits to West Anacapa to protect the
Brown Pelican rookery there. Policies for the other Anacapas and
Santa Barbara are considerably more liberal. Anacapa Island
receives the most visitors (Whelen, 1979, personal communication).
Under the newly created Channel Islands Park, visitor use must be.
.limited 1 to assure negligible adverse impact on Park resources
(P.L., 96-199).

Visitation levels at San Miguel are limited by restrictions on
access imposed by DFG, the Navy, and the NPS and the lack of
facilities on the Island. Enforcement responsibilities of the
Park Service have been carried out by seven rangers. Two boats, a
40 foot patrol boat and a 20 foot skiff are utilized for patrols
in marine areas (Johnson, 1979, personal communication). The Park
has just acquired a new 55 foot boat, which will be manned by one
ranger and one deck hand (Whelen, 1980a, personal communication).

U. S. Navy

The U. S. Navy conducts numerous military operations in and over
the waters offshore of southern California. Various portions of
the study area are within military districts operated by the Navy:
the northern Channel Islands are within the Pacific Missile Range;

F-48

the waters south of Santa Cruz Island are part of an Acoustic
Range Facility; and Santa Barbara Island is located in the south-
west corner of a Fleet Operating Area and is also just north of
the Santa Barbara Island Training Area. The Pacific Missle Test
Center at Point Mugu schedules control of the Navy operating areas
in the vicinity of the Channel Islands. Each week, the U. S.
Coast Guard publishes a "Local Notice to Mariners", which projects
the use of the military operating areas.

The Navy routinely conducts bombing practice and missile discrilmi-
nation operations in the airspace over the waters just south of
San Miguel Island. A Naval Danger Zone has been established which
extends 3 nmi (5.5km) seaward of the eastern half of San Miguel
Island. ' In this zone, the Navy permits nonmilitary uses, includ-
ing recreational use, only when the area is not being used for
military operations. Bombing practice runs take place in this
zone approximately 200 times a year. Because of the short notice
and intermittent nature of these exercises, long range planning of
recreational activities in the -zone will be difficult; the Navy
does, however, attempt to provide some advance notification
through the use of signs and map designations. The Navy retains
the right to escort boaters and other recreational ists violating
the zone away from the target area.

Although the Navy owns San Miguel Island, the National Park
Service, by agreement with the Navy, administers the Island
proper. By this agreement, the Navy has relinquished all autho-
rity to manage the resources of the Island and surrounding waters,
except within the Naval Danger Zone discussed above. The Navy has
agreed to attempt to conduct its operations in a manner which will
cause the least impact to Island resources. The sites selected
for and frequency of operations reflect this policy.

F-49

U. S. Ai r Force

The Air Force will regulate the Space Shuttle Vehicle System which
is to operate out of the Vandenberg Air Force Base in. Santa.
Barbara County. The Air Force is currently conducting a study to
determine the impacts - on the Island faun a, particularly marine
birds and mammals, of the supersonic boom acompanying the flight
of the shuttle.

F.l.c. Environmental Consequences

Maintaining the status quo and failing to designate a marine
sanctuary in the vicinity of the northern Channel Isl ands and
Santa Barbara Island, will eliminate the potential for positive
management of this rich marine area. In the absence of a sanc-
tuary, there will be less ecosystem research, no new education or
public awareness programs directed at users of the area, and no
institutional mechanism to focus on long term planning and co-
ordination issues for this particularly valuable geographic area.

There is no management system to aid in ensuring that the area's
research value and potential can be maximized over the long term.
While a variety of organizations conduct research in the waters
around the northern Channel Islands and Santa Barbara Island, no
agency serves to coordinate research projects to insure that
regional information needs are addressed in a timely and adequate

manner.

F-50

Similarly, no agency, or group conducts a systematic scientific
monitoring program to follow the conditions and fluctuations in
population levels of marine birds, fish stocks, or marine@ mammals,
or the water quality in general. While it provided general.
information on the Southern California Bight for OCS Sale #48,
BLM's baseline monitoring program has been narrowed to focus
primarily on questions affecting decision making in the OCS
leasing process (DOI, 1978). The.area's potential to serve as an
ecologic baseline indicator of regional environmental quality
conditions is underutilized. Thus a mechanism for monitoring and
evaluating. the long term adequacy of environmental protection
efforts and decisions affecting these resources does not currently
exist.

Presently,' 11 Federal, 7 State, and a multitude of regional and
local government agencies are vested with some regulatory autho-
rity over certain activities within the area. These authorities
provide a considerable degree of protection for marine resources
in general; the Channel Islands National Park and the Ecological
Reserves around San Miguel, Santa Barbara, and Anacapa Islands
protect the resources within those areas in particular. In
general, however, each of the statutes described above and the
agencies administering them are directed at a single purpose,
region or activity. No entity looks to the welfare of all the
living resources or the ecosystem of this marine area. Cumulative
impacts on the resources, arising from various activities subject
to the jurisdiction of separate-agencies, may escape the attention
of any agency.

F-51

The extraordinary diversity of natural resources concentrated in
the waters around the northern Channel Islands and Santa Barbara
Island deserves additional attention beyond that provided by the
present institutional structure. For instance, the resource
protection afforded by the Channel Islands National Park is aimed
primarily at the land based resources of the northern Channel
Islands and Santa Barbara Island, and the ecological reserves
discussed above include only the extremenearshore zone, providing
no buffer against outside activities.

Although certain uses of the area do not now seriously threaten
resource quality here, they could have more significant impact if
and when activity intensities grow. The current multitude of
regulatory authorities, many of which have different objectives
and jurisdictions, may not be able to respond on the basis of
ecosystem issues to future activities. Furthermore, some agencies
suffer from limited enforcement resources. Because these waters
contain so many valuable resources which in turn support so many
benificial uses, they require the special acknowledgement and
study possible in a marine sanctuary to ensure that they are used
and preserved in the future as effectively as possible.

Some particular problems which may arise if the present institu-
tional and regulatory structure continues to control activities in
the absence of the proposed sanctuary are discussed below.

F-52

Habitat and Species Protec.t.io n

The Marine'Mammal Protection Act (MMPA) and the Endangered Species
Act (ESA) prohibit the "taking" of marine mammals and threatened
,or endangered species, including marine species. The Migratory
Bird Treaty Act prohibits the hunting of seabirds. The term
"taking" -has been interpreted broadly by the administering agen-
cies, so that the ESA and MMPA provide considerable protection.
However, the potential threats to marine mammals and endangered
species range from direct injuriesto a specific animal or popula-
tion to indirect or cumulative degradation of habitat, and neither
the MMPA nor the ESA address cumulative or indirect degradation of
habitat. Section 7(a) of the ESA does provide protection against
actions which jeopardize endangered species or their critical
habitats, but this section applies only to activities authorized,
funded or carried out by Federal agencies, not to private or State
actions. There is no expl ic it provision -for designation or
protection of the habitat of marine mammals under the MMPA. This
is particularly significant because of the small number of prime
habitats remaining in and around the study area.

The California DFG, through the establishment of Ecological
Reserves, has the ability to protect exceptional marine habitats
in territorial waters. Reserves have been established in rela-
tively small yet sensitive areas off San Miguel, Anacapa, and
Santa Barbara Islands. While the Ecological Reserves protect
particularly important breeding grounds and haul-out areas, marine
mammals and seabirds (and the resources they feed on) are them-
selves dynamic entities and normally utilize areas much larger
than these designated protection zones.

F-53

As, discussed in section F.1-b-, the California DFG has only three
boats to enforce all the' California Fish and -Game regulations
applicable to the Channel Islands and along the mainland counties
of San Luis Obispo, Santa Barbara, and Ventura. These regulations
concern not only Ecological. Reserves, but also commercial and
sport fishing, endangered species, and migratory birds. Because
of the wide geographic expanse which must. be covered and the
.relatively small enforcement staff at hand to do so, the enforce-
ment capabilities of the DFG appear somewhat strained.

To provide additional enforcement, the National Park Service (NPS)
rangers have assisted the DFG in enforcing California Fish and
Game regulations in the waters within I nmi (1.8km) of Santa
Barbara, Anacapa, and San Miguel Isl.ands. This relationship has
been formalized (since 1978) in a cooperative agreement between
the DFG and the, NPS. However, this additional enforcement assis-
tance is only provided within 1 nmi (1.8km) of the three islands.
In addition, NPS enforcement capabilities are also rather limited-
-eight rangers, one 41-foot and one newl y acquired patrol boat
available for observing all three islands, and one small boat on
each island (Johnson, 1979, personal communication; Whelen, 1980a,
personal communication). Most of their attention is devoted to
the land-based resources of the islands, however. As a result of
the new national park status of the Islands and surrounding
waters, this cooperative agreement may be expanded (Whelen, 1980a,
personal communication).

F-54

Petroleum Development

The State of California has designated the State submerged lands
around the Northern Channel Islands, except Santa Barbara Island,
as an oil and gas sanctuary withdrawing the area from leasing
except as may be necessary for drainage sales. Under the Cali-
fornia Coastal Zone Management Program, the State comprehensively
controls oil and gas activities involving State lands and waters
around Santa Barbara. even though this area has not been declared
an oil and gas sanctuary. Regulations governing protection of
marine resources, oil spill control equipment, and the siting of
development adjacent to environmentally sensitive areas may
prohibit or severely restrict any such activities in this area.

Beyond State waters, California's coastal policies, applied
through Federal consistency, also may prohibit or restrict hydro-
carbon exploration, development, or production activities. Fo r
instance, the California Coastal Commission's concurrrence with
Chevron's certification of consistency of its application for a
U.S. Geological Survey Exploratory Well Drilling Permit on Tract
245 states that a production platform within 6 nautical mil es of
the Islands would hot be found consistent with the program. There
has been extremely limited experience in the application of
consistency to hydrocarbon activities within the 6 nmi area,
therefore, predicting a pattern of decisions is somewhat sp ecu-
lative.

.Under the OCSLA, the Secretary of the Interior can comprehensively
regulate activities associated, with oil and gas leasing. While
the Secretary is responsible for protecting the marine environ-
ment, this responsibility is exercised in the con text of carrying
out the primary objective of the OCSLA to expedite OCS oil and gas
development'. Of course, this responsibility is carried out in

F-55

consultation and coordination with other affected agencies and
parties as mandated by general environmental protection statutes
such as the National Environmental Policy Act and the Fish and
Wildlife Coordination Act. Nevertheless, these priorities and
objectives could result in administrative decisions on leasing,
exploration, or development that differ from those which would be
reached where preservation of marine resources has first priority.

The actual leasing decisions reached by the Secretary of the
Interior in the past indicate both the sensitivity of DOI to
environmental concerns and the primacy of the development mission
which is required by the OCSLA. For example, DOI withdrew 24
tracts within 6 nmi of the northern Channel Islands and Santa
Barbara Island from Lease Sale #48 (see Figure E-22). in -Lease
Sale #35 and sales held in 1966 and 68, however, several (34)
tracts within 6 nmi of the Islands were leased, despite recom-
mendations by the National Park Service and the U.S. Fish and
Wildlife Service that these Islands were particularly sensitive
and should be shielded from petroleum development. DOI also
tentatively included some waters within 6 nmi of the northern
Channel Islands and Santa Barbara Island in its call for nomi-
nations for Lease Sale #68, to be held in June 1982.

Development of hydrocarbon resources within 6 nmi of the Channel
Islands poses certain risks. In its HIS on Lease Sale #48, DOI
estimated the likelihood of a major oil spill reaching sensitive
areas within 30 days to be 100 percent (see Table F-7). This
estimate assumed that certain tracts within 6 nmi of the Islands
would be offered in the Lease Sale, although the estimate did not
account for the significant reduction in estimated economically
recoverable resources. Nor did it take the possibility of future
lease sales in account.

F-56

In addition, the USGS's OCS Order 47 (pertaining to pollution
prevention and control) and BLM'.s present stipulations, in tandem,
do not require certain oil spill containment equipment onsite (see
Section F.2.b.1). The presence of adequate onsite equipment, in
particular a boat to deploy-the equipment , is especially important
near the Islands because of the rather long time required for the
local oil spill cooperative @(Clean Seas, Inc.) to respond
to a spill in the more distant parts of the Channel or on the
seaward side of the Islands and because of the need to contain
spills, if they do occur, before they reach nearshore resources.
The California Coastal Commission has required additional contin-.
gency equipment on Exxon's tracts 222, 223, 230, 231, 232, and 238
under the Federal consistency provision of' the Coastal Zone
Management Act. However, development proposals are reviewed for
Federal consistency on a case-by-case basis, and there are no
guarantees that the State will impose the same requirements on all
the tracts near the Islands.

The potential impacts of oil and,gas expl oration and exploitation
are discussed in Section F.2.b.l. below.

Discharges

Numerous laws and regulations apply to the disposal of waste in
the marine environment. However, most decisions are made on a
case-by-case basis, which provides less certainty of protection
than would a designation of no discharge areas. Certain gaps
remain in the regulatory framework.

F-57

Al 1 discharges within the territorial sea are subject to EPA
requirements under the Clean Water Act (CWA) (administered by the
State) (or COE requirements under the River and 'Harbors Act for
discharges that might obstruct navigation). The EPA requ irements
are designed to protect marine resources, but may not effectively
prevent overboard dis posal of trash from ships and similar pro-
blems.

Beyond the territorial sea, the discharge of oil and listed
hazardous substances is generally prohibited, but, at present,
tank washing and bilge pumping are permitted for tankers of Aess
than 150.,dead weight tons (dwt) and other vessels of less than 500
dwt. EPA approval is needed for ocean dumpingbut the regulations
do not apply to discharges of substances that were not transported
from the U.S. with the intention of dumping, i.e., casual litter.
The CWA does not apply to discharges from vessels beyond the
territorial sea. For actual dumping, EPA regulations take the
ecological productivity and sensitivity of an area into consid-
eration, but again on a case-by-case basis.

Ocean dumping, municipal outfalls, and dredge spoil disposal can
adversely affect benthic biota and introduce toxic substances into
the marine environment which may have sublethal effects on fish,
bird, and mammal resources. In addition to reducing overall water
quality and lessening the aesthetic appeal of the area, the
discharge of litter may harm marine mammals that sometimes ingest
or become entangled in such litter (Morrell, 1979 personal commu-
nication).

F-58

Vessel Traffic and Overflights

Under the existing regulatory system c ommercial vessels including
.tankers and other bulk carriers can transit anywhere in the
proposed sanctuary, even within the very sensitive nearshore areas
where they could cause visual and acoustical disturbances, create
an increased danger of pollution, both from operational discharges
and from accidental groundings, and may occasionally strike marine
mammals.

Generally, compliance with the Coast Guard's Traffic Separation
Scheme has been good, although utilization is not mandatory. The
Coast Guard has commenced studying the possibility of designating
a port access route (PAR) in the Channel under the authority of
the Port and Tanker Safety Act. Once designated, a PAR would be
mandatory for vessels proceeding to or from Los Angeles. However,
its designation would not necessarily preclude all uindes'irable
traffic around- and between the Islands, since these vessels would
not be traveling in the direction of the PAR.

The present system for regulating the overflight of aircraft does
not appear to protect fully nearshore marine mammal and seabird
popul ations. While the existing DFG prohibition on overflights
below 1000 feet (305m) over the land areas of Santa Barbara,
Anacapa, and San Miguel Islands has lessened visual and acoustic
disturbance to island resources, protection does not extend to
Santa Cruz and Santa Rosa Island, or the nearshore water habitat
of marine mammals and seabirds surrounding the five islands.
Persistent low altitude overflights in nearshore waters can
severely disrupt various marine mammal and seabird behavior

F-59

patterns, particularly those of breeding and nesting.

Historic and Cultural Resources

Disturbing underwater archaeological artifacts (tee Table E-12) is
now prohibited only in the ec.plogica I reserves around the San
Miguel, Anacapa, and Santa Barbara Islands. Beyond. the 1 nmi
(1.8KM) boundary of these reserves,' as well as around Santa Cruz
and Santa Rosa- Islands, no regulation currently exists to prevent
the disturbance or collection of these resources, except in
relation to oil and gas development (see Appendix 5, Notice to
Lessees No. 77-3). Although statutory authority exists for the
recognition of underwater historic sites, no sites in the waters,
around the northern Channel Islands have been nominated to the
Federal Register of Historic Places.

F-60

F.2. ALTERNATIVE 2 the preferred alternative

a. Introduction

NOAA proposes the designation of a marine sanctuary to preserve
the special ecological, conservation, recreational, and aesthetic
values of the waters surrounding the northern Channel Islands and
Santa Barbara Island. This sanctuary would extend 6 nmi (11.1km)
seaward from the,mean high watermark of the following islands and
offshore rocks: San Miguel Island, Santa Cruz Island, Sa nta Rosa
Island, Anacapa Island, Santa Barbara Island, Richardson Rock, and
Castle Rock (see Figure F-6). The sanctuary waters would include
the entire'3 nmi (5.6km) of California State waters plus an equal
distance of Federal waters. The coordinates are set forth in
Appendix 1.

This area possesses an exceptionally rich and diverse assemblage
of living marine resources and offers a variety of benefits to
human users ranging from commercial and recreational fishing
opportunities to the less tangible benefits of studying and
finding beauty in a relatively unspoiled wilderness area Isee
Section E, affected environment).

The 6-nmi (11.1km) boundary includes significant sections of
several important resource areas; e.g., Santa Rosa Plateau and
Santa Rosa Cortes Ridge North extending south of San Miguel, Santa
Rosa, and Santa Cruz Islands, as well as the Santa Cruz-Catalina
Ridge which forms an underwater connection between the Anacapa
Islands and Santa Barbara Island. This boundary also coincides
roughly with the 250-ft. '(about 80m) bathymetric contour, and

F-61

7'.
LEGEN

Seaward
State A

Seaward
Marine

SANTA
BAR
BARj
CONTOUR

R@k

SAN Mr.UEL
ISLA@@@ ANACAPA
aAHM CFW

sum %am
19L&ND 1 14"
ni
% ak R
CAU

;j L I [A
N

FIGURE F-6. Boundaries for alternative 2--the preferred marine
sanctuary. a RA16

roughly delineates the island shelf and slope contours. it
thereby encompasses the most intense concentration of resources in
the area under consideration. As noted in Section E.2, many' of
the marine mammal, seabird, fish and invertebrate species consi-
dered to be important in the ecosystem tend to concentrate in the
waters over the shallow island shelves. Populations of certain
species (e.g., pinnipeds and birds) are, in fact, among the
highest in the world'here.

Marine sanctuary designation would allow NOAA to: (1) support
research -on and monitoring of the resources; (2) enhance public
awareness of the value of the area; (3) aid in coordinating
actions by existing authorities; (4) formulate long-range plans
and respond to currently unforeseen threats which might arise; and
(5) regulate activities which either pose the risk of causing
significant damage or may have greater impacts as use of the area
increases. Formal acknowledgement of the species value of these
waters may discourage excessive new development, focus attention
on the natural resources of the area under consideration and
direct special attention to future development plans.

b. Management

Management of the proposed marine sanctuary would integrate and
utilize all aspects of the program to provide for the preservation
of the special values of this marine area. These program ele-
ments-- research, education, coordination, long-term planning, and
necessary regulation, including effective enforcement--will be the
subject of a formal management plan (MP) for the proposed sanc-
tuary which will be developed in detail, if a sanctuary is desig-
nated. The MP will describe management goals and objectives
tailored to the specific resources and uses characterizing the
area.

F-63

area.

The goals and objectives will provide a framework for conserving
resources and integrating sound public uses, and since they are
the ends, rather than the means, they allow for alternative
planning strategies. Management goals are long term and open
ended and will focus on desired conditions, rather than on parti-
cular facilities and actions. Objectives of each goal represent
short-term measurable steps toward achievement of the goal.

The MP for this proposed sanctuary will be developed and imple-
mented by NOAA and an onsite manager. NOAA anticipates delegating
onsite management to an existing authority'in order to benefit
from the expertise of agencies familiar with the area. A logical
candidate for the task of sanctuary manager is the-California
Department of Fish and Game (DFG). DFG has submitted a proposal
to NOAA which involves working with NOAA to make recommendations
concerning elements of the MP for the area should it become a
sanctuary. In addition, DFG proposes to investigate methods for
State-Federal interagency cooperation on marine sanctuary manage-
ment, particularly with the National Park Service. The new
Channel Islands National Park includes the waters within 1 nmi of
the northern Channel Islands and Santa Barbara Island making
cooperation a crucial element for both programs.

If DFG assumes the position of onsite sanctuary manager, one
possible mechanism for continuing interagency cooperation would be
formation of an advisory board consisting of representatives from
agencies and interest groups such as the National Park Service,
the U.S. Coast Guard, the National Marine Fisheries Service, the
California Coastal Commission, the State Lands Commission, the
California Department of Parks and Recreation; the Santa Barbara

F-64

Commercial Fisherman, local citizen associations and industry.

Based on available information, the proposed sanctuary would have
the following goals:

1. To preserve a unique and strategically located part
of the California outer continental shelf where marine
life, geological formations, and ocean currents combine.
to form an outstanding marine ecosystem by ensuring
that human uses and activities do not: (a) degrade
intertidal habitats or foraging, resting, migratory
or other open wat,er habitat areas of value to marine
birds and mammals; or (b) otherwise threaten the con-
tinued health, stability, diversity, or numbers of
seabirds or marine mammal populations using sanctuary
waters;

2. To encourage scientific research consistent with
Objective I on the significant resources of the area
which will.contribute to understanding of ecological
relationships and to the resolution of management and
regulatory issues;

@3. To enhance public awareness of sanctuary resources,by
ensuring adequate interpretive and educational services.

During the planning 'process leading to the MP, quantifiable
objectives will be formulated for each goal. These may include,
but are not limited to objectives in research, education, coordi-
nation, and enforcement.

F-65

--Education and Research

The proposed'mari ne sanctuary will develop and enhance education
and research programs. An integral component of that effort would
be the establishment of the Sanctuary Information Center, which
would also serve as administrative headquarters for the sanctuary.
The Sanctuary Information Center would be primarily a research and
education facility intended to serve as a respository for scienti-
fic literature and information on resources and activities in the
sanctuary, as well as visitor orientation and education materials
such as slides, brochures, and displays. The visitor information
would help tourists and recreationists more fully appreciate and
enjoy the resources of the sanctuary; at th e same time, it would
apprise them both of regulations and the need for protecting
marine resources.

The general information coll.ection would include both technical
and nontechnical reference material for public use in studying
sanctuary resources and would collectively provide as complete and
detailed a description of sanctuary conditions and use over time
as possible. To further this end, the sanctuary managers would
ask researchers to notify the Sanctuary Information Center of
projects in the sanctuary and to submit reports of their research.
This notification process would result in a master listing of
research projects conducted 'from the time of designation. This
listing would be continually updated and kept open for public use.

A notification procedure should ensure that research parties are
not only familiar with existing regulatory controls but also that
they better understand which resources are particularly suscept-
ible to adverse research-related impacts. In addition, the master
listing could: (1) provide a record of scientific investigations
which might provide important man 'agement information; (2) contri-
bute to efforts to monitor. use patterns within the sanctuary; (3)

F-66

be of assistance in identifying areas of research not receiving
adequate attention; and (4) insure that sanctuary managers are
aware of relevant area-specific studies and literature. Finally,
this notification- process.,could provide both, sanctuary managers
and researchers with a record of individuals- and groups who have
firsthand experience with the area's resources. This would
provide a valuable tool for coordinating research efforts and
encouraging multidisciplinary analyses.

The notification of research projects in the sanctuary and- the
submission,of reports on the research to the Sanctuary. Informati.on
Center would constitute a slight inconvenience for researchers.
However, in turn, researchers could benefit from the resources of
the Information Center'and, unless the research would require a
permit (see above in this section) notification would not impose
any delay.

The compilation of technical documents in the Sanctuary Informa-
tion Center will provide a baseline of site-specific information
which. would help long-term environmental analysis and encourage
further research within sanctuary boundaries.

In addition to providing information and coordination to attract
researchers to the proposed marine sanctuary, the sanctuary
manager will directly encourage research by sponsoring monitoring
programs, providing partial funding for research, and encouraging
researchers and funding organizations to conduct or support
studies in the sanctuary. The monitoring effort will focus on the
overall health of the natural resources of the area as well as the
level and effects of human activities. The information gained
from such monitoring efforts and other research projects should
enable NOAA to manage and regulate the sanctuary more effectively,

F-67

and to assist other applicable authorities in, carrying out their
responsibilities.

Another research objective may be to map and compile an inventory
of historical resources. As part of BLM's baseline study of the
Southern California Bight, Science Applications, Inc. (1978),
listed the known wrecks around the northern Channel Islands.
Although some archaeological research has been conducted on.the
Islands themselves, no research or mapping has been done on the
possible historical artifacts in the waters around the Islands.

--Coordination

The proposed sanctuary will aid coordination between all the
authorities in the sanctuary, and will particularly stress consi-
deration of the special value of the marine sanctuary's living
resources in the formulation of policies affecting the area. The
greater understanding of sanctuary resources and the effects of
human use gained as. a result of the research and monitoring
described above will enable NOAA to provide valuable assistance to
other authorities in the area in deciding upon the best level of
protection for the natural resources of the sanctuary.

--E,nforcement

NOAA presently envisions a State-Federal cooperative enforcement
system for any regulations adopted, involving the California
Department of Fish and Game (DFG), the U.S. Coast Guard, the
National Marine Fisheries Service (NMFS), and the National Park
Service (NPS). Since the 'proposed sanctuary would include both

F,68

State and Federal waters, close coordination between State and
Federal authorities would be required. As DFG develops management
recommendations, it will consult with Federal authorities on the
mechanics of cooperative management. Naturally, agencies such as
the U.S. Coast Guard are concerned with the 'extent of additional
responsibilities. and the resources wh ich will be available to
fulfill any new duties. As noted in Section F.1.b, the DFG and
the NMFS have a cooperative agreement to - enforce the Fishery
Conservation and Management. Act; the DFG and the NPS have a
cooperative agreement concerning MPS enforcement of California
Fish and Game regulations within I nmi (1.8km) of San Miguel ,
Santa Barbara, and Anacapa Islands. A new cooperative agreement,
modeled after. the existing ones, could be adopted within the
sanctuary which would allow the DFG, NMFS, and NPS within 1 nmi
(I. 8km) o f , San Mi guel , Santa Barbara, Santa Rosa, Santa Cruz, and
Anacapa Islands to enforce jointly existing State and Federal
regulations as well as sanctuary regulations. It is also possible
that NOAA could provide funds to strengthen the present management
and enforcement. capabilities of the DFG, NMFS, and NPS.

Since the proposed marine sanctuary relies heavily on existing
regulations for the protection of the area's resources, its
enforcement agents would also enforce regulations imposed by other
authorities. Thus, the marine sanctuary would provide protection
for the area not only by proposing new regulations as discussed
below, but also by enhancing the effectiveness of existing regu-
lations by providing some resources for additional enforcement.

F-69

c. Regulated Activities

To protect the resources of the proposed sanctuary, NOAA propose s
to subject only the following activities.to sanctuary regulations:

1. hydrocarbon operations;
2. discharges or deposits of any substance;
3. alteration ofor construction on the seabed;
4. -vessel navigation (except within a desginated
VTSS or PAR) and operations (other than fishing
and kelp harvesting vessels);
5. overflights below 1000 feet (305m); and
6. removing or harming cultural and historic artifacts.

In the case of each of the above listed activities, NOAA's deter-
mination to propose regulations of particular aspects of the
activity was based on an evaluation that included a review of the
existence and application of current regulatory authority, the
primary mission of the agencies administering such authority, and
the need for any further regulation to help ensure the long term
preservation of the special resources of the proposed sanctuary.
In each instance, the alternative of not proposing any additional
regulation for a listed activity and of relying on the. authoriti es
as described in the status quo section was considered and reject-
ed.

The designation specifically excludes the harvesting of living
marine resources from the scope of possible sanctuary regulation
and leaves various other activities to existing authorities.
Permits, licenses, and other authorities applicable in the pro-
po5ed sanctuary would remain valid unless they would allow an

F-70

action which violates 'a ma Irine sanctuary regulation. In.order to
prevent unnecessary and costly delays, the proposed regulations
certify in advance the validity of permits and licenses which do
not conflict with marine sanctuary regulations.

1. Hydrocarbon Operations

(a) Hydrocarbon exploration, development and produc-
tion pursuant to any lease executed prior to the
effective date of these regulations and the laying of
any.pipeline is allowed subject to paragraph 935.6(b),
and all prohibitions, restrictions, , and conditions
imposed 'by applicable regulations, permits., licenses,
or other authorizations and consistency reviews
including those issued by the Department of the
Interior, the Coast Guard, the Corps of Engineers, the
Environmental Protection Agency, and the California
Coastal Commission pursuant to the Coastal Zone
Management Act and its implementing regulations.
(b) @o person may engage in any hydrocarbon operation
unless the following oil spill contingency equipment
is available at the site of such operation.

(1) 1500 feet of open ocean containment boom on
a boat capable of deploying the boom;

(2) one oil skimming device capable of open
ocean use; and

(3) fifteen bales of oil sorbent material.

(c) Hydrocarbon exploration, development and produc-
tion activities pursuant to , leases executed on or
after the effective date of these regulations are
prohibited.

These proposed regulatidns are designed to protect the sensitive
living resources of the northern Channel Islands from threats
resulting from oil and gas development by keeping such activities
at a minimum within the sanctuary and by requiring protective oil

F-71

spill containment measures when drilling and other operations
proceed. The regulations will reduce the likelihood of resource
degradation due to: (1) the effects of oil spills; (2) noise and
visual disturbances caused by drilling, presence of drill rigs or
platfo.rms, work crews, supply boats, and helicopters; and (3)
pollution associated with aquatic discharges. Table F-4 summa-
riz.es the hazards to marine mammals, seabirds, and marine organ-
isms which may result from offshore oil and gas development; Table
F-5 describes how NOW's sanctuary provisions will help mitigate
these impacts. This section addresses the impacts listed above,
tells how NOAA's sanctuary provisions will relieve the environ-
mental stress, and describes the projected socioeconomic effects
of these regulations.

It should be clearly noted at the outset that the present level of
oil and gas activity within the 6-nmi (11.1km) proposed sanctuary
As minimal due to previous actions by the Secretary of the Inter-
ior and to industry's failure to develop certain tracts. As
discussed previously and as illustrated in Figures F-7, F-8, and
F-8a, tracts within 6 nmi (11.1km) of the northern Channel Islands
were withdrawn from Sale -48. Because this tract withdrawal does
not apply to future sales, NOAA proposes to prohibit all future
hydrocarbon activities on these tracts. In additi on, as Figures
F-7, F-8, and F-8a show, 19 other previously leased tracts,
particularly off San Miguel Island, have expired or been termi-
nated. Thus, there are only 16 active leases fully or partially
within the 6 nmi (11.1km) boundary: 202, 203, 204, 205, 210 (off
Anacapa island); 223 off Santa Cruz Island;. 243-247 (off the south
side of Santa Rosa Island); 77 and 78 off the north side of San
Miguel Island; and 289-291 (off Santa Barbara Island). No devel-
opment activity at all (including exploratory drilling) has
occurred on the tracts south of Santa Rosa Island. However, the
California Coastal Commission has concurred that a Chevron U.S.A.,

F-72

TABLE F-4. Summary of potential hazards to marine mammals, seabirds, and marine organisms
resulting from off 'shore oil re@ource development and production (modified from
University of California, Santa Cruz, 1976).

Actiyity Qr Facility Chronic Hazards Episodic/Catastrophic Events
Exploration Profiling
Seismic Noise, "startle" effects Sub-surface noise Concussion
Drilling Siltation
Boat traffic, Prop hits Turbidity increase

Operation
Offshore facilities
-n Production platforms Intrusion
Well-head Leakage/seepage Blow-out
Support
Lj Crew and supply boats Sub-surface noise and
propeller hits
Aircraft Noise in air

Transport
Pipelines Leakage Rupture
Pumping buoys Leakage
Barges and Tankers Bilge Oil Intrusion Collision or grounding

Clean-up
Oil o water Intrusion Boat activity
Skimmers
Burn-off Pollution--air
Chemicals Pollution--water
Grounded rjil Toxicity of chemical Pollution--sediments
Booms dispersants Disturbance to sensitive bird and mama]
Straw populations on islands by human intrusion
Chemicals and aircraft activity
Presence of crew and equipment
Habitat destruction

Table F-5. Potential oil and gas development impacts mitigated
by NOAA's preferred sanctuary alternative

REGULATION REASON FOR MITIGATION OF IMPACT

1. No future leasing within --Creates a buffer area providing
6 nmi (11.1km) of north- increased response time for oil
ern Channel Islands and spill clean-up efforts;
Santa Barbara Island
--Increases the distance between
potential spill/pollutant dis-
charge point (i.e., rigs and plat-
forms) and sensitive resource areas
thereby allowing for weathering and
dilution of contaminants before
reaching important marine life con-
centration areas;

_-Prov.ides a [email protected] noise and
visual disturbances and important
marine life habitats;.

--Reduces congestion by additional
supply vessels which would other-
wise frequent nearshore areas;

--Reduces potential visual intrusion
on aesthetic values of the National
Monument, the proposed marine
sanctuary, and the proposed National
Park;

--Reduces potential air pollu tio n;

2. Requirement of addi- --Increases the probability that, if a
tio'nal on-site oil spill occurs, it can be reached and
spill containment controlled before drifting to sen-
equipment on exist- sitive breeding ground and nesting
ing leases areas.

F-74

11206 31Y

LEGO

Parcels offe
M-Leasing in S
F,
xpired or
X.
ederal Leas
_P
Leased Fed.
X., !n X
'OCS P" Leas
:-X
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XX
Sale 48 by
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E
OPE
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WLAM ChCHAMPLD
awk.,
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'MAI X

FIGURE F@-7. Existing leases and operators, and tracts offered in RAIC
Sale #48, in the northern Channel Island area (U. S.
Bureau of Land Management, 1979 (Visual.#1); Adams,
1979, personal communication; U. S. Geological Sur-
vey, 1975 (Map 1-974); California Office of Planning
and Research, 1977; U. S. Department of Inte
r1or,
1979a@,.and Oil and Gas Journal, 1979a).

2
LEG

0
Tracts
20
19

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NAL)TICAL MXIS

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V 290 A*qEIARA
": .0 X
11
FIGURE F-7a. Tracts leased in Lease Sale #48. (Oil and Gas
Journal 1979).

3W
4,
LEG
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10 108
MK;Ln
ISLAND SAXTA CN@Z\,@-
ROM
1KAND:. W"

i -it, t
Al
250

A
NAUTICAL MILES

FIGURE F-8. Existing OCS-Pacific numbers (186-291) and all tract
numbers originally proposed for Sale #48 (022-119) 51 RAd
in the northern Channel Island area (U..S. Bureau of
4@x
Land Management, 1979 (Visual #1); Adams, 1979,, 00
personal communication; U. S. Geolo ical Survey 3
9
1975 (Map 1-974); California Office of Planning and
Research, 1977; and U. S. Department of Interior,
1979a).

TT? -2 -T3 - --p- @25 -TO-5 zzzz@@ 120@
-M Or

37 186
40 41 42 3 44 45 241 240 4
38
!4D 141
1 1 1 46
let=
- ARB
48 49 50 51 52 53 54 5S 5a. 9 61 6f 62 238 37 63 234 233 &
179 V8 177 -74
66 67 68 232 231 230 229 228 227 226 7
69 79 73
T "W/ @el r76 175 )74 78 79, so of 82 83 84. 86 223 22 220 219. 218 21
222

as as,
.170 92 93 94 SIT. 2
172 90 Oee 6
isf 95 96
169 11
too Itj 105
168 go -99 a.... 201 300 see.,
167 102. '610 104 's
'MeW
SAN 1*0
10
"Wo' 40
-
4 % SANTA
4 7@ CRUZ ISLAND
SAftA
00

3 N.Mile

243

244 246 247

109
,no

248

249 112 8251
17

Figure F-8a. Tract numbers in the immediate vicinity of
the northern Channel Islands

Inc. request to drill a single exploratory well on' an existing
lease south of Santa Rosa Island i's consistent with the State's
coastal management program (Baird, 1980, personal communication).
The project calls for one exploratory well on lease block 245
approximately 1.7 nmi inside the proposed sanctuary boundary to
determine both the prospects for recoverable reserves of natural
gas at this location and the production potential on the remaining
leases south of the Island (California Coastal Commission, 1980).'
Drilling operations will not be permitted to begin before June 15,
1986 in order to protect the large numbers of harbor seals present
in this area in the spring (Baird, 1980, personal communication).
Only one exploratory well (with no discovery) has been drilled in
the tracts off Santa Barbara Island (Adams, 1979, personal commu-
nication; see Table E-16, Section E.3.b). Thus, because levels of
oil and gas development activity within 6 nmi (11.1km) of the
islands have so far been relatively low, the are-a's pristine
character has been well preserved. While it does not affect
future activities on existin g leases the sanctuary's prohibition
of operations on leases executed on or after formal designation
will keep down the level of oil and@gas development nearby and
thus enhance long-term resource protection.

Threats to Resources

--Oil Spills

The safety record. of the offshore oil and gas industry in the
United States has been good. Over 23,000 wells have been drilled
in coastal and offshore waters over the past 30 years with few
major mishaps (Mertens, 1980, personal communica tion). However,
accidents, natural disasters, and human error can lead to situa-
tions which result in the release of oil into the marine environ-

F-79

ment. Spills can be caused by well blowouts, barge and tanker
accidents, pipeline brea ks and leaks, and equipment failures.. The
large majority of spills involve relatively small amounts of oil,
usually less than 1000 gallons (24 barrels) (BLM, 1979). In the
Santa Barbara Channel and Santa Rosa and Santa Barbara Islands
area, 10. 20 o 11 spi 11 s o f 1, 000 b arrel s o r more - are sti 11 stati s-
tically expected to occur over the next 20 years as a consequence
of oil production and transport, not including blowouts (BLM,
1979).

Oil can directly affect living marine organisms biochemically or
physically (see, fo r instance, Boesch et al., 1973; National
Academy of Sciences, 1975; and U. S. Bureau of Land Management,
1975 and 1979). Petroleum hydrocarbons can also have-sublethal or
indirectly-lethal effects on marine organisms through the destruc-
tion or reduction of a species' food supply, chemical interference
with reproductive success, and synergistic effects which may
reduce resistance to disease and other stresses which alter
behavioral patterns such as feeding.

The physical damage that can be caused by oil coating marine
organisms, the feathers of seabirds, the' fur of marine mammals,
and the respiratory apparatus of fish is well documented (see, for
instance, BLM, 1979). With the exceptional abundance of marine
mammals and seabirds -- both of which may be seas onally present
around the Channel Islands in numbers representing a significant
percentage of the entire species population (as discussed in
Sections E.2.a and b) -- the possibility exists that the harm to
pinniped and seabird populations would be magnified if an oil
spill were to coincide with a concentration period (U. S. Bureau
of Land Management, 1979). The Fish and Wildlife Service, in
comments on pro posed Lease Sale #68, recommended that a 6nmi

F-80

buffer, zone from oil and gas leasing be established in 'order to
protect these major populations of marine mammals and seabirds
(Meyer to BLM, 1980, personal communication).

Spills are not the only potential source of oil in "the Santa
Barbara Channel region. The area is characterized by a large
number of natural oil seepage zones that are estimated to intro-
duce a total of from 40 to as much a s 670 barrels of oil per day,
into the marine environment (BLM, 1979). The amount of oil
escaping can vary daily and by, season. The major portion of the
seeps are found in the northernmost part of the Santa Barbara
Channel nearer the mainland (BLM, 1979). However, two seeps have
been reported within 'the boundaries of the proposed sanctuary
although the amount of oil being released is not documented
(Mertens, .1980, personal communication). While the total amount
of oil entering the marine waters is considerable, the number of
seeps is' also large and their distribution widespread. It is
therefore diffi cult to liken the effects of oil seeps to those of
a spill . A spill may involve much larger amounts of oil, perhaps
with much greater concentration on or near the water's surface, in
closer proximity to the valuable Island resources. In addition,
while some studies indicate that the ambient oil concentrations
may not effect the rich and varied marine life found in the region
(Mertens, 1980, personal communication), the full impact of these
chronic low level concentrations has not been evaluated and
further threats posed by the additional oil influx resulting from
a spill are unknown.

The Southern California offshore region also receives significant
quantities of oil from other sources not related to OCS develop-
ment. 'Rivers and creeks introduce about 91 barrels of oil and
grease per day and discharges of treated municipal wastewater,

F-81

whi ,ch exceeds 1 billion gallons per day, accounts for an addi-
tional 1,152 barrels per day (Bureau of Land Management, 1979).
Worldwide data on petroleum hydrocarbons entering the oceans
indicate that offshore production operations are responsible for
only a small portion of the total (National Academy of Sciences,
1975). Inputs from natural seeps, urban and river runoff, atmos-
pheric fallout and the various methods for transporting oil are
each several times greater. The impact of oil released as a
result of offshore production is not as correspondingly small as
it may appear. A spill originating from offshore activities can
have more serious immediate environmental -effects on the signi-
ficant ecological resources of this area than longer term di s-
charges from other sources,, although the effect of chronic dis-
charges is not well understood either.

--Pinnipeds

Floating oil may adversely affect pinnipeds in four ways: by
fouling the fur and through ingestion, inhalation, and the irrita-
tion of eyes and membranes (U. S. Bureau of Land Management,
1979). Oil contamination of fur can cause two very important
physiological changes -- loss of. buoyancy and impairment of normal
thermal resistance. Of the two, impairment of the body insulation
properties is probably the more damaging, particularly for fur
seals which depend primarily on their fur for insulation (U. S.
Bureau of Land Management, 1979).

Two species of fur seals are found in the proposed sanctuary, the
northern fur seal and the Guadalupe fur seal, which may be
proposed for listing as an endangered species. Both seals are at
the limit of their range at the northern Channel Islands which may
render them even more susceptible to stress. The sea otter, an

F-82

occasional transient in the area, is perhaps the most vulnerable
marine mammal to oil contamination (Davis, 1978; Kooyman and
Costa, 1978, U. S. Bureau of Land Management, 1979).

The,only major oil spill occurring in the study area was the 1969
Santa Barbara blowout. Estimates of the damage to biological
communities vary from essentially no damages to intertidal areas
to 100 percent mortality to certain organisms and plants at some
locations. All observers reported high mortality for birds (U. S.
Bureau of Land Management, 1979).

The long-term effects of the 1969 Santa Barbara oil spill on
marine mammals are also still unclear. Shortly after the spill,
biologists surveyed the percentage of mortality and of oil contam-
ination among the northern elephant seal and California sea lion
pups and tagged both oily and clean living pups (U. S. Bureau of
Land Management, 1979). While significantly more oiled than
11clean" California sea lion pups were found dead, the evidence did
not prove a cause and effect relationship. Although the spill
occurred soon after the breeding season for northern elephant
seals, the pups had already been weaned and they did not ingest
oil from their mothers. Tag returns for this species showed that
oily pups survived as well as clean pups. An earlier spill could
have had far more severe impacts (U. S. Bureau of Land Management,",
1979).

Several other circumstances of the spill may have also mitigated
the effects on biological resources. Most of the oil did not
reach shore until at least 3 days after the spill, thus allowing
time for weathering; favorable winds, kelp beds, and a natural
current barrier may have prevented much of the oil from reaching
shore; and the heavy rains of that year increased sedimentation

F-83

and flotsam in the area, which may have acted as sinking and
absorbent agents for the oil (U. S. Bureau of Land Management,
1979),

An oil spill in the sanctuary area would probably cause most
damage to pinniped populations if it occurred during the breeding
season (U. S. Bureau of Land Management, 1979). For San Miguel
Island, this would be from March to August and from December to
February (see Table E-4). On Santa Rosa and Santa Cr uz Islands,
the only species with rookeries are harbor seals; the greatest
effects of a spill would be between March and May. On Santa
Barbara Island, the breeding season extends from June to August
and from December to February (U. S. Bureau of Land Management,
1979).

--Cetaceans

Although the impacts of oil on cetaceans are not well understood,
some scientists believe that they may have both short and long-
term detrimental effects (Leatherwood, 1979, personal communi-
cation). Because baleen whales (Mysticeti) are filter feeders,
for example, they are susceptible to direct ingestion of oil or
oily substances. The toothed whales (Odontoceti), on the other
hand, would be more indirectly affected by eating organisms
further down the food chain, such as cephalopods and fish. Of
concern is the fact that this could trigger a magnification effect
where toxic oil might build up to high levels in the top carni-
vores; however, such effects have not yet been demonstrated.
There is no data available at present showing the bioaccumulation
of oil through the food chain resulting in a biomagnification
effect on cetaceans.

F-84

It is not known whether whales will swim through or around an oil
sl ick. Humpback whales have been seen feeding in an oil slick in
the northern Atlantic Ocean without apparent immediate i 11 effects
(National Oceanic and Atmospheric Administration, 1979). Although
the cumulative effects of toil on whales are not known, it is
likely that it would, at least, irritate their eyes and could
possibly affect their breathing apparatus given prolon ged expo-
sure. Because whales depend on blubber rather than fur for
thermal regulation, however, oil would not affect their ability to
withstand cold Pacific waters. Mammal reactions to an oil spill
would depend on many variables including the species of whale,
condition of the whale, time of year, and severity of the oil
spill.

--Birds

Floating oil affects marine birds by fouling feathers and through
ingestion, inhalation, and irritation of eyes and membranes.
Feather contamination is the primary cause of immediate mortality
because of the resulting inability to fly, avoid predators, or
forage under water as well as the lowering of body temperature due
to loss of insulation. Birds may also ingest oil while preening
or grooming contaminated feathers, which can lead to death (U. S
Bureau of Land Management, 1979).

A number of factors influence the vulnerability of different
species of birds to contact with spilled oil. Species which have
a tendency to form large, dense flocks on the water, spend consi-
derable time swimming on the water, dive when alarmed, or exist in
small, isolated populations are especially vulnerable (U. S.

F-85

Bureau of Land Management, 1979). To some extent., all seabirds
which breed in large colonies are vulnerable to contact with
floating oil during nesting season.

The study, area is characterized by a number of seabird breeding
colonies (see Section E.2.b. and Table E-10 above). In addition,
many migrating species congregate in the offshore region for brief,
periods throughout the year. Potential degredation threats
endangering seabirds due to oil spills and associated clean up
operations are likely to be particularly severe from January to
June when seabird densities are at their highest (U. S. Bureau of
Land Management, 1979). Both cormorants and alcids are particu-
larly susceptible to exposure in this respect largely on account
of their sizeable breeding colonies within the study area. Brown
pelicans, while present in far smaller populations here, are
equally vulnerable due to their restricted area distribution,
seasonally large breeding assemblages, and frequent diving (U. S.
Bureau of Land Management, 1979).

Among the other seabirds generally believed to be the most sus-
ceptible to oil contamination are: murres, guillemots, auklets,
murrelets, puffins, loons, grebes, and scoters (U. S. Bureau of
Land Management, 1979). According to an analysis of impacts
resulting from the 1969 Santa Barbara oil spill, the western grebe
was apparently incapable of discriminating between oiled and clean
water surfaces and thus was the one species most seriously affect-
ed by oiling (Battelle-Northwest, 1969). Shearwaters, albatros-
ses, petrels, gulls, terns, shorebirds, and some ducks and geese
all demonstrate vulnerability to oil contamination, but less so
than diver species (U. S. Bureau of Land Management, 1979) (see
Table F-6).

F-86

Tabl,e F-6. Seabird species most vulnerable to impacts related to
OCS oil resource exploitation. (All populations are
considered vulnerable to disruption-of feeding grounds
wherever they aggregate in large numbers. Birds are
protected under the Migratory Bird Treaty Act.)
(University of California, Santa Cruz, 1978).

SPECIES COMMENTS

Migratory waterfowl Most are divers and are very sus-
(loons, grebes, sea ducks) ceptibl e to oiling-of feathers;
many species forage in large groups
in restricted areas of shallow
water nearshore.

Cormorants Breeders in Channel Islands; very
susceptible to disturbance of. colo-
nies; roost ashore in large groups
and forage in flocks; susceptible
to oiling of, feathers.

Brown pelican Endangered species and Channel Is-
lands breeder; very susceptibl.e to
disturbance of colonies;

Phalaropes Very numerous and wide-ranging,but
susceptible to oiling of feathers.

Western gull Channel Islands breeder; may contami-
nate eggs by bringing oil to nests
on breast feathers.

Nesting alcids Very susceptible to oiling of feathers;
(Cassin's auklet, pigeon gather in large groups near colonies;
guillemot, Xantus' murrelet) vulnerable to disturbance of colonies
and introduction of terrestrial pre-
dators.

Wintering alcids Very susceptible to oiling of feathers;
may concentrate in restricted offshore
areas for feeding.

F-87

The long-term, cumulative effects of oil and gas.development on
seabird habitat areas and foraging grounds in the Santa Barbara
Channel area are still unknown, (U. S. Bureau of Land Management,
1979). Because of their direct dependence on nearshore food
sources, long-term contamination of foraging grounds'could cause
major alterations in seabird reproductive capabilities (U., S.
Bureau of Land Management, 1979).

Oil spi.1 1 treatment and clean-up operations also have important
impacts on the seabirds and mammals. Often the emulsifiers used
and associated human activity have been more harmful than the oil
(U. S. Bureau of Land Management, 1979). Because many new gene-
ration dispersants which are supposed to be no more toxic than oil
have not yet been totally evaluated, their environmental effects
remain largely unkown (U.S. Bureau of Land'Management, 1979). As
with oil spills themselves, the impacts of cleanup operations
would be particularly severe at times when seabirds are highly
concentrated.

--Fishery

A large oil spill in a fishing area also poses a serious threat to
sport and commercial fisheries such as those encompassed by the
preferred sanctuary alternative (see Section E.2.0. Potential
long-term effects include not only injury to the generally more
sensitive larvae and juveniles but also to adults, altered repro-
.duction (fish egg viability or sperm-egg interaction) or behavior
(feeding or migration), or disruption of the food chain. The
precise type of impact depends largely on timing with respect to
spawning season, migration patterns,, and whether the oil sinks

(i.e., affects bottom 'or demersal eggs) or floats (i.e., affects
pelagic eggs) A' spill resulting in a surface slick could affect
upper water biota such as the squid,. northern anchovy, jack
mackerel, and the planktonic basd of the food chain. Heavier oils
that sink could affect shellfish (abalone, lobster, crabs) and
fishes such as the flounders and soles.

A spill could prevent or limit fishing for a period of time during
and after its occurrence. In the case of the Santa Barbara spill
in 1969, it is estimated that fishermen lost a minimum of two
months of fishing with the area displaced by the spill (Neal and
Sorenson, 1970; U. S. Bureau of Land Management, 1979). The
chemical remains of spills 'of refined hydrocarbons in other
sectors of the world's, oceans, some of which are similar to
portions of themarine sanctuary study area, have closed waters to
fishing or other activities for many years (e.g., Hyland, 1977).,

The effects of oil and gas activities on kelp, particularly in
terms of kelp's role as a habitat for fish, are also important. A
number of kelp bed concentrations are evident around each of the
Northern Channel Islands (see Section E.2.c and Tabl.e E-14). It
is generally believed that the susceptibility of kelp and other
plants to oil pollution varies with its life stage and that the
adult generation has an outer mucilage covering which appears to
protect it against oil toxicity (U. S. Bureau of Land Management,
1979). While there appears to be little evidence tolindicate that
kelp is harmed by oil, it is an important habitat for flsh and
fauna which may ingest or come into contact with oil trapped in
its fronds. In addition, kelp contamination due to oil (e.g.,
natural seepage) renders it unfit for human harvest unless suffi-
cient wave action cleansing occurs (Szelenyi, 1979, personal
communication).

F-89

--Invertebrates and Intertidal Organisms

The effects of a large oil spill on the invertebrate species of
the study area could be devastating. These species include squid
and shellfish such as,the rock crab, lobster, shrimp, mussels, and
abalone, all of which are commercially valuable to the region, in
addition to many bottom-dwelling and intertidal organisms impor-
tant to the food chain. The planktonic larval stages of shellfish
are,highly vulnerable to the effects of oil. Bivalve shellfish
are sedentary and suffer significant mortalities in areas where
.sediments become contaminated with oil (NOAA, 1979).

The a 'rea supports a diversity of intertidal organisms. Many
invertebrates and other types of marine species are dependent on
tide pools during some part of their life cycles. The impact of
an oil sp.ill reaching these habitats could be severe. Smothering
could cause extensive,,damag,e and subsequent shore clean-up efforts
could serve to disrupt further the affected sites (Resources,
1978). The toxic and long-term effects.of the oil are not as well
known. The area contains a large number of endemic species which
could be threatened with extinction by even a small spill because
of their narrow range (Resources, 1978; BLM, 1979).

Low concentrations of oil or its components have been found to
affect the feeding behav.ior in species such as snail, lobster,
crab, and oyster and low levels of oil i,n sediments can impede the
burrowing activities of certain bivalves (NOAA, 1979). The long-
term effects from the Santa. Barbara oil spill have not been fully
determined. While high mortalities were suffered by acorn bar-
nacles and the breeding rates of barnacles and mussels and the

F-90

larval settlement of barnacl es were temporarily inhibited, certain
species of molluscs and other iniertidal species were- able to
return to the area (BLM, 1979).

--Reduced risks from spills

Based upon , existing knowledge concerning trajectories 'of oil
spilled at sites near and in the proposed sanctuary, the prohi-
bition of hydrocarbon activities within 6 nmi (11.1km) of the
islands will substantially reduce the risk to the sensitive
resources therein, both by -preventing some spills and providing a
temporal and spatial buffer to nearshore resources.

Immediately following a spill, the oil undergoes rapid weathering
and most of the toxic fractions evaporate into the atmosphere *or
disperse into. the water. Such dilution and chemical /biological
degradation lessens the damage from contact with oil spills. It
is, therefore, important to note that the greater the distance
between significant resources and potential oil spill sites, the
greater the amount of time available for spills to'be diluted and
weathered to a less toxic concentration or form.

The Bureau of Land Management developed oil spill probabilities
for leases predating and included in Lease Sale 48 and an oil
spill model to plot trajectories of hypothetical spills. Table F-
7 illustrates the probability of an oil spill (1000 barrels or
more) reaching the five islands as a result of activities asso-
ciated with all the tracts considered for Lease Sale 48 as well as
with tracts from earlier sales premised on BLM's oil spill model
and probabilities. Figure F-9 shows oil spill trajectories
computed by the California Office of Planning and Research (1977).

F-91

TABLE F-7. Probability of contact by one or more 1000 BBL spills between 1979 and 2000*,
(U. S. Bureau of Land Management, 1978b.)

Island 3 Days*** 10 Days 30 Days 60 Days
P E 'F P E B P E B P E B

San Miguel 6% 6% 12% 11% 18% 27% 14% 23% 34% 14% 25% 36%
Santa Rosa 10 20 27 15 33 44 18 37 48 .19 38 50
Santa Cruz 37 53 71 50 71 86 53 75 88 53 75 88
Anacapa 12 25 34 20 40 52 23 43 56 23 44 56
Santa Barbara <0.5 <0.5 1 2 4 6 4 8 12 5 9 14

P = Proposed Leases; **E = Existing Leases; B = Both
*These probabilities are based on USGS's original resource estimates which have subsequently been reduced by
84%. -
**Prooosed leases represent those analyzed in Final Environmental Statement on Sale 48 (U.S. Bureau of Land
Management, 1979). Sixty-nine of these tracts, including 24 near the northern Channel Islands, were with-
drawn from Sale #4@.
.***Days time from release of spill to contact with Islands.

30- t a-
1F
LEGD

Hypot
GANU

Poten

sAtVIA
BAR RA
C*u' CONTO

.de
Plale IW"
IGUEL
SAN M S A APA
SMILA CFAUZ
ISLAND

IWAM
A Sawa 11oft

-n

IT
FX \

FIGURE F-9. Potential oil spill trajectories (California Office
of Planning and Research, 1977).
_4

.1N\

In the Final Environmental Statement of Sale 48 (U. S. Bureau of
Land Management, 1979), BLM finds that "if just San Miguel Island,
.as the major pinniped breeding island is considered, the probabi-
lity of a major spill within the next 20 years is almost 100
percent."

As noted in Section E.3.b. and below, BLM's oil spill probabi-
lities reflect development scenarios analyzed in the Final Envir-
onmental Impact Statement on Sale 48 (U. S. Bureau of Land Manage-
ment, 1979). Since then, the Secretary of Interior withdrew 69
tracts from Sale 48, including 24 near the northern Channel
Islands and Santa Barbara Island (Figure F-7). Furthermore,
U.S.G.S. significantly reduced its most probable estimate of the
oil and gas reserves associated with Sale #48. Although the oil
spill model was not rerun to reflect changes in oil* spill probabi-
lities because of these tract withdrawals, these two changes have
certainly reduced the probability of an oil spill reaching the
Channel Islands. Spills can still result from operations on
existing leases in the area and, potentially, from Sale 48 tracts
beyond 6 nmi (11.1km). In addition, although the tracts closest
to the islands have been withdrawn from Sale 48, without sanctuary
designation they can still be leased in subsequent sales.

In addition to showing the probability that an oil spill will
reach the islands, BLM's oil spill model also developed probabi-
lities that an oil spill will affect: (1) major pinniped haulout
and breeding areas and (2) seabird breeding and nesting areas
within three days; these are shown on Table F-8*. -For instance,

*The probabilities that a hypothetical spill will affect
pinniped and seabird areas are not specific to the Channel
Islands,-but reflect areas throughout the Southern California
Bight. BLM's resource maps used for this analysis do illus-
trate a very high correlation between location of these areas
on the Channel Islands and their areal extent throughout the
Bight.

F-94

probabilities of a spill reaching major pinniped haulout an d
pupping areas from a proposed lease within the proposed sanctuary
(see P9 on Figure F-10) north of Santa Cruz and Anacapa Islands
(for Lease Sale 48 which. was later withdrawn) within three days
range as high as, 63 percent. Probabilities range as high as 68
percent that . spills occurring on a proposed lease (P9) and 70
percent from existing leases (see E5 on Figure F-11) will reach
seabird breeding and nesting areas. These probability figures do
not reflect the fact that a significant impact could also occur at
sea (i.e., not just to haulout and nesting sites) because of the
intensive use of these areas as foraging grounds.

Because BLM's oil spill model has not been rerun in light of the
withdrawal from Sale #48 of 24.tracts around the Islands or the
USGS's reduction in estimated resource potential available from
Sale #48 (see Table, E-13), it is difficult to determine the
specific additional protection from oil spills (i.e., a reduction
in the probability of a spill hitting an Island resource ) pro-
vided by the 6nmi (11.1km) buffer. NOAA also cannot project how
many tracts within 6 nmi of the Islands would be leased in the
future in the absence of a marine sanctuary designation. Table F-
8 and Figure F-12 show. the hi gh probability of oil spills origi-
nating from tracts in the proposed sanctuary and reaching sensi-
tive biol ogical areas. Although these probabilities have certain-
ly declined, given the lower resource estimates of USGS, there is
no question that a prohibition on oil and gas activities on future
tracts within 6 nmi of the Islands will reduce the risk of oil
spills reaching nearshore resources by' eliminating whatever
petroleum exploration and exploitation might otherwise occur.
Furthermore, while the risks of oil spilled beyond the proposed
boundary reaching nearshore resources may remain high, oil spilled
more-than 6 nmi from Island'shores is less likely to reach these

F-95

TABLE F-8. Probabilities (in percent) that an oil spill starting at a
particular location i,n the vicinity of the northern Channel
Islands will reach in three days: (1) major pinniped haul
out and breeding areas and (2) seabird breeding and nesting
areas- (U.. Bureau of Land Management, 1978b).

Hypothetical Major Pinniped Seabird Breeding and
Spill location** Haul-out and Breeding Nesting Sites***
(see Figure F-10 and F-IT) Areas *ii*

(Proposed Leases)
P1 13 26
P2 8 46
P3 26 28
P4 4 7
P5 30 13
P6 10 17
P7 11 17
P 16 14
P 63 68
P10 3
11 13 24
22 52

(Existing Leases)
E 10 10
E2 8 46
E3 23 40
E4 34 35
Es 55 70
E6 49 52
E7 2 2
E8 2 3
E9 18 37

These probabilities were computed from USGS's original high resource
estimate.
** See Figures F-10 and F-11 for hypothetical spill locations and their
proximity to San Miguel. Santa Cruz, Anacapa, and Santa Barbara Islands.
"P" stands for Proposed Sale 48 Leases and "E" for Existing Leases. 8LMs
Oil Spill Model also includes probabilities for spills from tankers hitting
these resources.
h** As noted, BLM's Oil Spill Model does not consider the probabilities of
an oil spill on these areas specifically at the northern Channel Islands
and Santa Barbara Island, but rather throughout the Southern California
Bight
**** P7, and P9, and P12 correlate with the 24 tracts around the islands
withdrawn from Sale 48.

n - less than 0.5 percent.

F96

TABLE F-9.. Oil spill recovery equipment in the vicinity of the
northern Channel Islands--see Figure F-13 (U. S. Bureau
of Land Management, 1979).

Location on Figure F-13 Equipment available at location

A Clean Seas
Getty Uil Terminal

1 trailer
1 51 T ACME Skimmer
-8001 of 16" Sea curtain boom

8 Clean Seas

3 Exxon Floating Weir skimmers
1 Komara Mini Skimmer
1 050 Cyclonet Skimmer
800' of 8" Sea curtain boom
400' of 16" Sea curtain boom
1,210' of'sea Sentry boom
2,000' of B-T boom
1 Vicoma sea pack (1,6001 of boom)'
1 trailer
1 39 T ACME Skimmer
1,500' of 43" Expandi boom
800' of 8" Sea curtain,boom

C Clean Seas
Carpinteri yard

1 trailer
1 51 T ACME Skimmer
800' of 16" Sea curtain boom
400' of 8" Sea curtain boom

0 Clean Seas
Union Term nal

1 trailer
1 51 T ACME Skimmer
4,400' of 43" Expandi boom
738' of 3011 Expandi boom

E Clean Seas

I trailer
1 51 T ACME Skimmer
2,410' of 30" Expandi boom

NOTE:

At each drilling location there is a
minimum of 1 skimmer, 1,000' of boom
and 10 bbls of dispersant.

F-9T

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FIGURE F-10. Hypothetical spill lodations from proposed Sale #48 (U. S.-Bureau of La

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FIGURE F-11. Hypothetical spill locations from existing leases (U. S. Bureau of Land

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FIGURE F-12. Hypothetical spill locations which correlate with tracts withdrawn from
of Land Management, 1978b; U. S. Departnent of Interior, 1979a).

nearshore wildlife concentrations in toxic' quantities, since the
increased distance from shore would provide more time for natural
forces to weather, mix, dilute, or redirect spilled oil.

The 6 nmi (11.1km) buffer created by NOAA's proposed regulations
is necessary because oil spill containment measures do not suffice
to protect the resources of these waters from the risks of an oil
spill in this area.. The success or failure of at-sea containment
and recovery operations in , the event of an oil spill depends
heavily on three factors: prevailing marine conditions, the amount
of time available before the oil will reach critical resources,
and speed of response.

Under calm ocean conditions, existing containment and recovery
equipment will function' effectively, making successful at-sea
recovery of the spilled oil more likely. But the effectiveness of
co ntai nment booms and sk i mmers ' f al 1 s, o f f dramati cal 1 y as wave
heights or wind velocities increase; the booms will not function
effectively if water currents exceed one to two knots (California
Office of Planning and Research, 1977). Wave period, height, and
the amount of turbulence also affect performance. Skimming
devices are, likewise, dependent on sea conditions. Effective
skimming is unlikely when ocean conditions are not at 1 east
moderately palm (California Office of Planning and Research,
1977).

The exposure of the waters seaward of the Channel Islands to
currents from the south and north and to storm swells makes sea
states too rough during most periods for effective at-sea spill
con ta i nmen t. Similarly, the seas around San Miguel Island are
typically very rough and would of-ten preclude effective contain-
ment. For instance, Clean. Seas, Inc. (no date), in their site

F-101

protection and cleanup, plan, state that the convergence of ocean
and Channel currents at the easternmost tip of San Miguel Island
results in breakers and rough seas. Access or approach for spill
control in that region is extremely dangerous (Clean Seas, Inc.,
n.d.) . Waters within th 'e Santa Barbara Channel are more protected
from offshore swells and storms, particularly in the eastern
portion of the Channel. Chevron (1978) noted that average signi-
ficant wave heights in the eastern portion of the Channel are. less
than 6 feet (1.8m) and that severe storm waves (100-year maximum)
have a 95 percent probability of not exceeding 34.4 feet (10.5m)
in height. Such currents and winds can still, however, make the
waters rough and limit the effectiveness of oil spill containment
equipment. Because of rough water conditions around the islands,.
even the availability of on-site containment equipment may not
insure that spills are effectively recovered.

Other spill abatement methods are available in addition to, or in
lieu of, at-sea containment. Dispersants act to facilitate the
incorporation of the oil into the water column and can be used
when conditions prevent the deployment of containment and collec-
tion equipment. The, application of di.spersants is contingent on
authorization for their use given by the Environmental Protection
Agency (CEQ, 1980). This permission is granted on a case-by-case
basis depending on specific spill site conditions and is planned
to result in the least overall environmental damage. Various
dispersant application techniques have been evaluated (Smith,
1979). However, an insufficient amount of research, especially
for newly developed dispersant chemicals, has been conducted to
assess adequately their effects of the marine environment
(McCarthy, 1980, personal communication). Early studies indicated
that the impacts of using dispersants at times exceeded that of
the oil alone (BLM, 1979; Dewling, 1979).

F-102

Because the tracts in the sanctuary are far from the mainland
where Clean Seas' oil spill response equipment is located (see
Figure F-13), in the event of an oil spill it is important that
there be sufficient time for Clean Seas to reach the site. NOAA's
prohibition on oil and gas operations within,6 nmi (11.1km) of the
islands on future leases extends the response time available for
possible at-sea oil spill cleanup before the spill reaches near-
shore areas. This increase in response time is particularly
important because, if a spill does reach shore, it is likely that
cleanup crew, equipment, and associated disturbances will greatly
compound the impact caused by the spill itself (U. S. Bureau of
Land Management, 1979).' For instance, Lindstet-Siva (1976) stated
that attempts to boom rookery beaches may be counterproductive
since most species of pinnipeds will. abandon rookeries if repeat-
edly disturbed. Because suitable areas for pinniped rookeries are
quite limited, abandonment of a rookery in this area could have
severe consequences. Even if disturbed only once, several days
may be required before activity patterns return to normal on a
disturbed beach. Because of these factors, Lindstet-Siva (1976)
noted that the best action is to mechanically contain the oil at
the site. Lindstet-Siva (1979) recommended that human activity be
kept to a minimum in nearshore waters and on beaches used by
pinnipeds and that the use of chemical dispersants in the open sea
(approximately 5 miles from the rookery) be considered to mitigate
the effects of the spill. If oil reaches rookerie-s, it is
probably best not to attempt cleanup since almost any method would
be disturbing to these animals.

In their site protection and cleanup plans, Clean Seas Inc.
recognize the potential that oil spill recovery activities may
disrupt pinniped rookeries (Clean Seas, Inc., no date). The site
protection plans for. San Miguel, Santa Cruz, Santa Rosa, and

F-103

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Clea

ad A
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BARA
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n;; ISLAND ANACAPA
SAM% CF=

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MILES115

FIQURE F-13. Location of Clean Seas, Inc. the oil spill
cooperative for the northern Channel Islands B RAIV
area (U. S. Bureau of Land Management, 1979).

2Y,

Anacapa Islands recognize that pinnipeds are very sensitive to
human disturba nce and, thus, no onshore cleanup should be attempt-
ed near haulout or rookery areas (Clean. Seas, Inc., no date). A
site protection and cleanup plan. is not yet available for Santa
Barbara Island.

In order to provide. at least a partial immediate response to an
oil Ispill, NOAA's proposed oil spill equipment regulation requires
possible, oil and gas development on existing leases within the 6-
nmi (11.1km) boundary to meet,not only the existing requirements
imposed by BLK, USGS, EPA, and others (see Section F.1.b), but
also provide onsite oil spill cleanup equipment to assist in
preventing damage to nearshore resources. Although OCS Order #7
requires that minimum containment equipment at each drilling
location must include a boom, skimming apparatus, and chemical
dispersants (U. S. Bureau of Land Management, 1979), this require-
ment may be inadequate particularly for sites near the Channel
Islands. For instance, the California Coastal Commission, in its
review of Exxon's Plan of Exploration on blocks 222, 223, 230,
231, 232, and 238 (see Figures F-7 and F-8) for consistency with
the California Coastal Plan,- has required: (1) 1500 feet (460m)
of open ocean spill containment boom; (2) an oil skimming device
capable of open ocean use; (3) fifteen (15) bales of oil absorbent
material; and (4) a boat capable of deploying the oil spill boom
at the site at all times (California Coastal Commission, 1979).

The Coastal Commission believes that effective onsite spill
containment equipment is essential due to the rather long response
time (approximately three hours or more) for Clean Sea, Inc. (the
responsible oil spill cooperative) to get heavy cleanup equipment
to this portion (relatively close to the mainland) of the Santa
Barbara Channel (California Coastal Commission, 1979). Chevron

F-105

(1978), in its environmental report for a 'proposed exploratory
well on lease block 215 in the Santa Barbara Channel , cites the
Clean Seas, Inc. general manager's estimate. that his firm's
equipment can reach the block.within seven hours. As Figures F-7
and F-8 illus-trate, Block 215 is approximately 8 nmi (14.8km) from
Anacapa' Island (Chevron, 1978); response time to spills closer to
the islands and, therefore further from the mainland, are very
likely to be greater. Estimated 'response times to tracts south-
east of Santa Rosa Island are 2-3 hours by helicopter and 7-10
hours by boat (California Coastal Commission, 1980).

In addi'tion to the Clean Seas, Inc. cooperative, the region
contains several other oil spill cleanup groups. The Southern
California Petroleum Contingency Organization (SC-PCO) maintains a
variety of equipment in the Los Angeles area and also on Santa
Catalina Island; Clean Coastal Waters (CCW) has booms, skimmers,
and other apparatus in Los Angeles (U.S., Bureau of Land Manage-
ment, 1979). While their area of responsibility extends only from
the Mexican border northward to Pt. Dume, these organizations do
have reciprocal agreements with Clean Seas, Inc. to provide
assistance in the event of a major oil spill (Barker, 1980,
pbrson al communication). This capability has yet to be used in
the Santa Barbara Channel area . Response times vary with weather
.conditions and the size and location of the spill. SC-PCO.can
have a four engine propel ler-driven airplane equipped to apply
dispersants at Santa Barbara airport within four hours of spill
notification. SC-PCO and CCW equipment on the mainland can be
transported by highway on trailers and can be in Santa Barbara in
4.5 hours. SC-PCO gear on Santa Catalina Island can be readied
for departure in one hour. . Some of the material can be flown to
the site and airdropped.

F-106

Becau se all the existi ng leases,in the proposed sanctuary are more
than 9 nmi away from the closest oil spill cooperative and because
these tracts are located near sensitive wildlife concentrations,
NOAA will require the equipment required by the California Coastal
Commission for the exploration of tracts 222, 223, 230, 231, 232,
and 238 (see above) as the minimum onsite oil spill containment
equipment for drilling within the sanctuary. This requirement
will provide some additional protection to the waters of the
sanctuary from the effects of an oil spill. Additional equipment
requirements set by the California Coastal Commission under the
Federal consistency provision of the Coastal Zone Management, Act
will also apply under NOAA's certification of existing permits
(see F.2.c.).

--Acoustic and Visual Disturbance

Oil and gas platforms, rigs, and activities produce both a visual
intrusion on the scenic qualities of the islands' seascape and
disturbances due to construction activities and the sound and
movement of boats and helicopters (U. S. Bureau of Land Manage-
ment, 1979).

The continuous noise and human activity associated with oil and
gas development in nearshore waters and the need for a steady
stream of crew and supply boats produce visual impacts and noise
which may disturb seabirds and marine mammals, particularlyduring
sensitive nesting, pupping, and migration seasons. If these
disturbances occur very close to shore, stampeding by pinniped s or
sudden flight by nesting birds can occur (U. S. Bureau of Land
Management, 1979). During critical breeding periods such re-

F-107

actions could result in increased mortality rates in Young sea-
birds and marine mammals (U. S. Bureau of Land Management, 1979).

Oil and gas development may have both negative and positive
impacts on the areals recreational values. Negative impacts
include: increased congestion; the visual effects of platforms,
tankers, and other activities on the open sea; degradation of
water quality; and the risk of oil spills. Positive benefits
could include the potential aid to navigation provided by develop-
ment structures and communication assistance for lost or distres-
sed boaters. Sportfishing may also improve around offshore plat-
forms due to the attraction their artificial reef habitat provides
sportfish species (U. S. Bureau of Land Management, 1979). Bo th
shellfish and vertebrate fish cluster around offshore platforms.

NOAA's prohibition of future leasing within the 6-hmi (11.1km)
sanctuary boundary would lessen the noise and human activity in
nearshore waters and also decrease the need for additional supply
boats to enter nearshore waters or incidently approach resting or
nesting marine mammals or seabirds. NOAA's requirement is in line
with the findings in the 1975 Final Environmental Impact Statement
(FEIS) on Lease Sale 35 (U. S. Bureau of Land Management, 1975)
which considered drilling activity and platform construction one
of the greatest dangers to the pinnipeds and seabirds:

"activities associated with platform installation,
exploratory drilling and production operations off San
Miguel and Santa Barbara Islands could cause signi-
ficant reductions in seabird populations and the
potential elimination of sea lions, fur seals, and
harbor seals from their principal breeding area in
Southern California" (U. S. Bureau of Land Management,
1975).

F-108

In addition, the prohibition of oil and gas activi rties on future
leases within 6 nmi (11.1km) will reduce the potentially adverse
aesthetic impact of oil and gas platforms,, rigs, pipeline -con-
struction, and other activities on the Channel Island National
Monument, the other islands, and boats in the area. , It also
serves to preserve the wilderness character of the island waters
from industrial oil and gas development. While the significance
of such values as undisturbed views and wilderness is difficult to
Iquantify in monetary terms, their protection is, nonetheless,,
important, particularly in proximity to heavily populated urban
areas such as those in southern California.

--Discharges

A wide variety of pollutant discharges are associated with OCS oil
I
and gas develpment: drill cuttings and muds; sewage and trash;
formation waters; and air pollutants (e.g., petroleum aer osols and
engine exhausts).

Drilling effluent discharges include drill cuttings (pulverized
rock fragments and chips removed during core drilling) and drill
muds (complex chemical mixtures that cool and lubricate the drill
bit, transport cuttings upward, equalize hydrostatic pressures,
and minimize corrosion of the drill pipe and casing)(U. S. Bureau
of Land Management, 1979).

The literature on toxic effects of drilling discharges indicates
that, while certain toxic effects must be considered potentially
significant, many of the chemical constituents of drilling muds
are relatively unreactive in a biologic sense and disperse to

F-109

background concentrations within a few thousand. feet of. the
drilling site (see, for instance, ECOMAR, 1978), particularly in
areas with strong currents and flushing action such as the waters
around the islands.

At the current lowlevel of. development of hydrocarbon resources in
the proposed sanctuary the data are inconclusive and do not
warrant further control of normal OCS discharges, such as forma-
Von waters and drill cuttings and muds., within the proposed
sanctuary beyond the regulations of the Department of the Inter-
ior, the Coast Guard, and EPA, which provide for the imposition of
mitigating measures if harm to biological populations is shown.
However, given the presence of many endemic benthic invertebrate
species in this biological transition zone, protection from the
discharge of drill muds and cuttings may be important. Many of
these species, though extremely valuable for scientific research,
may ,not show up in the biological surveys conducted by lessees
(Mohr, 1979, personal cominunication). Given the extremely limited
distribution of these species, even impacts only within a few
thousand feet of each platform may be significant if the number of
platforms increases. Furthermore, bioassay tests and other
studies of the effects of muds have been rather site specific and
cannot be considered determinative of the long-term consequences
of marine disposal of muds. If evidence of the need for more
stringent controls is found after monitoring and studying opera-
tions in the sanctuary, NOAA will take steps to propose further
controls.

Air pollutant discharges typically disperse rapidly into the
atmosphere or ocean waters and thus pose relatively minor threats
to sanctuary resources. A major effect, however, would be on the
areals aesthetic qualities and to adjacent regions (e.g., coastal

F-110

Calffornia). In addition, the Channel Islands National.Monument
(composed-of Santa Barbara and Anacapa Islands) had been proposed
as a Class I area under the Clean Air Act. Oil and.gas develop-
ment in the vicinity of these islands would greatly enhance the
probability that the Class I standards (if the Monument is so
designated) would be violated (U. S. Bureau of Land M anagement,
1979).

--State oil and gas sanctuaries

Finally, o f particular importance to the State of California, the
prohibition of future leasing with 6 nmi (11.1km) will also help
to insure that the State Oil *and Gas Sanctuaries can continue to.
provide protection to nearshore marine resources. If oil and gas
development is allowed adjacent to the Oil and Gas Sanctuaries, it.
is possible that California would have to hold a drainage sale
within State waters to avoid losing State reserves.

--Socioeconomic Impacts of the Proposed Regulation

The economic impact of this prohibition in large part depends on
two factors: the estimated selling price of the tracts and the
amount of economically recoverable hydrocarbons which would be
foregone under the proposed regulations.

F-111

Amount of Oil and Gas-Reserves Affected

Reliable data on the hydrocarbon. reserves within the sanctuary are
not, available. Approximately half of the proposed sanctuary has
never been considered for leasing and NOAA has no resource esti-
mates in these areas. In the remaining half, there are 43 un-
leased tracts, twenty-four of which were originally considered for
Lease Sale #48 and then withdrawn (Leases in the other 19 tracts
have expired due to insufficient attempts at development - poss-
ibly indicating low resource potential). The U. S. Geological
Survey's most recent resource estimate specifically for those 24
tracts was. 5.7 million barrels of oil and 8.9 billion cubic feet
of gas. This represents approximately 3 percent of the oil And 1
percent of the gas reserves estimated for all the tracts consi-
dered for Lease Sale 48 in the most recent U.S.G.S. calculations,
or less than 1 day's supply of oil and gas for the United States
(average daily consumption in the U. S. is about 19 million
barrels of oil and 53 billion cubic feet of gas). These figures
include all resources recoverable with current technology. BLM
estimated that about half the estimated resources for the entire
Sale #48 area would be economically recoverable. However, as the
price of oil rises, the proportion of resources which will be
economically recoverable will also rise.

The extent to which any resources, whatever their potential, will
be unavailable under the proposed prohibition is questionable. At
least some of the available reserves could be recovered by slant
drilling from outside the sanctuary despite any prohibition.
Eleven of the forty-three currently unleased tracts fall 'Only
partially within the proposed sanctuary. The Department of the
Interior has already withdrawn 24 tracts and the number of tracts
it would actually offer for lease cannot be predicted. The State
of California prohibits oil and gas development within its waters
around 4 of the 5 islands in the proposed sanctuary.

F-112

Since there is a limited amount of capital available for the
development of OCS oil and gas reserves, the prohibition on
exploration and exploitation activities on new leases in the
sanctuary will have.the effect of redirecting rather tha.n stopping
investment in o 'il and gas operations in the southern California
OCS.in the near future. Thus this proposed prohibition is unlike-
ly to affect the amount invested in offshore hydrocarbon produc-
tion. Audging by the area leased in OCS Sale 35 and 48 and by the
area receiving two or more positive nominations for leasing in the
call for nominations for, Lease Sale 48, and assuming that there
will be about two lease sales every five years, there. will be
opportunity for exploration over the next 25 years in the Southern
California Bight without the excluded sanctuary tracts. However,
although positive nominations provide some indication of industry
interest, they are not fully accurate indicators of resource
potential. In addition, the above estimate of available tracts
for investment does not take into account the possibility that
patterns of investment could shift toward or away from the south-
ern California OCS.

It is important to note that the proposed prohibition on hydro-
carbon activities on new leases in the sanctuary does not neces-
sarily mean that affected reserves will be permanently unavail-
ab I e. These reserves will be preserved for future use, when
technology may improve or the need for resources may increase. In
fact, various groups, including Get Oil Out (1978) and the Scenic
Shoreline Preservation Conference, Inc. (1979), have proposed that
the Channel become a hydrocarbon reserve so that resources can be
saved for specific uses (such as petrochemicals) for which suit-
able substitutes are not yet available. Should petroleum techno-
logy improve so that the risk of injury to sanctuary resources
would be sufficiently reduced, sanctuary regulations could be

F-113

changed to allow development subject to appropriate controls.
However, a decision to reevaluate the prohibition on petroleum
activities would be based on a 'requirement to permit only those
activities consistent with the fundamental purposes of the sanc-
tuary, particularly living marine resource protection.

Effect on Federal Income from OCS Leasing

The proposed prohibition could reduce U. S. income from offshore
leasing. It is unlikely that the industry will bid on affected
tracts located completely within the sanctuary if those tracts are
offered in future lease sales. Tracts located partially within
the sanctuary would probably also be less attractive to industry
given a prohibition on drilling in the sanctuary and may draw
lower bids or none. This change in bidding could represent a
reduction of revenue to the U. S. Treasury if these leases might
otherwise have been sold. The total amount of lost revenues
cannot be estimated at this time. The prices of leases are based
on data much of which is proprietary. Furthermore, the future
prices of leases in the Channel will depend heavily on the results
of exploratory activity from Sale 48. Prices for tracts leased in
earlier sales do not follow any clear geographic pattern. The
Department of the Interior estimated the social value of the 24
tracts deleted from Sale 48 to be $1 million* (U. S. Department of
the Interior, 1979c). The social value is the savings gained by
producing oil. domestically rather than importing it. The Federal
government obtains most of these savings through leases, royal-
ties, and taxes.

*This estimate is based on the reduced USGS resource estimate.

F-114

Effect on Industry

Under this, proposed prohibition the petroleum industry would
forego the profits it could otherwise realize from the development
of the affected tracts. Companies that have leased tracts in the
area include Texaco, Chevron, Exxon, Mobil, Continental,' Union,
Phillips, and Champlin oil companies. However, as discussed
above, in the short term, this prohibition will impose only minor
losses, if any, on the industry, because operators can channel
their cap-ital for exploration and development to other areas of
the Southern California Bight. If resources in the sanctuary were
substantially higher than in other portions of the Bight, industry
would forego a higher profit margin. However, the data available
from USGS indicate that the resource potential in the excluded
tracts is relatively low.

Finally, development on tracts and portions of tracts within 6 nmi.
of the Islands which are already leased would have to meet the
proposed provision requiring 1500 ft of open ocean spill contain-
ment boom, 15 bales of oil sorbent material, an oil skimming
device for open ocean use, and a boat capable of deploying the
boom on location. Since these requirements exceed those imposed
by USGS operating order V, they would impose some additional
costs on th e industry. However, since itis likely that in many
cases the California Coastal Commission would also require identi-
cal onsite spill containment equipment, NOAA's minimum may not
impose any additional cost.

F-115

Sectors Affected

The primary sectors affected are the Federal and State of Cali-
fo rnia governments because of the loss of possible revenues from
lease sales. However, the State of California already has an oil
and gas sanctuary surrounding 4 out of 5 of the islands in the
proposed sanctuary. The oil industry would forego the profits it
might otherwise realize from the sale of the oil under the affect-
ed tracts. However, as discussed above, in the short run, the
regulations would redirect rather than curtail oil and gas invest-
ment activities. The oil. industry might also have slightly
greater costs to meet the oil spill contingency requirements.
Offshore drilling and service industries may also be indirectly
affected in the long run. The tourism and recreation industry in
the Santa Barbara and Ventura area may benefit from the restric-
tion on petroleum development around the Islands, but these
benefits cannot be estimated. Sport and commercial fishing may
also gain from this regulation, although, again, the possible
economic gains cannot be projected precisely.

2. Discharge of polluting substances

No person shall deposit or discharge any materials or substances
of any kind except:

(A) indigenous fish or parts and chumming materials;
(B) effluents from marine sanitation devices;
(C) nonpolluted cooling waters from ocean vessels;
(D) effluents incidental to those hydrocarbon exploration.
and exploitation activities with an NPDES permit.

F-116

The proposed regulation prohibiting discharging and littering
within the sanctuary complements the existing regulatory system
and would enhance the area's overall recreational and aesthetic
appeal and help maintain the present good water quality in the
sanctuary. At present, specific discharges such. as oil, are
regulated in order to protect the marine environment. In parti-.
cularly sensitive offshore zones, such as those designated by the
State of California as areas o *f special biological significance
(ASBSs), harmful discharges are prohibited (This prohibition does
not apply to vessels, (see Section F.1.6)).

This@ regulation would ensure that solid wastes will not degrade
wildlife rookeries or otherwise alter the area's aesthetic appeal.
It would prevent floating or submerged waste debris (e.g., non-
biodegradable plastic or metal objects) from being deposited into
'heavily used foraging areas, where animals could ingest or become
entangled in them. Under current human activity levels casual
littering is not widespread and observed adverse impacts upon
resources have so far been minimal (Johnson, 1979, personal
commun i c ati o n) .NOAA's regulation would increase the probability
that additional use of the area will not lead to substantial
degradation. Although litter and other solid wastes do move in
the marine environment subject to winds and currents, this prohi-
bition will reduce the amount of trash in the marine sanctuary.
Specifically it will prevent aesthetic and water quality degra-
dation at nearshore anchorages if the use of those areas by
recreational and other boaters rises. The prohibition will also
prevent the possibility of dredge disposal or ocean dumping in the
area in the future. By prohibiting dredge disposal in the imme-
diate vicinity of marine bird and mammal breeding grounds and
haulout areas, risks from the distribution of contaminant mate-
rials (e.g., toxic substances, heavy metals) are reduced. How-

F-117

ever, there has been no evidence of contamination to date within
the study area.

The impacts of this regulation on sanctuary users is expected to
be minor; trash will have to be kept on boats and disposed of at
proper facilities, most likely on the mainland. The prohibition
on locating dredge disposal or ocean dumping sites in the sanc-
tuary could conceivably impose costs on future development in or
near the Santa Barbara Channel by r6quiring more expensive dis-
posal methods.

3. Alteration of or Construction on the Seabed

Within 2 nmi (3.7km) of any island, no person shall
dredge, drill, or otherwise alter the seabed in any.
way, nor construct any structure, except for a navi-
gation aid or except in connection with the laying of
any pipeline associated with petroleum development.

Dredging and dredge disposal activities, while not ongoing within
the proposed sanctuary area, represent a potential threat to
particularly sensitive marine resources. Foremost among these
potentially adverse impacts would be increased turbidity levels,
disruption/displacement of benthic communities, and human intru-
sions near seabird and marine mammal concentrations. A 2-nmi
(3.7km) offshore buffer area will help ensure that these impacts
do not affect breeding grounds, haulout areas, and adjacent
foraging areas.

F-118

Dredging for, pipelh@ne construction (i.e., for oil, water's and gas)
is -allowed subject to authorization by the California Coastal
Commission and all other regulating agencies.

This regulation will enhance resource protection by prohibiting
the presence of large, and often noisy, dredging machinery within
2 nmi (3.7km) of the shore. Thus, both over the short and long-
term, human intrusion upon marine wildlife along with potentially
adverse impacts on their food supplies (e.g., benthic and pelagic
fish resources) will be minimized. Dredging for pipeline place-
ment is exempted because over the long run pipelines often have
less impact on wildlife and pose a smaller risk of oil spills than
barge traffi c. This is particularly important in a high use area
such as the Channel.

No economic impacts upon commercial firms are expected because
current dredging operations are located outside of the sanctuary's
boundaries and no zone within the 6 nmi (11.1km) boundary is used
for dredge spoil disposal. Dredging restrictions may limit the
harbor facilities of the Channel Islands if expansions are pro-
posed in the future.

4. Operation of Commercial Vessels

Except to transport persons or supplies to or from an
Island, no person shall operate within one nautical
mile of an Island any vessel engaged in the trade of
carrying cargo, including but not limited to tankers
and other bulk carriers and barges, or any vessel
engaged in the trade of servicing offshore instal-
lations. In no event shall this section be construed
to limit access for fishing (including kelp harvest-
ing), recreational, or research vessels.

F-119

To the extent consistent with international law, within 1 nmi
(1.8km), NOAA would prohibit traffi -c by commercial cargo vessel-s
and offshore service vessels. Commercial fishing, kelp harvest-
ing, research, enforcement and recreational vessels, would not be
affected.

This regulation wi 11 reduce certain environmental impacts within I
nmi (1.8km) from large commercial vessels including: (1) visual
and acoustic disruption of hauled outseals and sea lions, nesting
seabirds, and whales; (2) possible accidents involving groundings
or collisions with nearshore vessels; (3) routine or accidenta 1
discharge of pollutants (from ballast discharge tank washing, and'
bilge bunkering) directly into important nearshore habitats; and
(4) aesthetic intrusion on the view from the islands.

It is difficult to predict what level of human intrusion will
disturb marine mammals and birds. Frequently, birds will act as
sentinels; warning signals by birds will cause hauled out pinni-
peds to flee. Shyness varies according to species, time of year,
location of the animals, and nature of the disturbance, 'among
other factors (Beach, 1979, personal communication).

DeLong (1975) reported that the mere sight of a passing vessel off
crowded pinniped haulout areas has been sufficient to cause a
stampede into the ocean. If pups are in the hauled-out herd,
larger seals or sea lions may trample, kill, or injure smaller-
animals in their rush to the sea. Stampedes may also cause
permanent separation of pups from their parents as a result of the
confusion. Similarly, a ship passing near the shore may frighten
nesting birds and leave c hicks and eggs unprotected. However,

F-120

other reports indicate that on occasion pinnipeds may show rela-
tive indifference to small vessels as long as they do not land or
make noise.

As noted in section E.3.d., a significant.ambunt of vessel traffic
currently uses the Santa Barbara Channel A U.S. Coast Guard
survey reported a daily average load of nine large vessels (300
feet or 90m, or even longer) and seven medium (100-299 feet or 30-
90m long), small (less than 100 feet or 30m) or tug-in-tow vessels
en route along the Traffic Separation Scheme (TSS) in a northerly
direction (Cherney, et. al., 1978). In addition, current traffic
levels are likely to increase as a result of new southern Cali-
fornia offshore oil production and a number of other maritime
projects now being planned. If vessels remain in the TSS -they
will not infringe on the 1 nmi (1.8km) buffer (Figure F-14).
While compliance. with, the TSS has been good (Adie, 1979, personal
communication), it is not mandatory; vessels can and occasionally
do enter nearshore waters.

In addition to disturbing marine mammal. and Seabird rookeries,
nearshore vessel traffic would. create an aesthetic impact out of
character with the present wilderness and recreational features of
the islands and surrounding waters. Tankers and freighters
transitting the Channel are substantially larger than other craft
in the area, ranging in length from slightly less than 100 feet
(30m) to more than 300 feet (90m). On the other hand, commercial
fishing boats range in size from about 35 feet (10m) to 85 feet
(26m) and most recreational vessels average approximately 35 feet
(10m) (Johnson, 1979, personal communication; Larson, 1979,
personal communication). The DFG presently protects particularly
sensitive areas from small boat intrusion through its Ecological
Reserve Program (see Section F.Lb). OCS supply and crew boats,

F-121

120- w

7
LF, LEG
Vesse

CONTOU

f CRUZ

L NAUTICAL MILES

FIQURE F-14. Santa Barbara Channel traffic separation scheme u A10
(TSS) and the 1-nmi (1.8km) prohibition zone. . .....

although they do not generally exceed 65 feet (20m) (Cassel, 1979,
personal communication), have no need to enter nearshore waters
and are therefore subject to the regulatory prohibition.

Finally, the restriction on some commercial -traffic within 1 nmi
(1.8km) reduces the risk that vessels will collide with the
smaller recreational, fishing, or,,.pther boats. The nearshore area
is more treacherous to navigate due to shallow rocky areas.
Prohibiting nearshore navigation by larger @vessels would thus
reduce both near-island spills and pollution resulting either from
collisions or from.accidental groundings.

Exclusion of certain vessels from a 1 nmi RAW band around the
islands will not result in extended travel times to port or other
major impacts on commercial shipping because vessels generally
adhere to the TSS. In fact, it is the most direct route for
transitting the region. Those vessels which have any need to be
present in this particular nearshore zone are exempted from the
regulation.

The final proposed Designation document precludes the regulation
of navigation within the present TSS or any future port access
route (PAR) designated by the Coast Guard provided such PAR is not
designated within the 1 nmi area of concern. This provision
ensures protection of the sensitive area while avoiding any
duplication of , or interference with, the Coast Guard's naviga-
tional expertise.

F-123

.5. Disturbing Marine Mammals and Birds b Overflights
Y

No person, shall disturb seabirds or marine mammals by flying
motorized aircraft at less than 1000 feet over the waters within
one nautical mile of any Island except:

(A) for enforcement purposes,

(B,) to engage in kelp bed surveys; or

As for vessels, the prohibition on disturbance by overflights
below 1000 feet (305m) is designed to limit potential noise
impacts--particularly those that might startle seals and sea lions
along the nearshore,margin@ of the sanctuary. It would complement
the existing California Fish and Game regulation (which prohibits
Overflights below 1000 feet (305m) over San Miguel, Anacapa, and
Santa Barbara Islands) by extending prohibitions out over adjacent
water areas where these animals forage. It would also parallel
the National Marine Fisheries, Service's interpretation regarding
overflights under 1000 feet as harrassment in an area where
disturbing whales is likely. This regulation would affect recrea-
tional aircraft and some charter airline groups which fly passen-
gers over the islands to enjoy the scenery.or observe whales. As
noted in section E.3.g.., two companies presently charter planes
for nature observation. In addition, a number of private planes
in the area may, on occasion, fly over migrating gray whales
around the islands.

F-124

This' regulation will contribute to the protection of natural,
undisturbed behavior patterns of marine mammals and seabirds
,concentrating and breeding along island shorelines. Necessary and
reasonable uses of the area's air space, such as Coast Guard
surveillance, kelp bed surveys, landing at island airstrips, and
military operations, would be exempted. Since no commercial
airlines (other than the above mentioned charters) fly regular
routes over the islands at these low altitudes, this regulation
should pose no burden on other commercial airline carriers.

Although the charter planes often fly as low as 75-100 feet (23-
30m) and private planes on occasion as low as 50 feet (15m)
(Glendinning, 1979, personal communication), marine mammals can
still be seen from altitudes of 1000 ft. (305m) or above.

6. Removing or Damaging Historical or Cultural Resources

No person shall remove or damage any historical or cultural

resource.

This regulation is aimed at protecting archaeological or paleon-
tological resources from damage and/or removal. Additionally,
NOAA will seek listing of identified resources on the National
Register of the National Historic Preservation Act. Listing in
the National Register would make possible grant and survey funds
from the Secretary of the Departmentof the Interior (DOI) (Heri-
tage Conservation and Recreation Service) to study the artifacts
and identify their distribution. Listing on the National Register
also insures that proposed Federal activities which could affect
the resource are carefully reviewed.. This regulation should not
significantly affect activities within the sanctuary, except the

F-125

collection of historical artifacts by recreational divers.

@d. Other Regulations.

--Amendments

California's Coastal Zone Management Program ha s been approved
under Section 306 of the Federal Coastal Zone Management Act.
Consequently, any activity conducted or supported by a Federal
agency which directly affects California's coastal zone must be
consistent with thi s program to the maximum extent practicable.

The proposed regulations provide that any significant change in
the extent to which various activities are prohibited within the
sanctuary automatically will be considered to have a direct effect
on the coastal zone and will require NOAA to provide the State
with a consistency determination.

In addition, should California determine that certain activities
no longer need to be prohibited (for example, that technology has
progressed to the point where hydrocarbon production no longer
poses unacceptable risks even in nearshore areas) and propose to
relax the restrictions on activities within State waters imposed
by State law, NOAA will propose similar changes to the sanctuary
regulations unless it determines such changes would be clearly
inconsistent with the sanctuary. Of course, there would be no
guarantee that such a change would be adopted as proposed after
the rulemaking procedures were completed. In addition, California
can always impose stricter requirements on activities in State
waters than provided by the sanctuary. Thus California is pro-

F-126

vided with a considerable measure of assurance that the sanctuary
will continue to respond to its coastal issues and need.

--Permits for certain research activities

Permits to conduct specific research activities which are other-
wise prohibited by sanctuary regulations may be issued by the
Assistant Administrator of the Office of Coastal Zone Management
if such research is: (1) directly related to the resources of the
.sanctuary or (2) to further the sanctuary's education value, or'
(3) for salvage or recovery operations.

A permit system would allow research activities which would
otherwise be prohibited by sanctuary regulations. For instance a
study of the effects of introducing pollutants could be permitted
if it would contribute toward increased understanding of the
sanctuary area and its resources and not cause substantial harm.
The primary advantages of the permits would be to allow research
projects which could not be allowed on an uncontrolled basis and
to enable more effective management of the resources. OCZM would
seek to coordinate its permit process with that administered under
The Marine Mammal Protection Act, the Endangered Species Act, and
any systems implemented at the Channel Islands National Park.

--Defense Activities

The regulations shall not prohibit any activity conducted by the
Department of Defense that is essential for national defense or
because of emergency. Such activities shall be conducted consis-
tently with the sanctuary regulations to the maximum extent
practicable.

F-127

The Navy has ongoing efforts to protect the natural mari.ne re-
sources of San Miguel Island. These include turn,ing management
authority for San Miguel Island over to the National Park Service
and conducting its activities in area s as far away as practicable
,from key marine mammal and seabird concentration points such as
Point Bennett on San Miguel Island.

NOAA/Navy consultation efforts might enhance protection of marine
life in the area. Increased protection might be realized through
monitoring and studies which would coordinate military operations
and provide guidance to assure minimum interference with critical
life stage periods and habitat areas for significant marine life.
Since military operations necessary for national defense or
emergency will not be prohibited, the sanctuary will not signi-
ficantly inhibit military activities.

A potential threat to marine birds and mammals is the United
States Air Force's Space Shuttle Vehicle System (SSVS). This
project is expected to create overpressures resembling jet air-
craft sonic booms in and around the northern Channel Islands
during both takeoff and reentry (see Section E.3.0. The Ai r
Force is now conducting a special noise impact study to evaluate
the intrusive effect which these intermittent flights could have
upon island fauna, including seabird and marine mammal popula-
tions, 'particularly on San Miguel Island (Wooten, 1979, personal
communication).

F-128

In the proposed sanctuary, NOAA and the Air Force would consult
both during this impact assessment period and throughout the life
of the SSVS. The effects upon marine birds and mammals could be
closely monitored and, wherever possible, joint steps could be
taken to minimize environmental, harm without hindering the pro-
gram's effectiveness

--Fishing and Plant Harvesting

Fishing and plant harvesting are not subject to sanctuary regula-
tion (except with respect to discharges.)

In its decision advising NOAA to proceed with the preparation of a
Draft Environmental Impact Statement for the proposed marine
sanctuary, the California Coastal Commission (CCC) also recom-
mended that the management of living marine resources remain under
the jurisdiction of the California Department of Fish and Game
(DFG) and the Pacific Fisheries Management Council (PFMC). In its
evaluation of this issue, NOAA considered whether, under the
present regulatory structure, sufficient protection for sanctuary
resources existed. At present, fishery resources in the proposed
sanctuary do not appear to be suffering from overharvesting (Frey,
1980, personal communication),

NOAA did evaluate the possibility of proposing some sanctuary
management of this activity. However, the existing management
authorities, the California DFG within State waters and the PFMC
beyond State waters, have comprehensive management authority over
these resources. Moreover, the long term interests of these
agencies parallel those of the marine sanctuary: ensuring healthy
stocks and protecting important habitat. Therefore, no signi-

F-129

ficant advantage would be gained by adding, the a dditional pers-
pective of the sanctuary managers to decisions on management of
these stocks and, by relying on the existing arrangements, NOAA
will avoid duplication of regulations and programs. In addition,
the close coordination and consultation which has already been
initiated between the DFG and NOAA and which will be expanded to
include the PFMC, in dicates that sanctuary concerns, if any, will
be fully communicated to the authorities dealing with these on-
going management issues.

NOAA will consider the possibility of making funds available for
technical assistance for studying the area's marine finfish,
shellfish, and plant resources and for strengthening the present
enforcement capabilities of the DFG and other enforcement entities,
including the National Park Service and the Coast Guard.

--Emergencies

Activities necessary to respond to an emergency threatening life,
property, or the environment are exempted from the proposed
sanctuary regulations described above. Thus, uses of the area
such as for harbors of refuge or during air-sea rescue operations
are allowed in an emergency, even though the action would other-
w1se violate marine sanctuaries regulations.

F-130

F.3.- ALTERNATIVE 3

Boundaries

The sanctuary consists of those waters off the coast of California
adjacent to the northern Channel Islands and Santa Barbara Island,
seaward to a distance of 6 nautical miles (11.1km).

The non-regulatory aspects of the proposed marine sanctuary--
assessment, education, long term planning and coordination--
parallel those set out and discussed for the preferred alter-
native, with one exception. The differences between this alter-'
native and the preferred relate generally to the degree and
stringency of r egulation. The boundary and the proposed reg.ula-
tions which were considered for discharges, removing or damaging
historic or cultural resources, defense activities, and fishing
and plant harvesting are the same and have the same environmental
consequences as those discussed in the preferred alternative.
More stringent regulations for hydrocarbon operations, seabed
alterations, operations of vessels and aircraft, and firearms, as
well as management provisions, are described below, and alter-
native 3 is compared to the preferred alternative at the end of
this section.

Prohibited Activities

Hydrocarbon operations

F-131

(a) Hydrocarbon exploration, development and production activi-
ties are prohibited except pursuant to any lease executed prior to
the effective date of these regulations which is located entirely
within the sanctuary. Operations on such leases and the laying of
any pipeline is allowed subject to paragraph 935.6(b), and all
prohibitions, restrictions, and conditions imposed by appl,icable
regulations, permits, licenses, or other authorizations and consis-
tency reviews including those issued by the Department of the
Interior, the Coast Guard, the.Corps of Engineers, the Environ-
mental Protection Agency, and the California Coastal Commission
pursuant to the Coastal Zone Management Act and its implementing
regulations.

(b) No person may engage in any hydrocarbon operation unless the
following oil spill contingency equipment is available at the site
of such operation.

(1) 1500 feet of open ocean containment boom on a
boat capable of deploying the boom:

(2) one oil skimming device capable of open ocean
use; and

(3) fifteen bales of oil sorbent material.

(c) Resources underlying tracts located partially within the
sanctuary may be recovered by directional drilling from platforms
outside the sanctuary boundaries.

The environmental consequences of prohibiting operations on future
leases within 6 nmi (11.1km) are the same as those of the prefer-
red alternative. Alternative 3 is, however, more stringent
because the siting . of drilling rigs and platforms within the
sanctuary is prohibited, except on tracts 243 and 244 which are
located entirely in the proposed sanctuary. Without this exclu-
sion, the lessees of tracts 243 and 244 would be completely
prohibited from developing their lease. The prohibition on
operations affects these existing tracts: 203, 204, 205, 243, 244,
245, 246, 247, 2893. 290, -and 291 (see Figures F-12 and F-13).

F-132

Under this alternative, resources from these tracts may be re-
covered only by drilling from platforms situated more than 6 nmi,
(11.1km) from the islands.,

Generally, this prohibition would extend the level of resource
protection provided by the preferred alternative's prohibition of
oil and- gas operations on future leases within.6 nmi (11.1km)
around the five islands (except. for tracts 243 and 244). This
action would further lessen the risk of oil spills and routine
discharges reaching sensitive nearshore resources in toxic quan-
tities and would increase the response time available for at-sea
oil spill containment should a spill occur on an e xisting lease.
Supply boat traffic and other disturbances associated with oil and',
gas development would also be reduced near the islands.

The economic effects of prohibiting the location of platforms and
rigs on existing leases within 6 nmi (11.1km) of the islands are
difficult to quantify. Operators can still exploit some resources
in the sanctuary from platforms located beyond the 6 nmi (11.1km)
boundary, but this siting requirement is likely to increase the
cost of reaching these reserves and/or reduce the total amount of
reserves ultimately recoverable from that lease. Al though no
drilling is currently occurring within 6 nmi (11.1km) of the
islands, several adjacent discoveries have been made. For
example, tract 202 and the adjacent tract 203, are being developed
by Union; a platform--Gina--is to be located on tract 202.
Platform Gina will, be approximately 9 statute miles (14.4km) from
Anacapa Island (Adams, 1979, personal communication). Discoveries
have also been made on tracts 204 and 205. Because of the traffic
separation scheme (TSS) and policies against siting in it, the
exploratory wells to define these reserves were drilled north of
the TSS and thus further from the,islands. Because the rest of

F-133

the reserve appears to underlie tracts 208 and 209 (north of the
islands -- see Figures F-12 and F-13), the platform will probably
be sited north of the northerly TSS lane and thus well beyond the
6-nmi (11.1km) boundary (Adams, 1979,,personal communication).

Because tracts 245-247 south of Santa Rosa Island have had no
exploratory wells and tracts 289-291 near Santa Barbara Island
have had one, no reliable estimate of reserve potential, location
of reserves, or possible platform location can be made (Adams,
1979, personal communication). Chevron has applied for a permit
for exploratory drilling of one well on tract 245 and will carry
out operations in 1980 (California Coastal Commission, 1980).

The rationale for and effects of NOAA's required additional onsite
oil spill contingency equipment are discussed under alternative 2,
the preferred alternative.

Alteration of or Construction on the Seabed

Within the sanctuary, no person shall dredge, drill, or otherwise
alter the seabed in any way, nor construct any structure, except
for navigation aids (or in co'nnection with any hydrocarbon explor-
ation or exploitation activity or the laying of pipelines other-
wise allowed by sanctuary regulation).

This regulation differs from that of the preferred alternative by
extending the prohibition over the entire sanctuary area rather
than only within 2 nmi of the islands. This expanded prohibition
offers slightly greater protection from displacement or sediment
smothering to the benthic resources of the proposed sanctuary;
however, it would provide relatively little additional protection
to marine birds and mammals, and shallow subtidal and intertidal
organisms.

F-134

Operation of Commercial Vessels

Except to transport persons or supplies to or from an Island, no
person shall operate within one nautical mile of an Island any
vessel engaged in the trade of carrying cargo, including but not
limited to tankers and other bulk carriers and barges, or any
vessel engaged in the trade of servicing offshore installations.
In no event shall this section be construed to limit access for
fishing (including kelp harvesting), recreational, or research
vessels.

Within the remaining portions of the sanctuary:

U.S. flag and, to the extent consistent with
international law, foreign flag vessels
(except for fishing, military, kelp harvesting,
enforcement, research, and recreation vessels)
traveling parallel to established shipping lanes
shall remain in those lanes.

Alternative 3 incorporates from alternative 2, the prohibition on
most commercial vessel traffic within 1 nmi (1.8km) of the
islands. In addition, alternative 3 requires that all commercial
traffic -- U.S. flag and, to the extent consistent with inter-
national law, foreign flag vessels -- traveling parallel to
established shipping lanes must remain in shipping lanes while
transitting sanctuary waters.

F-135

As discussed under the ' preferred alternative ' most commercial
traffic already follows the traffic separation scheme. Further-
more, the Coast Guard has begun studying the possibility 'of
designating a port access route which would be mandatory in the
Channel. This regulation would ensure that affected traffic would
remain at a greater distance from the Islands than dictated by the
preferred alternative which would simply prohibit certain. traffic
i n a 1 nmi area. At least in the short term, this would add some
protection from trip shortcuttings, either through Island passages
or closer to shore, thus removing certain collision, intrusion,
and pollution risks from the Islands' nearshore sensitive re-
sources, discussed in the preferred alternative and in Section E.
Since few large commercial vessels have used such shortcuts,
neither major environmental benefits nor inconvenience to commer-
cial shipping traffic is envisioned.

Generally speaking, requiring vessels to adhere to designated
shipping lanes is an action pursued for the safety of navigation.
If mandatory lanes within the sanctuary would decrease the general
risk of vessel collision and subsequent spills of certain cargo,
such requirements could reduce the threats of harm to sanctuary
resources from pollution. The on-going Coast Guard study con-
cerning the designation of a PAR in the Channel is considering
such issues of navigational safety, but the conclusions of the
study are currently unavailable.

Disturbing Marine Mammals and Birds by Qverflights

Within 1 nmi of any Island, no person shall disturb seabirds or
marine mammals by flying motorized aircraft at less than 1000 feet
(305m) except:

F-136

(A) for enforcement purposes;

(B) to engage in kelp bed surveys; or'

Within the remaining portions o,f the sanctuary no person shall fly
any aircraft at less than 500 feet (152.1m)..

NOAA's regulation.of overflights under alternative 3 would include
and expand upon regulations described under the preferred alter-
native. In addition to prohibiting 'overflights below 1000 feet
(305m) within 1 nmi (1.8km) seaward of the mean high tide line of
the islands and exposed rock, NOAA would prohibit aircraft flights
below 500 feet (152m) over all o ther areas of the sanctuary.

This regulation would extend protection to marine mammals and
birds from low flight engine noise to offshore areas of a 6-nmi
(11.1km) sanctuary, as well as the more sensitive nearshore areas.
The purpose of this added regulation is to protect swimming marine
mammals from harassment by aircraft engaged in whale watching or
other activity. As described under the preferred alternative,
this regulation would affect only some charter planes and recrea-
tional flyers; commercial carriers do not fly at such low alti-
tudes and military planes and kelp survey flights are exempt.
This regulation would not supercede more stringent regulations
pursuant to the Marine Mammal Protection Act.

F-137

Firearms

No person shall use firearms, except as necessary for military
operations and enforcement.

This regulation is designed to protect the area's resources from
direct harm and indirect disturbance, as well as to protect the
safety of sanctuary users. Because State and Federal regulations
(see section F.Lb.) prohibit the use of firearms in many situa-
tions, the impacts of this prohibition on sanctuary users are
expected to be minimal.

Other Activities

Fishing and Plant.Harvesting

Fishing and plant harvesting are not subject to sanctuary regula-
tions, except in specified research zones (see Management, below).

The implications of restricting the harvesting of living marine
resources in specified research zones are discussed in the Manage-
ment section. Otherwise, the environmental consequences of this
regulation are the same as those discussed in the preferred
alternative.

Fs- 138

Management.

The management system,applied under this alternative would be the
same as that described under the preferred alternative, except
that this alternative would establish specific research zones in
the sanctuary. Because of similarities between alternative 3 and
the preferred alternative, the discussion focuses on establishing
additional research areas.

The purpose of establishing resea rch zones would be to dedicate
areas within the, sanctuary to research. One of the primary
purposes of these sites is to gather baseline information on
sanctuary conditions which reflect as closely as possible the
natural undisturbed state of ecosystem processes, biotic diver-
sity, abundances, and general environmental conditions. Neither
the exact, location, number, or size of these areas has been
selected; such specifics would be developed after a more thorough
consultation with area researchers, area user groups, and applic-
able authorities, such as the California DFG. In general , the
system of sanctuary research areas envisioned might include
perhaps three to five sites of variable sizes dispersed throughout
the sanctuary (e.g., one or two off San Miguel, one off Anacapa
Island, and one off Santa Barbara Island).

Within these research zones, only selective scientific studies
such as taking water samples or limited numbers of marine organ-
isms for laboratory analysis would be allowed. Other uses within
reserves zones would be limited to those with negligible impacts.
Boat access would be allowed on a case-by-case basis but all
consumptive or po tentially poll uting/disturbing uses would be
prohibited. Commercial and recreational fishing would be limited
to areas outside research zone boundaries. Discharges, transit by
large vessels, pipelines, and other potentially disruptive uses

F-139

would similarly be excluded. Research would be allowed in these
zones under permit from sanctuary managers and would be controlled
to prevent significant impact to natural resources. NOAA would
seek inclusion of these marine research zones in existing systems
which identify and/or set aside areas solely for research pur-
poses. Examples include the National Science Foundation's system
of Experimental Ecological Reserves and the Federal Committee on
Ecological Reserves' system of Research Natural Areas.

This management measure would result in an improvement in natural
conditions within established research zones. The extent of
improved protection would be proportional to the - extent that
disruptive activities are excluded. The information developed
from studies within these zones will assist sanctuary managers in
assessing effects other sanctuary users might have on different
portions of the sanctuary. In this manner, research zones should
have a beneficial effect of areas beyond their boundaries through
their contribution to improved management capability. The esta-
blishment of research zones would thus recognize research inter-
ests as representing a valuable ocean use which has a right to the
exclusive use of localized ocean areas in much the same manner
other areas are set aside for recreation, military activities, or
oil and gas development.

The establishment of research zones could limit and perhaps
displace several other uses of the area's resources, most notably
fishing and plant harvesting and various recreational activities.
The extent of these impacts would be proportional to the size of
the area and the intensity to which it is currently used.

F-140

The displacement of uses, such as,recreation, from these research
areas may intensify use and impacts in other ocean areas. For
example, the prohibition of recreational diving from a previously
available area could lead to increased diving pressure in another
area. NOAA would try to minimize such potential impacts and
concerns by working closely with both area users and research
interests on the selection of areas. Areas with high research
value and minimal use for fishing and plant harvesting and recrea-
tion would be sought.

Comparison with the Preferred Alternative

Although Alternative 3 proposes more stringent regulation of
certain activities and@might be viewed as more environmentally
protective than the preferred alternative, it has been rejected
for several reasons.

The proposed sanctuary prohibition of any exploration, development
and production activities on existing leases within the proposed
sanctuary does not appear appropriate at this time. In some
situations, depending on geologic and other factors which vary in
each case, the slant drilling which might be required to explore
and extract resources may pose a range of technical problems for
operators, including increased time and cost on site, and increas-
ed risk of adverse geological conditions. These questions, as
well as the extent to which the requirement may dimish the extent
of recoverable resources, appear to be appropriate for case-by-
case consideration, evaluating all information available.

F-141

NOAA has rejected the possib,ility of sanctuary review and certi-
fication of each application for activiti*es on existing leases
within the 6 nmi boundary primarily because such review is now
exercised by both the United States Geological Survey and the
California Coastal Commission. In particular,,the review by the
California Coastal Commission gives primary consideration to the
protection and preservation of the sensitive Island and marine
resources within the State's coastal zone. The Commission applies
policies and regulations governing the protection of marine
resources, location of oil spill control equipment,, and the siting
of development adjacent to environmentally sensitive areas. For
instance, in, its review of Chevron's consistency certification of
its permit for drilling one exploratory well on Tract 245, approx-
imately 1.7 nmi inside the proposed sanctuary boundary, the
Commission required that. operations not begin before June 15,
1980, in order to reduce the risks to the large number of harbor
seals present in the spring, and required a special drill for,
deployment of oil spill containment equipment (Baird, 1980,
personal communication). In its staff recommendation which found
Chevron exploratory permit consistent, the Commission noted that
location of a production platform within 6 nmi of the Channel
Islands would not be consistent with the California Coastal
Management Program because a production platform would involve
various activities posing unacceptable threats to the sensitive
marine resources in this zone and emphasized that the exploratory
operations were to proceed with full knowledge of this policy
(California Coastal Commission, 1980).

In light of the existing case-by-case agency reviews by the USGS.
and the California Coastal Commission, and because there are only
sixteen tracts presently leased within the 6 nmi boundary which
restricts significantly the extent of possible operations in any

F-142

event, sanctuary restrictions do not presently appear necessary.
Should future data support reconsideration of this matter, regu-
lat6ry changes can be proposed and subjected to public review and
comment.

The regulation prohibiting seabed alteration and construction
throughout the sanctuary would provide little protection beyond
the preferred alternative to marine birds and mammals and inter-
tidal and -nearshore subtidal organisms. These resources are most
vulnerable to disturbance in the nearshore areas close to breeding
and haulout sites. Known concentrations of special benthic and
intertidal organisms also occur, primarily close to the Islands.
Although there may be important benthic resources beyond 2 nmi
from the Islands which could be smothered or otherwise damaged by
seabed alteration, there is . not enough evidence of resource
concentration to justify a blanket prohibition on seabed alter-
ation dredging, and construction beyond 2 nmi from the Islands.
Existing authorities (the California Coastal Commission and the
Corps of Engineers) already provide case-by-case review of such
activities.

The regulation prohibiting most commercial vessels from the waters
within one nautical mile of the Islands is identical to the
regulation in the preferred alternative. Vessel traffic beyond
one nautical mile from the Islands is considerably less likely to
disrupt critical bird and mammal behavior, and since most vessels
observe the TSS anyway, additional regulation requiring vessels to
stay within the shipping lanes does not seem necessary. Further-
more, of course, such a requirement could be applied to foreign
flag vessels only to the extent consistent with international law,
which may limit its impacts in an area like the Channel where
foreign flag traffic is substantial. Most importantly, the U.S.

F-143

Coast Guard has authority to designate mandatory port access
routes (PAR), and has an ongoing PAR study to determine the desir-
ability of such a measure. If this study indicates that mandatory
shipping lanes are necessary in the Santa Barbara Channel,- the
Coast Guard presumably will' designate them on a Channel-wide
basis, after considering the complicated i ssues of use and loca-
tion, which would provide greater navigational safety than a
mandatory VTSS ap plying only within a 6 nmi sanctuary. In light
of this study and the extensive consideration that the Coast Guard
is devoting to accommodating other uses and resources of the
Channel, including a possible marine sanctuary, imposing mandatory
shipping lanes within the 6 nmi boundary through sanctuary regu-
lations is not advisable.

The 500 foot (152m) overfl ight restriction from 1 nmi RAW to 6.
nmi (11.1km) offshore is also not warranted because, as described
above in - the preferred alternative, the greatest danger from
disturbance to marine birds and mammals is at rookeries, resting
places, and in the nearshore waters, Beyond one mile from shore,
the harassment provisions of the Marine Mammal Protection Act
probably provide adequate protection.

The need to restrict firearms is presently unclear. Federal and
State laws regulate the use of firearms and hunting of most
species in the area; additional regulation does not appear war-
ranted at this time.

The additional controls imposed upon uses, including fishing and
plant harvesting, in speciffed research areas would provide some
protection for the area's resources beyond that afforded by the
preferred alternative. At the present time, however, the need for
an additional level of protection is unclear. Al though the

F-144

establishment of research zones could have substantial benefits
for research, NOAA prefers to work-with the California DFG through
the State's ecological reserve program to accomplish this. The
other aspectsof sanctuary management are the same as those in the
preferred alternative.

F-145

ALTERNATIVE 4

Boundaries.

The sanctuary consists of the entire Santa Barbara Channel from
Point Arguello to Point Mugu and 12 nautical miles around the
northern Channel Islands and Santa Barbara Is land.

This sanctuary includes the Santa Barbara Channel from Point
Arguello north of Point Conception to Point.Mugu east of Anacapa
island and exten ds 12 nmi (22.2km.) seaward from the high water
mark around the northern Channel Islands and Santa Barbara Island.

In addition to the resources contained in the preferred alter-
native, this boundary would encompass other habitatsof marine
birds and mammals and intertidal and subtidal flora and fuana on
the mainland shelf and coast and the Santa Rosa-Cortes Ridge and
Plateau. As discussed in Section E, numerous kelp beds dot the
mainland coast, fish are harvested throughout the Santa Barbara
Channel, seals haulout on the mainland, gray whales migrate
through the Channel twice yearly, and recreational boating,
surfing, diving, and beach visits are important uses of mainland
coast. Several biologically valuable wetlands are also included
in this boundary alternative.

At the same time, development and use levels are high beyond 6 nmi
for the Islands. Most of the current and past hydrocarbon devel-
opment in the Channel is near the mainland. Tankers and freight-
ers travel through the Channel in large numbers. Coastal develop-

F-146

ment, both residential' and industrial, results in the discharge of
wastes into the Channel and dredging and construction. Other
economically important projects, such as the planned construction
of a liquid natural gas terminal at Point Conception, are planned
for the waters encompassed in this expanded alternative boundary.

Prohibited Activities

There did not appear to b e any need for different regulation of
overflights, removing or damaging historical or cultural re-
sources, defense activities, and fishing and kelp harvesting in
the expanded area than have already been discussed in the prefer-
red alternative. The possibility of prohibiting discharges in the
expanded sanctuary was considered, as was the advisability of
alternative regulation of vessel traffic, hydrocarbon operations
and placement of structures. Various restrictions on these
activities and their relation to the objectives of preserving the
marine resources at acceptable costs without significant dupli-
cation of existing 'processes are discussed below.

Hydrocarbon Operations

(a) Except as provided in paragraph 935.6)(c), hydrocarbon explora-
tion, development, and production, and the laying of any pipeline is
allowed subject to paragraph 935.6(b), and all prohibitions,
restrictions, and conditions imposed by applicable regulations,
permits, licenses, or other authorizations and consistency
reviews, including those issued by the Department of the Interior,
the Coast Guard, the Corps of Engineers, the Environmental Protec-
tion Agency, and the California Coastal Commission pursuant to the
Coastal Zone Management Act and its implementing regulations.

F-147

(b) No person may engage in any hydrocarbon operation unless the
following oil spill contingency equipment is available at the site
of such operation.

(1) 1500 feet of open ocean containment boom on
a boat capable of deploying the boom;

(2) one oil skimming device capable of open ocean
use; and

(3) fifteen bales of oil sorbent material.

(c) Hydrocarbon exploration, development and production activi-
ties within 6 nmi of the Islands pursuant -to leases executed on or
after the effective date of these regulations are prohibited.

Placement of Structures

Within any vessel traffic separation scheme (VTSS) or port access
route (PAR) designated by the Coast Guard or within a quarter nmi
thereof, no person shall locate any structures which could be
struck by a vessel using or likely to use the VTSS or PAR, except
for a navigation aid.

The primary threat to the preservation of the rich and fragile
.ecosystem in the nearshore Island waters originating from activi-
ties beyond the 6 nmi zone and to the wetlands and other resources
of the expanded sanctuary under review in Alternative 4 is the
risk of major spills from hydrocarbon exploration, development and
transporation. A large spill anywhere in the Channel or within a
considerable distance seaward of the Islands could reach the
Islands and might heavily impact their living marine resources.
The results of the 1969 Channel blowout and theIxtoc incident are
cited as evidence of the dangers to the nearshore zones from
distant activities. Similar observations are possible concerning

F-148

accidents involving tankers transporting hydrocarbons, LNG, or
other hazardous substances. Such activities also threaten the
nearshore mainland waters and their resource.s. Various approaches-
to possible sanctuary control of these risks were considered, with.
detailed evaluation given to the restrictions embodied in the
regulations set forth above.

Within 6 nmi (11.1km) of the northern Channel Island s and Santa
Barbara Island, alternative 4 proposes the same restrictions as
the preferred alternative, except that the location of structures
'is prohibited in the tanker lanes and separation zone and within
one-quarter nmi (0.45km) of the lanes. In particular, . this
provision would affect hydrocarbon exploration and production on
tracts 203, 204, 205, and 210 within 6 nmi (11 *1km) and develop-
ment on certain leases (including 202, 209, 221, 222, 223, 230A,
231, and 232) beyond 6 nmi (11.1km) from the islands which are
traversed by the curre nt tanker lanes or separation zone.

NOAA's restriction on the location of structures in 'and within
0.25 nmi (0.45km) of shipping lanes in the sanctuary is similar to
the California Coastal Commission's (CCC) stated policy for
consistency review that location of structures within vessel
traffic lanes or within 1650 ft. (500m) of them is inconsistent
with the policies and objectives of the California Coastal Plan
(California Coastal Commission, 1979). NOAA's restriction would
also be consistent with the special condition attached by the Army
Corps of Engineers on the recommendation of the Coast Guard to
Exxon's permit to anchor a drillship in navigable water for
exploratory drilling on tracts 222, 223, 230, 231, 232, and 238.
The special condition provided -"(flhat vessels shall not engage
in drilling inside sea lanes or within one-quarter nmi (0.45km) of
established sea land boundaries" (California Coastal Commission,

F-149

1979). The purpose of this prohibition is to eliminate the hazard
of a collision or ramming and possible subsequent oil spills, that
the presence of , a fixed structure within a designated vessel
traffic lane or buffer poses to navigation. The Coast Guard is
undertaking a major study of the necessity of designating 'fairways
in the Channel within which such structures would be prohibited or
a modified version of a fairway where placement would be restrict-
ed.

NOAA's requirement for on site oil spill containment equipment has
has the same en .vironmental consequences as discussed in the
preferred alterna tive . and is applied for the same reason--to
insure more effective at-sea oil spill containment. In al ter-
native 4 however, this stipulation applies to all development
around the Islands and in the Channel.

Vessel Traffic

In evaluating the expanded sanctuary, NOAA reviewed the possi-
bility of requiring vessels to adhere to shipping lanes designated
by the Coast Guard to the degree consistent with international
law. The routing of vessels laden with hydrocarbons and other
hazardous substances outside the Channel was also considered.
Both requirements are among the actions being evaluated by the
Coast Guard in its on-going study of the need to designate port
access.routes in the Channel area.

F-150

Discharges

ROAA considered the possibility of regulating discharges in the
entire area included in alternative 4. The limitations on dis-
charges in the nearshore Island zone of the-preferred alternative
are designed to protect the waters which are heavily used by
marine mammals, seabirds and recreationists. There is no dis-
charge from municipal or industrial sites occurring in this
smaller area. The territorial waters on the mainland coast
receive a variety of discharges and, although recreational use is
high, the populations of mammals and birds are fairly scattered in
this area.. Discharges of various sorts are currently regulated by
permit requirements of State and Federal agencies.

Comparison with the Preferred Alternative

Consideration of this larger sanctuary where current and potential
development is much greater than within the 6 nmi of the Islands
raises issues of resource focus, the practicality of management of
the area, and the reasonable form of possible sanctuary regula-
tion.

The marine sanctuary proposal emphasized first and foremost the
existence of special resources, worthy of national attention and
preservation. The nearshore Island waters contain the most
intense concentration of valuable biological resources within the
larger area. The use of the nearshore Island waters by seabirds
and marine mammals appears to be qualitatively different than
their use of other waters of the Channel, although assuredly the
birds and mammals do range beyond the 6 nmi boundary. While the
territorial mainland waters also have high recreational use, and
include valuabl e wetlands- and significant kelp beds, from a

F-151

resource perspective, NOAA concluded during its evaluation of the
potential sanctuary, that the Island waters comprised an identi-
fiable unit, which also could benefit from the long term planning,
research, monitoring, education,' and management A ich a mari ne
sanctuary can provide. While the expanded area described in
Alternative 4 also is a valuable marine area rich in ecological
and recreational resources, the intensity of certain resources
varies considerably. Because the resources are diffuse, among
other reasons, the waters of the larger area do not constitute a
readily identifiable unit from a management perspective.

While this larger sanctuary might also benefit from management
activities, the impact of the program would be diminished.
Limited program resources for research, monitoring, surveillance
and enforcement would be spread over a much greater area. The
benefit to the expanded sanctuary.would be less than that for a
smaller management area.

With respect to regulatory alternatives, since the expanded
boundary includes an area of variable resource concentration and
an area which is presently heavily developed and proposed for
expanding development, overall. prohibitions of activities beyond
those already discussed for the 6 nmi area were rejected. That
is, even should a large s anctuary be designated, NOAA concluded
that only the nearshore Island waters, where development is
minimal and resources concentrated, should reasonably be subject
to prohibitory regulations. In the nearshore zone prohibitions
such as those restricting discharges, activities on new hydro-
carbon leases, and certain vessel operations and overflights can
add to the protection available for the resources without imposing
unacceptable costs. The level and diversity of economic develop-
ment, in combination with the dispersed resources, renders prohi-

F-152

biti.ons'inappropriate in the largerarea.

The alternative regulatory approach in the expanded sanctuary
would be case-by-case review by the sanctuary of each decision to
discharge, perform hydrocarbon operations, or locate a structure
.in a VTSS. Almost all these decisions are now subject to at least
two levels of case-by-case review--once by a Federal agency and
once by California Coastal Commission. Given the existence of
this case-by-case review, where environmental concerns are taken
into account, institution of another level of review for each
situation appeared inappropriate.

For instance, NOAA considered the possibility of restricting
hydrocarbon activities on any new lease within the Alternative 4
boundaries, either indefinitely or for a specified period, such as
a 'five year moratorium. Even though a majority of the'tracts in
the Channel, including those near the ma inland, have already been
leased and other tracts near Santa Barbara have been designated
informally as a non-leasing are a by DOI and the State of Cali-
fornia, such a provision would still affect over '50 tracts. The
likelihood of substantial recoverable petroleum resources under-
lying the tracts still unleased on the mainland side of the
Channel, in combination with the concern of industry and other
regulating agencies to allow orderly development of resource
basins, weighed heavily against a flat prohibition. Furthermore,
the resources of particular concern in relation to hydrocarbon
operations occur in dispersed areas of concentration and this
scattering militates against a prohibitory regulation for the
entire expanded area. This conclusion is reinforced by the fact
that two levels of agency review of all hydrocarbon operations on
new leases already occur. The Federal agencies take environmental
cons iderations into account. in lease sale, exploration and devel-

F-153

opment decisions,.and the California Coastal Commission has long
exercised its consistency review with a special concern for the
preservation of the Islands' nearshore ecosystems.

In summary, the potential economic costs and the differences of
the resources indicated a prohibitory regulation was inappro-
priate. Since the current system provides at least two levels of
case-by-case review, a third level.of sanctuary review w as reject-
ed.

NOAA reached similar conclusions concerning other possible regu-
lations in the expanded sanctuary after an evaluation of the
economic costs of prohibition in the sanctuary, the diffuse nature
of the resources, and the existing levels of case-by-case review.*
Prohibitions on discharges in the expanded sanctuary were consi-
dered unworkable given the degree of development,; particularly
along the mainland territorial sea. The . blanket. prohibition
against locati,ng of structures in vessel traffic lanes was reject-
ed in part because there may be extraordinary situations in which
such location is necessary. Additionally, as discussed in Alter-
native 3, action to require adherence to vessel traffic lanes was
rejected as premature, since most . vessels now adhere to esta-
blished lanes and the subject of mandatory lanes is under intense
study by the Coast Guard.

The role of the sanctuary as a coordinator for all activities on a
case-by-case basis in the expanded sanctuary was considered. The
primary management need in the larger boundary- appears to be
coordination of various on-going uses, such as location of dril-
ling structures and routing of vessels. Some coordination ques-
tions are currently subject to case-by-case review each time a
permit application is considered by a Federal agency and each time

F-154

the California Coastal Commission reviews a consistency certifi-
cation. Some are under review by the Coast Guard in its study of
port access routes. . The existing institutional structures, while
not fully centralized, do provide some coordination of activities.
A marine sanctuary overlaid on the existing institutional struc-
tures now dealing with questions of coordination on a case-by-case
basis is unlikel.y to add sufficiently to the degree of information
exhanged, the data available, or the points of view considered to
justify the additional burde'n which would be placed on limited

program resources.

Finally, NOAA also considered whether the expanded boundary and
regulation of activities there were required to preserve the
nearshore Island resources. The nature of the marine environment
is such that restricting activity a considerable distance from the
concentration of the resources might be required in order to
minimize or eliminate the risk of any harm. This seems parti-
cularly true of the risks involved in hydrocarbon exploration,
development and transport. NOAA concluded that, while certain
activities outside the 6 nmi zone would continue to pose a threat
of some harm to the nearshore Island resources, there was no
meaningful. way to reduce the level of risk without completely
banning the activity. Eliminating all drilling and tanker traffic
would add to the protection of the proposed sanctuary, but the
margin of safety would be purchased at an enormous cost. The
objective of the sanctuary program to preserve certain valuable
marine sites cannot in every situation be equated with the elimi-
nation of all risk of harm at the cost of all other socially and
economically valuable activities. Therefore, prohibitory regu-
lations on hydrocarbon production and transport were rejected.
Case-by-case review was similarly rejected for the reasons out-
lined above and because it seemed unlikely to add significantly to
the protection of the nearshore Island resources.

F-155

In summary, because of the diffuse resource. characteristics, the
level of economic d evelopment, and the present regulatory struc-
ture which assures case-by-case review by Federal and, State.
agencies, both overall prohibitory regulation of the activities at
issue and case-by-case sanctuary review were rejected as regul-
atory approaches in. any expanded sanctuary. In addition, the
greater area and dispersed resources would dilute t he impact of
sanctuary research, monitoring, and education programs. The
resources of the preferred alternative comprise an identifiable
unit capable of sanctuary management and likely to benefit from
certain regulatory sanctuary measures. On balance, the smaller
sanctuary is more appropriate given present program goals and

resources.

F-156

ALTERNATIVE 5

Boundaries

The sanctuary boundary consists of the waters 3 nautical miles
(5.6km) beyond the territorial Sea (State waters) around the
.northern Channel Islands and Santa Barbara Island.

The 3-nmi (5.6km) "donut" around the northern Channel Islands and
Santa Barbara Island excludes State waters., Hence, many of the
most important habitats of valuable marine resources that concen-
trate in the up per Island shelf waters would not be included in
the sanctuary. This exclusion, even if cooperative agreements
were executed between NOAA and the State, renders long term
planning, research, and educational programs less significant
because they would not address fully the most important resource
areas. This failure to include important natural resource areas
within the boundary compromises the potential for the sanctuary
designation to assure long term preservation of the critical

resources.

Provisions to establish: (1) a Sanctuary Information Center, (2)
a registry of research projects, (3) a monitoring program for
human uses and sanctuary resources, and (4) an effort to encourage
non-consumptive research would be similar to those described under
the preferred alternative, except they would apply to a smaller
geographic area of less direct resource significance. In terms of
research, the exclusion of State waters will significantly lower
the number of research projects subject to sanctuary management
because: (1) the inshore waters (where marine life tends to

F-157

concentrate) are attractive to a greater variety and number of
res earch projects, and (2) the geographic area is significantly
smal 1 er. The benefits of this alternative, while covering the
same types of impacts described under the preferred alternative,
will thus be considerably smaller both in terms of coordination
and protection of marine life.

Since' the sanctuary boundaries under this alternative almost
exclusively include deeper waters where the likelihood of finding
archeological resources is remote, initiation of a cultural
resource inventory is not considered appropriate. NOAA would seek
cooperative agreements with appropriate State agencies to ensure
that protective provisions applied in the s.anctuary complement and
further the resource protection objectives of the adjacent State
waters. These agreement would be designed to coordinate State and
sanctuary decision making and to reduce the potential that actions
by either party would negate resource protec tion policies and
objectives of the other.

The potential regulations concerning hydrocarbon development,
discharges of polluting substances, vessel traffic and over-
flights, defense activities, and fish and plant harvesting, as
well as the management provisions, are the same as those in the
preferred alternative. * Because of the exclusion of State waters
from alternative 5, they offer less protection to the resources.

Alternative 5 would o ffer no additional protection from nearshore
vessel traffic and overflights, from alteration of or construction
on the seabed, or from damage or removal of historical or cultural
resources. Also, because State waters are not included in this
alternative, it is possibl.e that oil and gas development could
occur within the 3-nmi (5.6km) limit. This is not likely, how-

F-158

ever, particularly at San Miguel, Santa Cruz, Santa Rosa, and
Anacapa Islands, since State Oil and Gas Sanctuaries have been
established in the waters out to 3 nmi (5.6km) around these
i sl ands. Within these sanctuaries, oil and gas development is
prohibited, except in certain instances to allow a "drainage" sale
to protect the State's economic interests. Since oil and gas
development would be prohibited in adjacent Federal waters, it is
unlikely that State petroleum resources will be drained.

Under alternative 5. littering and discharges could continue
shoreward -(in State waters) of sanctuary boundaries.

Comparison with. the Preferred Alternative

This alternative has been rejected in favor of the preferred
alternative for the following reasons. First, in terms of the
regulation of the discharge of polluting substances, the regu-
lation as stated is the same, but no protection is provided the
particularly important nearshore waters The regulation provides a
buffer from the potential impacts of oil and gas development on
the Fd'deral OCS, but does not insure that oil and gas development
is prohibited, in State waters, particularly around Santa Barbara
Island.

Primarily, in terms of management, even with cooperative agree-
ments with other agencies and the othgr sanctuary provisions
relating to the information center, promoting awareness of sanc-
tuary resources, registering research projects and encouraging
nonconsumptive research, the failure to include the most important
natural resource areas within sanctuary boundary compromises and
restricts the potential that sanctuary designation will achieve
long-term protection of critical resources.

F-159

ALTERNATIVE 6

Boundaries

The entire,Santa Barbara Channel from Point Arguello to Point Mugu
and 12 nautical miles around the northern Channel Islands and
Santa Barbara Isla*nd, excluding State-waters.

This "donut" sanctuary resembles alternative 4, but excludes all
State waters i.e., all waters within the 3-nmi (5.6km) terri-
torial sea. The remaining waters include portions of the forage
and migration areas of important resources, yet leave out the
vital waters overlying the upper island she-1f. This boundary
alternative is the same as that nominated by the County of Santa
Barbara, California (Resources, 1978).

The non-regulatory management aspect s of the marine sanctuary
program would be subject to the same limitations and deficiencies
as discussed in Alternative 5.

The regulations on discharges, and policies on defense activities,
and fishing and plant harvesting were considered the same as in
the preferred alternative except that they would not apply in
State waters and would apply throughout the Santa Barbara Channel
(excluding territorial waters) and out to 12 nmi around the
islands. They therefore, provide no direct protection for the
nearshore resources.

F-160

Under alternative 6, NOAA would not regulate overflights or the
alteration of or construction on the seabed because the exclusion
of the nearshore waters'renders such prohibition unnecessary. The
possible regulation of hydrocarbon activities, location of struc-
tures, and vessel traffic considered parallel those discussed in
Alternative 4 except that no regulation of nearshore vessel
traffic in the most sensitive areas is 'possible because of the
exclusion of the territorial sea.

Comparison with the Preferred Alternative

This alternative has been rejected in favor of the preferred
alternative based on a combination of the deficiencies identified
in the discussion of Alternative 5 which also excluded the terri-
torial sea and the problems elaborated in the discussion of
Alternative 4.

F-*161

G. RESPONSES TO COMMENTS RECEIVED..ON THE PROPOSED CHANNEL ISLANDS
MARINE SANCTUARY DRAFT ENVIRONMENTAL IMPACT STATEMENT

This section summarizes the written and verbal comments received on the
Draft Environmental Impact Statement (DEIS) and provides OCZM's response
to these comments. Generally, responses are made in one or more of the
following ways:

(1) Expansion, clarification, or revision of the EIS

(2) Generic responses to comments raised by several reviewers, and/or

(3) Specific responses to the individual comments made by each reviewer.

OCZM will publish all comments in a compendium and distribute it to persons
who commented on the DEIS, or anyone else upon request. Comments received
after March 7, 1980, are not addressed.

The following are some of the most common issues raised by reviewers:

Generic Comments and OCZM's Responses

GENERIC COMMENT A

Alternative 4 (the entire Santa Barbara Channel from Point Arguello to
Point Mugu and the waters extending 12 nautical miles (nmi) around the
northern Channel Islands and Santa Barbara Island) should be designated
as a marine sanctuary instead of alternative 2 (the proposed sanctuary)
for the following reasons:

(1) The natural resources described in the DEIS are found throughout
the Channel-, indeed, some are most prevalent beyond the boundaries
of alternative 2.

(2) Because of the circular nature of the water currents in the
Channel, activities occuring in the Channel beyond the 6 nmi sanctuary
proposed in the DEIS are extremely likely to affect the waters near the
Islands.

(3) Coordinated management of the resources and activities of the
proposed sanctuary is only realistically possible on a Channel-wide basis.

GENERIC RESPONSE A

NOAA acknowledges that important biological and ecological resources
occur in the Channel beyond the proposed marine sanctuary; for example,
numerous kelpbeds dot the mainland coast, fish are harvested throughout
the Santa Barbara Channel, seals haul out on the mainland, gray whales
migrate through the Channel twice yearly, and recreational boating,
surfing, diving, and beach visits are important uses of mainland coast.

G-1

Several biologically valuable wetlands are also included in the larger
boundary alternative. At least some of these resources are substantially
dispersed and some areas within the Alternative 4 boundary are not
characterized by particular concentrations of living marine resources.

At the same time, development and use levels are high beyond 6 nmi from
the Islands. Most of the current and past hydrocarbon development in the
Channel is near the mainland. Tankers and freighters travel through the
Channel in large numbers. Coastal development, both residential and
industrial, results in the discharge of wastes into the Channel and
dredging and construction. Other economically important projects, such
as the construction of a liquid natural gas terminal at Point Conception,
are planned for the waters encompassed in the Alternative 4 boundary.

In comparison, the nearshore Island waters contain the most intense
concentration of certain valuable biological resources within the larger
area and the use of the nearshore Island waters by seabirds and marine
mammals appears to be qualitatively different than their use of other
waters of the Channel, although they do range beyond the 6 nmi boundary.
The current level of development in the area is minimal.

Consideration of the larger sanctuary boundary where current and potential
development is much greater than within the 6 nmi of the Islands raises
issues of the practicality of management of the area and the reasonable
form of possible sanctuary regulation.

NOAA has concluded, during its evaluation of the potential sanctuary,
that the nearshore Island waters comprise an identifiable unit, which
also could benefit from the long tern planning, research, monitoring,
education, and management which a marine sanctuary can provide. While
the expanded area described in alternative 4 also is a valuable marine
area rich in ecological and recreational resources, the intensity of
certain resources varies considerably.

While this larger sanctuary might also benefit from management activities,
the impact of the program would be diminished. Limited program resources
for research, monitoring, surveillance and enforcement would be spread
over a much greater area. The benefit to the expanded sanctuary would
be less than that for a smaller management unit.

With respect to regulatory alternatives, since the expanded boundary
includes an area of variable resource concentration and an area which is
presently heavily developed and proposed for expanding development,
overall prohibitions of activities beyond those proposed for the 6 nmi area
were rejected. That is, even should a large sanctuary be designated,
NOAA concluded that only the nearshore island waters, where development
is minimal and resources concentrated, should reasonably be subject to
prohibitory regulations. In the nearshore zone, prohibitions such as
those restricting discharges, activities on new hydrocarbon leases, and
certain vessel operations and overflights can add to the protection
available for the resources without imposing unacceptable costs. The
level and diversity of economic development, in combination with the
dispersed resources, renders prohibitions inappropriate in the larger
areao

G-2

The alternative regulatory approach in the expanded sanctuary would be
case-by-case review by the sanctuary of each decision to discharge,
perform hydrocarbon operations, or locate a structure in a VTSS. Almost
all these decisions are now subject to at least two levels of case-by-case
review--once by a Federal agency and once by the California Coastal
Commission. Given the existence of this case-by-case review, where
environmental concerns are taken into account, institution of another
level of review for each situation appeared inappropriate.

For instance, NOAA considered the possibility of restricting hydrocarbon
activities on any new lease within the alternative 4 boundaries, either
indefinitely or for a specified period, such as a five year moratorium.
Even though a majority of the tracts in the Channel, including those
near the mainland, have already been leased and other tracts near Santa
Barbara have been designated informally as a non-leasing area by DOI
and the State of California, such a provision would still affect over
50 tracts. The likelihood of substantial recoverable petroleum resources
underlying the tracts still unleased on the mainland side of the Channel,
in combination with the concern of industry and other regulating agencies
to allow orderly development of resource basins, weighed heavily against
a flat prohibition. Furthermore, the resources of particular concern
in relation to hydrocarbon operations occur in dispersed areas of concen-
tration and this scattering militates against a prohibitory regulation
for the entire expanded area. This conclusion is reinforced by the fact
that two levels of agency review of all hydrocarbon operations on new
leases already occur. The Federal agencies take environmental considerations
into account in lease sale, exploration, and development decisions,and the
California Coastal Commission has long exercised its consistency review
with a special concern for the preservation of the Islands' nearshore
ecosystems.

In summary, the potential economic costs and the differences of the
resources indicated prohibitory regulation was inappropriate. Since
the current system provides at least two levels of case-by-case review,
a third level of sanctuary review was rejected. NOAA reached similar
conclusions concerning other possible regulations in the expanded
sanctuary after an evaluation of the economic costs of prohibition in
the sanctuary, the diffuse nature of the resources, and the existing
levels of case-by-case review.

Finally, NOAA also considered whether the expanded boundary and regulation
of activities there were required to preserve the nearshore island resources.
The nature of the marine environment is such that restricting activity a
considerable distance from the concentration of the resources might be
required in order to minimize or eliminate the risk of any harm. This
seems particularly true of the risks involved in hydrocarbon exploration,
development and transport. NOAA concluded that, while certain activities
outside the 6 nmi zone would continue to pose a threat of some harm to
the nearshore island resources, there was no meaningful way to reduce
the level of risk without completely banning the activity. Eliminating
all drilling and tanker traffic would add to the protection of the proposed
sanctuary, but the margin of safety would be purchased at an enormous
cost. The objective of the sanctuary program to preserve certain valuable

G-3

marine sites cannot in every situation be equated with the elimination of
all risk of harm at the cost of all other socially and economically
valuable activities. Therefore, prohibitory regulations on hydrocarbon
production and transport were rejected. Case-by-case review was similarly
rejected for the reasons outlined above and because it seemed unlikely to
add significantly to the protection of the nearshore island resources.

In summary, because of the diffuse resource characteristics, the level
,of economic development, and the present regulatory structure which
assures case-by-case review by Federal and State agencies, both overall
prohibitory regulation of the activities at issue and case-by-case
sanctuary review were rejected as regulatory approaches in any expanded
sanctuary. In addition, the greater area and dispersed resources would
dilute the impact of sanctuary research, monitoring, and education programs.
The resources of the preferred alternative comprise an identifiable unit
capable of sanctuary management and likely to benefit from certain
regulatory sanctuary measures. On balance, the smaller sanctuary is more
appropriate given present program goals and resources.

GENERIC COMMENT B

The status quo, with 11 Federal, 7 State, and various local authorities,
already provides enough protection for the natural resources described
in the DEIS. A marine sanctuary would only add an unnecessary and
expensive layer of Federal bureaucracy.

GENERIC RESPONSE B

The many Federal and State agencies which exercise authority in the
proposed sanctuary provide a considerable degree of regulatory protection
to the resources of the area. However, an area as biologically rich and
important as this deserves the particular attention to the entire range of
issues involved in long term preservation. Marine sanctuary designation
will provide this management framework which does not presently exist.

The marine sanctuary program, unlike other regulatory programs which
have jurisdiction in the area of the proposed sanctuary, offers a
mechanism to focus on this particular geographically defined marine
area and to provide comprehensive planning to preserve the resources
of the site. Other statutes either focus on management of much smaller
areas, single resources, or have resource protection only as an ancillary
goal. Marine sanctuary planning and management also includes provision
for research and monitoring of the condition of the resources to assure
long-term protection and maximum safe use and enjoyment; other statutes
do not provide in most cases the same geographically focused, comprehensive
research and monitoring effort. An educational element of the program
heightens public awareness of the value of the resources and thereby
reduces the potential for harm; again, this aspect of the marine sanctuary
program is unavailable under the present system.

G-4

The marine sanctuary proposal can fill an important regulatory role.
Presently 11 Federal, 7 State, and a multitude of regional and local
government agencies are vested with some regulatory authority over
certain activities within the area. These authorities provide a considerable
degree of protection for marine resources in general; the Channel Islands
National Park and the Ecological Reserves around San Miguel, Santa Barbara,
and Anacapa Islands protect the resources within those areas in particular.
No entity looks to the welfare of all the living resources or the ecosystem
of the marine area defined by the sanctuary proposal. Cumulative impacts
on the resources, arising from various activities subject to the jurisdiction
of separate agencies, may escape the attention of any agency.

The extraordinary diversity of natural resources concentrated in the
waters around the northern Channel Islands and Santa Barbara Island
deserves additional attention beyond that provided by the present
institutional structure. For instance, the resource protection afforded
by the Channel Islands National Park is aimed primarily at the land
based resources of the northern Channel Islands and Santa Barbara Island,
and the ecological.reserves discussed above include only the extreme
nearshore zone, providing no buffer against outside activities.

Although certain uses of the area do not now seriously threaten resource
quality here, they could have more significant impact if and when activity
intensities grow. The current multitude of regulatory authorities, many
of which have different objectives and jurisdictions, may not be able to
respond on the basis of ecosystem issues to future activities. Furthermore,
some agencies suffer from limited enforcement resources. Because these
waters contain so many valuable resources which in turn support so many
beneficial uses, the special planning and study possible in a marine
sanctuary is necessary to ensure that they are used and preserved in
the future as effectively as possible.

GENERIC COMMENT C

The regulation on vessel traffic is worded in a confusing manner and
could be interpreted as prohibiting recreational and research vessels
within 1 nmi of the Islands. Even if it is not NOAA's intent to impose
such a restriction, enforcement agents and future managers may not.be
aware of NOAA's intent. A prohibition on recreational boating would
have a significant negative impact on thousands of recreational boaters
in southern California. Unless the language is clarified so that
recreational boating is clearly allowed, the sanctuary should not be
designated.

GENERIC RESPONSE C

The proposed regulation on vessel traffic was worded in a somewhat
confusing manner. NOAA never intended to prohibit recreational vessel
traffic near the northern Channel Islands and Santa Barbara Island.
The prohibition on certain commercial vessel traffic within one nautical
mile of the Islands was aimed at tankers, freighters, barges, and OCS

G-5

supply vessels. The regulation on vessel traffic has been rewritten to
clarify this intent (see Section F.2.c.4 and Appendix 1).

GENERIC COMMENT D

The marine sanctuary should institute a moratorium on leasing for oil
and gas development throughout the area covered by alternative 4. An
oil spill anywhere in the Channel would be likely to affect the resources
near the Channel Islands and the other resources of value located
throughout the Channel. Most of the tracts with high resource potential
have already been leased, as is indicated by the fact that many tracts
offered for lease in the Channel in OCS Sale #48 received no bids.
Finally, the number of rigs and platforms already located in the Channel
or planned for existing leases already pose a dangerously high threat
to vessel traffic and other activities in the Channel.

GENERIC RESPONSE D

While it is true that a major oil spill anywhere in the Channel could
harm the natural resources of the area, including those around the
Islands, the risk of damage from such a spill must be weighed against
the costs of the exclusion of oil and gas operations. The economic
consequences of prohibiting future oil and gas development are substantial.
The Santa Barbara Channel is an area of proven offshore oil reserves; the
oil and gas industry ranks it as the third highest offshore area for oil
and gas exploration. While no economically recoverable reserves have
been discovered within 6 nmi of the Islands to date, oil production
in other portions of the Channel has been occurring since 1896. Although
not all the tracts offered for lease in OCS Sale #48 received bids,
54 tracts were leased, most of which were in the Channel. Depending on
the success of exploratory drilling on those and other tracts in the
Channel, the remaining tracts may be leased in future lease sales,
including Sale #68, scheduled for June 1982. The oil spill contingency
requirements, operating orders, and lease stipulation imposed by the
Department of the Interior and the consistency requirements imposed by
the California Coastal Commission provide some protection against oil
pollution. While these precautions cannot completely forestall the
possibility of an oil spill, the distance between most hydrocarbon activities
in the Channel and the nearshore Island waters, which the proposed sanctuary
buffer guarantees, will provide a minimum amount of time for cleanup
activities before the oil can reach shore, and will also allow time for
the spilled oil to weather and thus lose its most toxic parts before it
reaches the nearshore Island waters. (See also Generic Response A.)

GENERIC COMMENT E

There is no proof that oil and gas development has harmed the natural
resources of the Channel Islands, although offshore petroleum development
has been occurring in the Santa Barbara Channel for years. Even the

G-6

1969 oil spill from Platform A had no long term effects on the biota
of the Channel. Furthermore, natural oil seeps add far more oil to the
Channel than offshore oil and gas operations. In fact, platforms
provide an artificial reef environment on and around which many species
of fish and shellfish thrive. Therefore, NOAA should not prohibit
new oil and gas development.

GENERIC RESPONSE E

There remains considerable controversy surrounding the probable long
term effect of oil and gas production activities in these Island waters,
or any other OCS region. Current data is limited for a number of
reasons. While offshore operations have been conducted in the Southern
California area for many years, most of the activity has been outside
the boundaries of the proposed sanctuary and in many cases at a significant
distance from the Islands. The question whether petroleum development
will eventually cause degradation of the unique natural resources of
the Channel Islands is difficult to address because it must therefore
be based on data from rather dissimilar areas. Certain comparisons
and extrapolations are possible. In the case of the 1969 Santa Barbara
spill, which had primarily nearshore mainland impacts, the long term
effects, or their absence, cannot be definitively ascertained because
of the lack of detailed pre-spill environmental information. However,
the most apparent effect of this blowout was the extensive bird mortality
it caused and this impact would only be even more devastating on the
seabird nesting and feeding areas found within the proposed sanctuary.
For instance, the entire breeding population of Xantus' murrelet would be
vulnerable to a major spill affecting the waters near Santa Barbara
Island. Various effects on the endemic species, invertebrates, tidal
organisms, and marine mammals that have been identified as a result of
.biological surveys conducted after 1969 could also be particularly
heavy in the Island nearshore zones. (See Section F.2.c.l. for greater
detail.)

Oil and gas development has other inherent impacts besides the release
of toxic materials into the environment. Disturbances caused by machinery,
noise, and increased supply boat and helicopter traffic can force pinnipeds
and seabirds to abandon rookeries, nesting areas and haulout grounds.
Man's activities have already accomplished this on the southern California
mainland. The six nautical mile proposed sanctuary boundary and regulations
provide a necessary buffer to mitigate this impact. In addition, the
proposed boundary allows for additional response time in case of a spill.

The amount of oil introduced by natural seeps into the vicinity of the
proposed sanctuary has not been documented. The entire Santa Barbara
Channel region is characterized by a large number of natural oil seepage
zones that are estimated to introduce a total of from 40 to as much as
670 barrels of oil per day into the marine environment. The majority
of the seeps are found in the northernmost part of the Santa Barbara
Channel nearer the mainland. While the total amount of oil entering
the marine waters is considerable, the number of seeps is also large
and their distribution widespread. It is therefore difficult to liken
the effects of oil seeps to those of a spill. A spill may involve much

G-7

larger amounts of oil, perhaps with much greater concentration on or near
the water's surface, in closer proximity to the valuable Island resources.
In addition, the full impact of these chronic low level concentrations
has not been evaluated and further threats posed by the additional
oil influx resulting from a spill are unknown.

The benefits derived from the artificial reef environmental created
by the presence of a drilling or production platform are relatively
short-lived. The fishery@habitat exists only over the life of the field
and disappears once the platform is removed. This limited enhancement
of the fin and shellfish habitat must be balanced against threats posed
by oil and gas production.

GENERIC COMMENT F

The HIS should present and discuss a management plan before the designation
occurs. The discussion should take enforcement mechanisms and costs into
account.

GENERIC RESPONSE F

The discussion of'the management plan for the proposed Channel IslaAds
marine sanctuary has been revised and expanded to include a more exact
formulation of management objectives and some additional information
on enforcement mechanisms and costs (see Section F-2-b-) The Department
of Fish and Game is working under a cooperative agreement with NOAA to
prepare recommendations for a specific sanctuary management plan which
will address in further detail the issues of coordination, public
participation, research, monitoring, assessment, public education
and enforcement. Preliminary forms of these recommendations will be
available at the time of final statutorily required consultation with
the Federal agencies and the State and will be subjected to a public
participation process involving consultation, review and comment before
adoption.

Furthermore, the details of a management program will only evolve with
actual experience. Cooperative agreements with other agencies are ,
impractical before designation and the promulgations of final regulations.
Elements of the management plan itself will depend on the final form of
these documents. The details of some management issues will probably
first be identified after the administration of the sanctuary begins.
It is not at all unusual for a management plan to be developed after
the formal protection of an area. For example, in the bill creating the
Channel Islands National Park, Congress asked the Department of the
Interior to develop a management-plan within three years after statutory
creation of the Park.

G-8

GENERIC COMMENT G

The marine sanctuary should require vessels transitting the Santa Barbara
Channel to adhere to the Vessel Traffic Separation Scheme (VTSS) established
by the U.S. Coast Guard.

GENERIC RESPONSE G

Most commercial vessel traffic already adheres to the Coast Guard's
designated VTSS in the Channel. In addition, the Coast Guard is
conducting a Port Access Route (PAR) study for the California coast and
the Santa Barbara Channel is under careful consideration as part of that
study. Under the 1978 amendments to the Ports and Waterways Safety Act,
the Coast Guard has the authority to make shipping lanes mandatory and
will exercise that power for the entire Santa Barbara Channel if the PAR
study indicates that that is the best course of action. NOAA has
commented on the Coast Guard's PAR study, and the Coast Guard will take
the Channel Islands marine sanctuary proposal into consideration in its
decision, as well as the other complicated issues of use, location, and
safety of navigation. Since the study is incomplete, it is premature
and inadvisable for NOAA to take any action concerning the VTSS.

GENERIC COMMENT H

The marine sanctuary should prohibit the placement of structures,
including platforms for oil and gas production, in or near the Vessel
Traffic Separation Scheme.

GENERIC RESPONSE H

The California Coastal Commission presently considers the placement of
structures in or within 500 m of a VTSS to be inconsistent with the
California Coastal Zone Management Program. In addition, the Coast
Guard has in the past recommended that permits for the location of
structures or anchoring of drillships granted by the Army Corps of
Engineers be subject to a special condition that prohibits the activity
inside the sea lanes or within a quarter mile of the sea lane boundaries.
Furthermore, under the 1978 amendments to the Ports and Waterways Safety
Act, the Coast Guard can prohibit the placement of structures in a Port
Access Route (PAR) and can otherwise restrict such placement. As part
of its current southern California.PAR study, the Coast Guard is considering
various ways of managing vessel traffic in the Channel and coordinating
it with potentially conflicting uses, such as energy exploration and development.

Given the current review of location of structures in the VTSS through
the Federal consistency requirements imposed by the California Coastal
Commission, the Coast Guard review of permits, and the prospect of permanent
Federal control through the designation of a PAR or modified fairway in
the Channel, NOAA has determined not to propose sanctuary regulations at
this time.

G-9

GENERIC COMMENT I

The recreational boating community in Los Angeles and Long Beach, California,
was not informed of this proposal and therefore did not have an opportunity
to comment adequately. Additional hearings should be held in Los Angeles
and Long Beach so that the affected parties can comment on the proposal.

GENERIC RESPONSE I

NOAA regrets that segments of the boating community in the Los Angeles
area were not aware of the proposal earlier. However, this proposal
has been under discussion since spring 1978, and both NOAA and the
California Coastal Commission have held several public meetings and
public hearings in Southern California on a possible Channel Islands
marine sanctuary, which were publicized through NOAA's and the Coastal
Commission's mailing list, the Federal Register, and announcements and
stories in Santa Barbara and Ventura newspapers. The comment period
on the DEIS was 60 days (15 days longer than required by the National
Environmental Policy Act) and was extended to March 7 to accommodate
late comments. Direct telephone contact was initiated with the recreational
boating groups to assure they were aware of the time for comments.
Numerous written comments were received from recreational boating
groups and oral testimony was submitted at the hearings in Ventura and
Santa Barbara. NOAA's responses to the particular comments are set out
in the FEIS.

GENERIC COMMENT J

The FEIS should discuss and propose protection for the benthic, intertidal,
and other invertebrate resources as well as the marine mammals and birds.

GENERIC RESPONSE J

Invertebrate resources, particularly those unique to the Santa Barbara
Channel transition zone, are important elements of the ecosystem and thus
worthy of marine sanctuary protection. The regulations proposed in the
FEIS for the marine sanctuary are also intended to preserve sensitive
invertebrate resources. The discussion in the EIS centers on marine
mammal and bird populations as top predators in the food chain and
therefore easily visible indicators of the balance and health of the
other elements of the ecosystem whose state is less easy to measure.

Sections E.2-c and E.2.d provide some discussion of invertebrate and
plant life in the Channel, and Section F-2-c- has been expanded to
include some additional discussion on the impacts of sanctuary designation
on invertebrate fauna and flora.

G-10

GENERIC COMMENT K

The prohibition of oil and gas development pursuant to future leases
in the sanctuary will have a major economic impact. This economic
impact must be more fully addressed.

GENERIC RESPONSE K

NOAA has provided a more extensive economic analysis in Appendix 6
of the HIS to supplement the discussion of the socioeconomic consequences
provided in Section F-2.

G-11

U.S. AIR FORCE, Colonel Robert L. Klingensmith - 2/8/80

COMMENT: The Air Force has no objections to the proposed sanctuary and
agrees with Alternative 2.

RESPONSE: No response necessary

U.S. NAVY, Captain Richard Scruggs - 3/4/80

COMMENT: The Navy objected to the last line in Article 5, Section 2
of the draft designation, stating that it appeared to be an invita-
tion to sue for those objecting to their operations in the area. NOAA
and the Navy agreed that the substance of the section was not altered by
the sentence, that operations not essential to the national defense
would remain subject to regulation.

RESPONSE: In view of the Navy's concern, NOAA agreed to delete the
sentence.

L.A. DISTRICT - CORPS OF ENGINEERS, Norman Arno, Chief, Engineering
Division - 1/3/80

COMMENT: Reference to Corps of Engineers jurisdiction under Section 10
TU -of the River and Harbor Act of 1899, (33 USC 403), over any structures
or work in or over navigable waters of the United States (including the
territorial seas) has been omitted from the DEIS. The permit program of
the Corps of Engineers would cover oil "exploration and development,"
"platform placement, " and "pipelines." Figure F-1 on page F-4 should
be amended accordingly.

RESPONSE: Figure F-1 has been modified to include the River and Harbor
A-cf-a-n-T-the Corps responsibilities in this area. It was combined with
the Clean Water Act (CWA).' Thank you for that correction.

COMMENT: Section 404 of the Clean Water Act which is noted in the
FE-ISon page F-36 would also cover oil "pipelines" if they include
trenching and backfilling: Figure F-1 should be amended accordingly in
conjunction with our previous comment.

RESPONSE: See previous response.

COMMENT: "Page F-36" Discussion of the Corps of Engineer permit program
sF_o_uT_dbe amended to note that "filling" actions require a permit in addition
to dredging actions.

RESPONSE: Comment accepted.

G-12

COMMENT: Page F-42: The discussion of the Corps of Engineers
permit system for the Outer Continental Shelf (OCS) should, in
accordance with Title 33, Code of Federal Regulations, Navigation
and Navigable Waters, Chapter II, Regulatory Programs of the Corps
Engineers, Parts 320-325, be amended to note that the Corps of
Engineers "issues permits based on an evaluation of the impact of the
proposed work on navigation and national security" in cases involving
construction of fixed structures or artificial islands on Outer Con-
tinental Shelf lands.

RESPONSE: Comment accepted.

DEPARTMENT OF ENERGY, R. Dobie Langenkamp, DAS, Resource Development
Operations - 2/15/8U

COMMENT: DOE feels the proposed sanctuary designation runs counter to
Te-ction 102(2) of the OCS Lands Act Amendments of 1978, which calls for
expedited exploration and development of OCS energy sources. If indica-
tions appear of likely substantial reserves within sanctuary boundaries,
exploration should be allowed under revised sanctuary regulations.

RESPONSE: The OCS Lands Act (OCSLA) as amended in 1978 is intended to
Tx-pedite OCS oil and gas development while protecting the marine en-
vironment. Title III of the Marine Protection, Research, and Sanc-
tuaries Act, on the other hand, directs the preservation and restor-
ration of particular marine areas for their conservation, recreational,
ecological, or esthetic values. Thus, there will be differences, in
emphasis, objectives, and priorities between proposals under Title III
and implementation of the OCSLA. These differences, judicially recognized,
may well affect administrative decisions.

The proposed marine sanctuary protects one of the most signi-
ficant habitat areas off the California coast. If the technology for
the offshore exploration and production of hydrocarbon improves to
eliminate risk of pollution and disturbance, NOAA has the option to
propose modifications to the regulations dealing with oil and gas
activities in the sanctuary.

COMMENT: Increased oil production in the Channel Islands area would
tencT -to make pipeline systems more feasible relative to tankers. Pipe-
line systems are generally acknowledged as having lower potential en-
vironmental impacts than tanker operations. Thus, new leases needed to
achieve maximum economic recovery of oil and gas resources, even within
the sanctuary boundary, may not increase environmental risks.

RESPONSE: Depending on the amount of oil to be transported and the
geological structure of the area, pipeline transport of petroleum may

G-13

be environmentally safer than tanker transport or barging. The pro-
posed regulations specifically permit the laying of pipelines in the
sanctuary. However, the Department of the Interior calculates a direct
correlation between the amount of oil produced and the amount spilled.
Furthermore, the closer to the Islands a spill occurs, the less time
and space the oil has to weather and disperse. Thus new leasing within
the proposed sanctuary boundary in all likelihood will increase the risk
of environmental damage to the resources of the nearshore island waters.
In addition, pipelines cannot eliminate the disturbance to marine mammals
and seabirds caused by oil and gas operations. See Section F.2.c.1 for
a more detailed discussion of the relationship between offshore oil and
gas development and the living marine resources of the proposed sanctuary.

COMMENT: The DEIS does not acknowledge the extensive history of oil and
gas operations in the area (900 wells drilled, 14 platforms, 436 million
barrels produced with minimal environmental impact).

RESPONSE: In Sections E.3.b and F.2.b.l. the DEIS described in detail
the history of oil and gas development in the proposed sanctuary. As
noted in those sections, extensive oil and gas development has occurred
in the Santa Barbara Channel near the mainland, as mentioned in this
comment. The 1969 oil spill, numerous small spills and leaks, the
increased numbers of rigs and associated level of supply activity have
had an impact on the environment. The DEIS does acknowledge that the
safety record of the industry as to large spills is quite good.

COMMENT: The DEIS requirement for oil spill contingency equipment is
redundant, since the California Coastal Commission already requires
onsite spill containment equipment. Oil spill containment requirements
on oil and gas lease tracts are also imposed by BLM, USGS, and EPA.

RESPONSE: NOAA's proposed oil spill contingency equipment requirements
exceed those imposed by BLM, USGS, and EPA. The California Coastal
Commission requires onsite oil spill containment equipment on a case
by case basis. The proposed regulation reflects the decision that
all tracts within 6 nmi of the Islands warrant additional onsite
equipment.

U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT, Trudy P. McFall
Acting Director, Office of Planning and Program Coordination - 1/8/80

COMMENT: There is no conflict with HUD programs, policies or interests.

RESPONSE: No response necessary.

COMMENT: They have no comments to offer on the DEIS and do not wish to
receive copies of the FEIS.

RESPONSE: No response necessary.

G-14

U.S. DEPARTMENT OF THE INTERIOR: R. L. Herbst, Assistant Secretary for
Fish and Wildlife and Parks, 2-/22/80

COMMENT: The analyses displayed in the DEIS are very superficial and
highly conclusory, without much factual support for the conclusions.
They are unquantified and lack significance about the impacts under
discussion.

We feel the DEIS should clearly state the value of the marine mammal and
bird resources, analyze all of the real and potential activities that
not only conflict with, but also support, the preservation of these
resources, and then compare the various alternatives for management that
offer the preservation ideal.

RESPONSE: NOAA has provided more factual support and quantification
Tn -the FEIS. However, neither the value of the natural resources of
the proposed sanctuary nor the threats to those resources lend them-
selves to particularly accurate quantification.

COMMENT: The impact topics, themselves, should be structured around
et-f-ects and not causes. It is useless "do it yourself" information
to advise a reader that vessel and overflights will do one thing, present
authorities will do another, petroleum development.will cause a third
thing to happen, and management another. The important knowledge re-
quired by a decision-maker selecting alternatives is what happens to
the whales, the pinnipeds, the birds, the recreationists, etc., due
to the proposal (and each alternative). In other words, the structure
of these analyses should be based upon the analytical assembly oif total
cumulative consequences in one presentation for each single topic affected.

We do not object to the purpose and need for the sanctuary. It generally
seems a desirable idea intuitively, but the DES does not establish that
purpose and need very convincingly for the sanctuary configuration
presented.

RESPONSE: NOAA feels that its proposal is more easily understood if it is
presented as a whole and then compared to various alternative courses of
action than if each component of the proposal is analyzed seperately
in comparison to all the alternatives.

However, Section F.1-c (Environmental consequences of the status quo)
has been rewritten to more closely parallel the discussion of resources
and activities in Section E and the various alternatives presented in
Section F. This should assist the reader in followng the analysis.

G-15

COMMENT: An area to be managed usually requires a positive prime objective
to guide management. The DES states only constraints as the prime objective
of this sanctuary (p. D-5). We question that the prime purpose of the sanc-
tuary would be for either recreation or research.

RESPONSE: Research and education, along with resource preservation, are
primary objectives of the proposed sanctuary. NOAA has rewritten its
statement of purpose in a positive vein, as suggested.

COMMENT: When citing the Bureau of Land Management (BLM) (1979) more care
should be given to the definition of Channel Islands. The term when used
in the BLM paper refers to all eight islands within the Southern California
Bight. NOAA uses it to refer to the four northern Channel Islands.

RESPONSE: NOAA has attempted to refer to the northern Channel Islands and
Santa Barbara Island either in full, or merely as "the Islands," which is
defined in the regulations and the text. In general, NOAA has avoided us-
ing the name "Channel Islands," except in the name of the sanctuary in
order to avoid confusion. In general, unless specified otherwise, Channel
Islands refer to all eight islands as in BLM"s text and this use should
help eliminate confusion.

COMMENT: Page C-6 of the DEIS states: "Article 5 of the draft Designa-
tion s-pecifically exempts fishing activities from sanctuary regulations."
Fish, as well as other harvestable marine resources, are among the most
important resources in the proposed sanctuary, from both a biological
and commercial sense.

In the case of harvestable marine resources, we feel that NOAA should
reserve the option of future management in cooperation with the California
Department of Fish and Game. The issue of whether to regulate commercial
and sport fishing and kelp harvesting in the proposed sanctuary is dismissed
rather abruptly, the decision not to regulate these activities apparently
being based on little more than recommendation from the California Department
of Fish and Game.

RESPONSE: The decision not to reserve marine sanctuary regulatory
authority was endorsed by the California Coastal Commission, the
California Department of Recreation, the County of Santa Barbara,
commercial and sport fishermen's associations, and a variety of en-
vironmental groups, as well as the California Department of Fish and
Game. The decision was based on the comprehensive management authority
of DFG and PFMC in the regulation of fishing, the fact that the long term
interests of these agencies parallel those of the sanctuary, and the
existing close cooperation with DFG on management issues.

COMMENT: It seems particularly inconsistent to allow commercial
petroleum, transport vessels, a principal source of marine oil spills,
to navigate as close as I nmi from the Channel Islands when oil and
gas pipelines may not be placed closer than 2 nmi from any island,

G-16

and other related activities (i e., exploration and production on leases
executed after the effective date of sanctuary regulations) would not be
permitted at all.

RESPONSE: NOAA's proposed regulations permit the laying of pipelines
within 2 nmi of the Islands. While it might be environmentally preferable
to keep petroleum transport vessels outside the marine sanctuary, this
would make use of the VTSS established by the Coast Guard impossible. The
safety added by the use of a VTSS outweighs the disadvantage of having such
vessels in the sanctuary. Moreover,-east of Anacapa Island, the Channel
is too narrow to permit safe tanker transit in both directions more than,
6 nmi from the island. See also generic response G.

COMMENT: On p. D-2, the DEIS implies that "Special Status" is required
to assure protection of sensitive areas of future lease sales. The DEIS
does not demonstrate the inadequacy of the present DOI regulatory system.
The withdrawal of 24 tracts from Lease Sale 48 demonstrates the Secretary
of the Interior's responsibility and authority to protect biologically
sensitive areas of the OCS from unreasonable risks.

RESPONSE: The fact that tracts within 6 nmi of the Islands were leased
in 1968 and in OCS Sale #35 despite comments from the National Park
Service and the U.S. Fish and Wildlife Service recommending that that
area not be leased, coupled with the fact that the Department of the Interior
is reviewing tracts within 6 nmi of the Islands for OCS Sale #68 demonstrates
that the current system does not offer long term protected status to the
proposed sanctuary despite the Secretary of Interior's previous withdrawal
of the 24 tracts.

COMMENT: The DEIS assumes, on p. D-3, that geographical isolation is the
principal means for protecting the Islands from the adverse impacts of
hydrocarbon development. The document should discuss oil spill response
provided by Clean Seas, Inc. and Southern California Pollution Contingency
Organization Teams.

The DEIS should place greater emphasis on the safety and pollution
prevention assurances that modern blowout preventors, casing programs,
train ing programs, and the numerous strict operating regulations and
OCS Orders provide.

RESPONSE: NOAA acknowledges in the FEIS the protection afforded by modern
drilling technology, cleanup and containment equipment, and the controls
imposed by existing authorities, particularly BLM and USGS, (See Section
F.1-B. and the expanded discussion of Clean Seas, Inc and SCPCO in
Section F-2.c.1). However, NOAA finds that the resources of this area
still warrant special management, planning and protection. See Section
F-2-c.1 for a discussion of the impact of NOAA's proposed regulations on
hydrocarbon development.

G-17

COMMENT: On p. C-10 paragraph 2 of the DEIS, the statement, "USGS later
U@rastically reduced its estimate for the sale area - - - " is incorrect.
The previously mentioned 5.7 million barrels of oil and 8.9 billion
cubic feet of gas are the revised estimates.

RESPONSE: Comment accepted.

COMMENT: Section F. Alternatives. Maps specific to each alternative
should be provided. Tabular presentation of the specific control actions
intended as compared to the proposal would greatly facilitate explicit
understanding of the precise diffferences between alternative plans.

RESPONSE: The boundary descriptions are clear. Table F-I shows the
regulations proposed for each designation alternative.

COMMENT: P.-F-28 - Federal Authorities. This section of the DEIS should
include a discussion of the provisions of the National Environmental Policy
Act.

RESPONSE: The National Environmental Policy Act cannot protect resources
di-r--e-c-tT-Y; rather, it creates a procedure which enables other authorities
to determine the environmentally preferable course of action.

'COMMENT: What requirements will be placed on tracts that fall both in and
out of the sanctuary? Would the regulations cover that portion of tract
outside the sanctuary?

RESPONSE: The discussion and regulations clearly state that the provisions
of tFe-marine sanctuary only apply within its boundaries.

OTHER COMMENTS: Other specific editorial and technical comments by the
Ue-partment of @he Interior have been addressed in the FEIS.

U.S. DEPARTMENT OF THE INTERIOR - NATIONAL PARK SERVICE - CHANNEL ISLANDS
NATIONAL MONUMENT, William E. Ehorn - 1/10/80

COMMENT: Legislation is pending to establish the Channel Islands National
Ta-r-@ -to 1 nautical mile from the Islands. This boundary does not affect
California's jurisdiction but allows NPS to deputize California Fish and
Game rangers to enforce regulations.

RESPONSE: NOAA will coordinate management and enforcement with the
Channel Islands National Park.

G-18

COMMENT: The NPS fully supports the sanctuary with a six mile boundary
around the Islands.

RESPONSE: No response necessary.

DEPARTMENT OF STATE, OFFICE OF OCEANS AND POLAR AFFAIRS, R-Tucker Scully,
Acting Director - 2//3/79

COMMENT: In Section 2 of Article 4 the reference to "listed in Section 4
of this Article should instead read "listed in Section 1 of this Article".

RESPONSE: Comment accepted. Section 2 of Article 4 has been changed as
suggested.

COMMENT: Foreign governments must not view the marine sanctuary program as
a departure from the customary. U.S. view on law of the sea issues. There is
no question that under U.S. domestic law there would be no authority under
this proposal for any assertion of jurisdiction contrary to international
law. The proposed regulations do not include a reference to international
law. The following sentence should be added at the end of Section 935.5:

"All prohibitions must be applied consistently with
recognized principles of international law..."

.RESPONSE: Comment accepted. The concept is already contained in Article 4,
Section 2 of the Designation, which controls the scope of the regulations.
However, NOAA has added the suggested sentence to the regulations as
well to ensure that there is no misunderstanding on this point.

DEPARTMENT OF TRANSPORTATION, FAA: Leonard A. Ceruzzi - 10/15/79

COMMENT: The FAA favors protection for the sanctuary area. However,
iWe -firmly insist that regulations of the navigable airspace is expressly
granted to the FAA by Section 307 of the Federal Aviation Act of 1958,
as amended. NOAA does not have the authority to control the altitude
of aircraft flying over marine sanctuaries. The statutory authority
of the FAA Act of 1958 supercedes agency regulations.

RESPONSE: NOAA acknowledges the mandate of the FAA to control aircraft
altitude to ensure safety and for other purposes. NOAA is not trying
to control altitude but rather prevent disturbance in sensitive habitat
areas within the sanctuary consistently with the NMFS position on harassment.

G-19

DEPARTMENT OF TRANSPORTATION, Federal Highway Administration - Region Nine:
Neil Dillabough, Director - Office of Environment and Design - 1/18/80

COMMENT.: The proposed sanctuary will not affect the Federal-aid,highway
program.

RESPONSE: No response necessary.

DEPARTMENT OF TRANSPORTATION, llth Coast Guard District: H. W. Parker,
Commander, Elevenfh -Coast Guard District - 111IT8-0

COMMENT: The proposed sanctuary regulations present a potential for
conflict with the Coast Guard's existing Traffic Separation Scheme and
changes in that scheme designated by the Port Access Route Study, the
TSS, or under Rule 10 of the International Rules for Preventing Collisions
at Sea, and the Port and Tanker Safety Act of 1978 takes precedence over
any agency regulations. We suggest that the proposed sanctuary boundaries
be redrawn so that they do not overlap the TSS or the 500 meter buffer
zone to either side of it. This would avoid duplication or conflict
between NOAA and Coast Guard regulations. The proposal should recognize
that the TSS may be modified upon conclusion of the PAR study.

RESPONSE: NOAA has rewritten the documents concerning the proposed
sanctuary to eliminate any conflict with any VTSS or PAR designated by
the Coast Guard, as long as the VTSS or PAR lies beyond one nmi from
the Islands. Although the boundaries of the sanctuary have not been
redrawn, the designation document now specifically exempts navigation
within a designated VTSS or PAR from any sanctuary regulation (see
Article 4, Section 1, Appendix 1). Other regulations of vessel operations,
such as those controlling discharges, will continue to apply.

COMMENT: The Coast Guard is of the opinion that Marine Sanctuary regulations
would apply only to citizens of the United States. Most of the vessels
passing through the Santa Barbara Channel are under foreign flags, and
the Sanctuary regulations would not apply to them outside of the territorial
sea.

RESPONSE: Under the Marine Protection, Research, and Sanctuaries Act,
the regulations apply to foreign citizens only in accordance with recognized
principles of international law. NOAA will 'not apply regulations in a
manner not authorized by statute.

COMMENT: The mechanics and cost of enforcing Sanctuary regulations must
be determined before and during the rulemaking process, not after, as
the DEIS implies. The Coast Guard presently has neither the funds or
staff to make more than a token effort to enforce new marine sanctuary
regulations.

RESPONSE: NOAA will provide funds for onsite management and enforcement

G-20

of a marine sanctuary, as described in Section F-2-b and generic response F.
The California Department of Fish and Game is gathering more information
concerning methods and costs of enforcing sanctuary regulations as
part of its management study. NOAA is aware that the Coast Guard is
under severe personnel and resource restraints.

COMMENT: Vessel control within one mile of the Islands seems unnecessary,
since commercial vessels do not normally pass within one mile of the
Islands. Unless existing regulations are inadequate, additional regula-
tion of vessel traffic seems pointless.

RESPONSE: No existing regulation prohibits tankers , freighters, or
other large commercial vessels from entering nearshore waters. While
it does appear that most vessels of this description remain outside
this area, there have been reported incidents to the contrary. NOAA's
proposed regulation will ensure that commercial vessel traffic will
not disturb sensitive marine mammal and bird populations in resting
and breeding areas and will reduce the potential for potentially damaging
polluting incidents in this sensitive area. As use of the Channel
increases and oil and gas exploration and production activities move
further offshore, commercial vessel traffic near the Islands may increase
in the absence of marine sanctuary regulation.

U.S. ENVIRONMENTAL PROTECTION AGENCY: Carl C. Kohnert, Jr., Director,
F_- 1/3/80
Surveillance and Analysis Division

COMMENT: The EPA's comments on the DEIS have been categorized as LO-1.
Lack of objections - adequate.

RESPONSE: No response necessary.

U.S. ENVIRONMENTAL PROTECTION AGENCY: William N. Hedeman, Jr., Director,
Office of Environmental Review-7-17-23/80

COMMENT: EPA endorses the proposal. The protective measures envisioned
for the sanctuary appear sufficiently comprehensive to protect the
valuable resources of the area.

RESPONSE: No response necessary.

COMMENT: On page C-8, the description of the prohibition of dredging,
drilling, constructing on or altering the seabed should stipulate the
exclusion of hydrocarbon extraction activities from the prohibition,
as has been done elsewhere in the statement.

G-21

RESPONSE: The discussion of the prohibition on dredging, drilling,
const ion on, or alteration of the seabed in the summary (Section C)
has been changed to show that the laying of pipelines is excluded from
the prohibition. Since there are currently no leased tracts in the area
affected by this regulation, and since the marine sanctuary regulations
prohibit oil and gas development pursuant to future leases in this area,
no other hydrocarbon activities would occur. References to this regulation
elsewhere in the HIS have been amended accordingly.

COMMENT: On page F-34, the description of the Clean Water Act should
be clarified in the following way. EPA's NPDES permitting is based
upon technology-based effluent guidelines as well as site-specific
water quality concerns. Water quality issues are addressed by means
of Section 403(c) of the Clean Water Act which requires that all permits
for discharges into ocean waters be in accord with ocean discharge
criteria (now being developed by the Agency). These criteria allow
case-by-case consideration of special sensitive ecological areas that
may require more than conventional protection measures, as in the case
of Tanner Banks where concern for unique coral populations caused the
addition of special protective conditions to discharge permits. In this
connection, EPA requests removal of the statement that for Tanner Banks,
special permit conditions were added to the NPDES permit in order to
conform to BLM stipulations.

RESPONSE: Comment accepted.

COMMENT: On page F-35, the table showing the effluent guidelines for
the far offshore oil and gas extraction category should be corrected
to indicate that the standard for oil and grease in deck drainage is
"no discharge of free oil" listed instead of "72 mg/1" and "48 mg/l."

RESPONSE: Comment accepted.

COMMENT: On page F-43 it should be mentioned that there is a pending
designation of EPA's San Nicholas Basin (32*55'N - 119'17'W) ocean dumping
site for the disposal of drill cuttings and drilling muds.

RESPONSE: Comment accepted.

COMMENT: On page F-60, this section and others in the EIS that describe
the requirement for onsite oil spill containment equipment, should further
describe the performance requirements of operators to respond to a spill
rather than specifying parti.cular kinds of equipment. As presently
stipulated, inappropriate equipment and procedures could be used to fulfill
this requirement.

RESPONSE: The performance of oil spill containment operations depends
heavily on weather and sea states as well as the equipment and procedures
used. Thus, performance requirements beyond those already imposed on
a case-by-case basis by the California Coastal Commission are impractical

G-22

for NOAA to establish. The equipment required conforms with California
Coastal Commission requirements imposed for similar leases.

COMMENT: A map should be included in the text depicting the zone affected
by each of the five regulated activities in the sanctuary.

RESPONSE: Section E.3 contains figures showing the areas affected by
the various activities. Beyond that, the written description clearly
states the affected area for each regulation.

MARINE MAMMAL COMMISSION: John Twiss 2/6/80

COMMENT: The Commission supports prohibition of oil and gas development
in the proposed sanctuary, at least until information is available which
shows that such development will not adversely impact living marine
resources. OCZM should be ready to reassess oil and gas development
prohibition if such information appears.

RESPONSE: NOAA's proposal is consistent with this concept.,

COMMENT: Fishing activity is excluded from the proposed sanctuary
regulation. We believe that potential regulatory authority for fisheries
activity, especially nearshore fishing, should not be precluded as a sanctuary
management option.

RESPONSE: See Response to the fifth comment by the Department of the
Interior.

COMMENT: On pages D-1 and F-68, statements indicating that the Gaudelupe
fur seal has been proposed for listing as an endangered species should
be revised. The species has not yet been proposed for listing under
the Endangered Species Act.

RESPONSE: The National Marine Fisheries Service is considering the
@o-ssibility of proposing the Gaudelupe fur seal for listing as an
endangered species. NOAA has changed the two statements cited above
to reflect this status.

COMMENT: The Commission recommends that the proposed regulations be
changed to provide protection for all shoreline areas, including both
the smaller offshore islands and rocks, as well as the main islands.

To implement this protection and resolve uncertainties, the Commission
recommends the addition of a definition for the tern "Island" in
section 935.4 of the proposed regulations which would indicate that use
of this term in the regulations refers to all permanently exposed rocks
and islands within the proposed sanctuary boundaries. Clarification
of this point should also be made in the discussions in the DEIS of

G-23

seabed construction (pages F-102 and F-103) and of vessel and aircraft
operation (pages. F-103 to F-108) and on-Figure F-14 (page F-106).

RESPONSE: NOAA has-defined "Island." to include Richardson Rock and Castle
Rock as well as the four northern Channel I slands and Santa Barbara
Island (see Section C, Section F.2.a,.and Appendix. 1).

COMMENT: We recommend that the third paragraph of the Marine Mammal
Protection Act discussion (last paragraph on page F-31) be deleted and
the following two paragraphs be inserted:

The MMPS defines "take" quite broadly to include "harass", hunt,
capture, or kill any marine,mammal or to attempt to enga e in
such conduct (16 U.S.C. Sec 1362(13), emphasis added). The term
has been interpreted to encompass both intentional and negligent
acts, including the operation of motor,boats, which result in
the disturbi.ng or molesting of marine mammals (50 CFR 18.4; 50 CFR
216.3).

The MMPA provides for limited exceptions to the moratorium.
Pursuant to these-exemptions, marine mammals in the Channel Islands
area may be taken for scientific research, for public display,
and incidental to commercial fishing operations, under specifically-
authorized permits. Similarly, stranded or debilitated marine
mammals may be taken for the protection and welfare of the marine
mammal or for the protection of the public health and welfare.

RESPONSE: The suggested change has been made.

COMMENT: In the last paragraph on page F-32, we recommend that OCZM
simply list those species in the study area which are treated as "depleted"
under the MMPA. There would seem to be no reason to distinguish among
depleted species which have been "sighted in the study area" and those
which are "possible transients" since at least one of the latter group
(the sea otter) has also been sighted around the northern Channel Islands
(see page E-24 of the DEIS).

RESPONSE: Comment accepted.

COMMENT: Further, the Commission recommends that the fifth paragraph
of this discussion (the second to the last paragraph on page F-32) be
deleted and the following inserted:

The Act calls for effort to restore and maintain marine mammal
populations at "optimum sustainable population" levels (16 USC
Sec. 1361(b)). Optimum sustainable population (OSP) is defined to
mean "...the number of animals which will result in the maximum
productivity of the population of species keeping in mind the
carrying capacity of the habitat and health of the ecosystem of
which they form a constituent element" (16 USC 1362 (9)). OSP
has been further defined by regulation as "...a population level

G-24

of a given species or stock which is the largest supportable
within the ecosystem to the population level that results in maximum
net productivity. Maximum net productivity is the greatest net
annual increment in population numbers or biomass resulting from
additions to the population due to reproduction and/or growth less
losses due to natural mortality" (50 CFR 216-3).

RESPONSE: NOAA finds that-the original paragraph conveys the same
information in fewer words, and therefore has retained the original
wording.

COMMENT: The Commission recommends that the DEIS be expanded to indicate
the approximate level of personnel and funding commitment which it
expects to direct towards efforts to establish a Sanctuary Information
Center, promote public awareness, monitor sanctuary resources, partially
fund research projects within the sanctuary, inventory historical resources,
enforce regulations, and consult with other marine management authorities.

RESPONSE: See generic response,F.

G-25

U.S. REPRESENTATIVE ANTHONY C. BEILENSON (California) - undated

COMMENT: It is appropriate that vessels adhere to Coast Guard-designated
traffic lanes while in the sanctuary boundaries; that all hydrocarbon
exploration (with the exceptions which they have noted) on current leases
within six miles of the islands be undertaken using a slant drilling
technique from outside the six-mile limit; that oil spill contingency
equipment requirements be in accordance with the Commission's requirements;
and that a Channel-wide designation be pursued in recognition of the
need for integrated management in the area.

RESPONSE: See generic responses A and G and Section F.3.

COMMENT: A Channel-wide marine sanctuary coupled with the ban on leasing
for oil and gas development within six miles of the islands discussed
in the Draft Environmental Impact Statement preferred alternative and the
California Coastal Commission position is recommended. Such Channel-wide
designation need not conflict with the accelerated exploration and
exploitation of the channel's oil and gas resources. It might aid that
development by mitigating many of the conflicts that will otherwise
inevitably ensue.

RESPONSE: See generic response A.

STATE OF CALIFORNIA COASTAL COMMISSION: Michael L. Fischer,
Executive Director - 2/l/80

COMMENT: The Commission supports the proposed sanctuary. The Commission
recommends that the boundary be extended to include 12 nmi around the
Islands and rocks as well as the entire Channel and that the Designation
and regulations be rephrased accordingly. The entire area is a total
ecosystem and integrated management is essential.

RESPONSE: See generic response A.

COMMENT: Sanctuary regulation of oil and gas operations should encompass
only those areas within six nmi of the Islands and rocks.

RESPONSE: This is consistent with NOAA's preferred alternative.

COMMENT: The Commission recommends the following ground rules for activities
on the 15 existing leases which lie partially or wholly within the 6 nmi area.
No oil or gas exploration activities shall be permitted within six nmi of
the islands unless the tract operator has first explored the adjacent

G-26

leased area outside the six nmi. Exploration would be permitted within
six nmi only if the prior exploration has indicated the likelihood of an
oil or gas field extending within the six nmi. The sanctuary manager may,
however, permit exploratory drilling first within six nmi only when the
operator demonstrates with geophysical data that the most favorable
potential hydrocarbon bearing structure in the area can only be explored
from within six nmi. The purpose of explorations within such area would
be to determine the extent of the field and to determine how much of the
petroleum resources could feasibly be produced from a platform outside
the six nmi buffer area. No oil and gas development and production
activities shall be permitted within the six nmi area, including those
tracts which lie entirely within the area. Production of petroleum
resources within the six nmi area could take place only from production
facilities located outside the boundary which employ slant drilling.
The only possible exception to the above requirement would be subsea
completions linked to production facilities outside the six nmi area.
If any petroleum resource discovered during exploration cannot be
produced from outside the boundary under the guidelines proposed above,
NOAA and the Department of the Interior should develop a compensation
scheme for the lessee for the unproducible petroleum (e.g., credit and/or
preference for new leases).

RESPONSE: Marine sanctuary prohibition of any exploration, development
and p uction activities on existing leases within the proposed sanctuary
does not appear appropriate at this time. There are only 16 existing
leases fully or partly in the proposed sanctuary. In some situations,
depending on geologic and other factors which vary in each case, the
slant drilling which might be required to explore and extract resources
may pose a range of technical problems for operators, including increased
time and cost on site, and increased risk of adverse geological conditions.
These questions, as well as the extent to which the requirement may
diminish the extent of recoverable resources, appear to be appropriate
for case by case consideration, evaluating all.information available.

NOAA has rejected the possibility of sanctuary review and certification
of each application for activities on existing leases within the six nmi
boundary in large part because such review is now exercised by both the
United States Geological Survey and the California Coastal Commission.
The Commission in particular gives primary consideration to environmental
factors in its consistency review. (See the comparison with the preferred
alternative in Section F.3 for a more detailed discussion of this proposed
regulation.)

COMMENT: The Commission will use its consistency review to prevent
placement of structures in the vessel traffic lanes. The Commission
recommends that NOAA include this prohibition, as stated in alternative 4,
in.the sanctuary regulations for those portions of the Vessel Traffic
Separation Scheme within six nmi of the Islands.

RESPONSE: See Generic Response H.

G-27

COMMENT: Article 4, Section 1, should be revised to indicate that
activit es may be regulated only within 6 nmi of the Islands and rocks.

RESPONSE: Article 4, Section 1, states that listed activities may be
regulat;;d in the Sanctuary. NOAA's proposed sanctuary includes only
the waters within six nmi of the Islands.

COMMENT: The Coastal Commission objects to the discussion in the preamble
to the Regulations on the bottom of Page 69971 which would allow OCS
exploration and development including platforms under existing leases
within the six nmi area in spite of the extensive documentation in the
DEIS on the nature of the marine life around the Channel Islands and
the effect of oil and gas operations thereon. The discussion in the
preamble, should reference the Coastal Commission's consistency review
authority over OCS exploration, development and production plans pursuant
to the Coastal Zone Management Act.

RESPONSE: The preamble to Section 935.6 has been changed to reference the
Coastal Commission.

COMMENT:

(6) In the event NOAA does not incorporate the proposed revision to
the regulations on oil and gas activities.on existing leases into the
final marine sanctuary regulations, the Coastal Commission recommends
that �935.6(a) be revised to read as follows:

(a) Hydrocarbon exploration, development and production
pursuant to any lease executed prior to the effective date of
these regulations and the laying of any pipeline is allowed subject
to paragraph 935.6(b), and all prohibitions, restrictions, and
conditions imposed by applicable regulations, permits licenses,
or other authorizations and consisten@y revi.ews including those
issued by the Department of the Interior, the Coast Guard, the
Corps of Engineers, the Environmental Protection Agency, and the
California Coastal Commission ursuant to the Coastal Zone ffa-nagement
Act and its implementing r-e gu Taations.

RESPONSE: Section 935-6(a) has been revised in accordance with this
comment.

CALIFORNIA COASTAL COMMISSION, REGIONAL OFFICE: Steve Stanley - 1/11/80

COMMENT: The Commission supports the purposes of the proposed sanctuary,
and the thrust to prevent new offshore oil leasing within six miles of
the Islands and coordinate enforcement of wildlife regulations.

RESPONSE: No response necessary.

G-28

COMMENT: The DEIS is a thorough identification and analysis of marine
resources around the Islands and the proposed regulations provide major
additional protection for these resources at a time when activities threaten
their continued existence.

RESPONSE: No response necessary.

THE RESOURCES AGENCY OF CALIFORNIA: James W. Burns, Assistant Secretary
2/V8-0

COMMENT: The Department of Fish and Game (DFG) believes that Federal
involvement in the management of the Channel Islands is'likely in the
future. If this occurs, alternative 2 would be an acceptable plan.

RESPONSE: No response necessary.

COMMENT: DFG participation is essential for the development and enforcement
of a complete and effective management plan, and alternative 2 appears
to allow for such participation. DFG is pleased to note that the Draft
EIS also discusses the advisability of continued fisheries management
by DFG and the Pacific Fisheries Management Council, and cl iearly states
that sanctuary status will not subject either sport or commercial.fishing
or kelp harvesting to additional,regulations.

RESPONSE See generic response F and Section F.2.b for a discussion of
DFG's current and potential role in managing the proposed sanctuary.

COMMENT: The Department of Parks and Recreation (DPR) agreeswith the
intent of the proposed sanctuary.

RESPONSE: No response necessary.

COMMENT: DPR believes that regulation of navigation and operation of
all vessels other than those used for.fishing may unduly restrict such
activities as kelp harvesting, recreation, military, law enforcement,
research, education, and commercial (party) fishing or diving. The
Department, therefore, believes that Article 4 of the Draft EIS should
state more clearly that the above pursuits like sport and commercial
fishing will not be subject to additional regulations while the intent
to allow such activities i's expressed elsewhere in the report, it,should
also be clearly stated in Article 4, Section 1, Item D.

RESPONSE: Both Article 4, Section 1, Item D and Article 5 in the draft
Designation clearly exempt fishing and kelp harvesting from regulation.
The regulations have been'rewritten to state more clearly that recreational
and research boating, as well as the other types of vessel traffic
listed in this comment will be allowed throughout the sanctuary.

G-29

COMMENT: On page D-5 (Item 1), the sanctuary's purpose would be better
reflected if the wording "... not a) degrade intertidal habitats of
were changed to "... not a) degrade intertidal and subtidal habitats
and their associated communities or

RESPONSE: Comment accepted.

COMMENT: The island shelf is listed as 5 to 10 nautical miles wide
on page E-9 and 3 to 6 nautical miles wide on page E-34.

RESPONSE: The former reference has been changed to "3 to 611.

COMMENT: The statement regarding kelp on page E-46 applies only to the
southern California area; the range and maximum abundance figures are
not correct for northern California.

RESPONSE: Comment accepted.

COMMENT: The number and size of boats to be subject to enforcement
is not clear from the di.@cussions on pages F-47 and F-51.

RESPONSE: The National Park Service has one 55-foot patrol boat, one
40-fo patrol boat, and one 20-foot skiff for marine enforcement at
the Channel Islands National Park (see page F-48).

COMMENT: Although most of the fish and invertebrates discussed on page
E-46 Fparagraph 2) and in Appendix 2 are edible, the report should
indicate that these species and others also have recreational, non-
consumptive uses (photography, sightseeing, etc.).

RESPONSE: The discussion states that these species have both recreational
and commercial value.

COMMENT: The report correctly states that the State of California has
established an Oil and Gas Sanctuary around four of the five Channel
Islands. This constitutes a finding by the California Legislature that
the natural resource values of these islands are higher than the value
of the potential oil and gas that could be extracted from these locations,
so extraction of oil and gas is conditionally prohibited.

RESPONSE: No response necessary.

COMMENT: The FEIS should make it clear that the creation of the
proposed Channel Islands Marine Sanctuary does not constitute any
transfer of State title for any of the State-owned lands or resources
within the sanctuary.

G-30

The HIS should discuss the effects the proposed Marine Sanctuary would
have on the rights and jurisdiction of the State of California over the
State's tide and submerged lands, gas and oil resources, and waters with-
in the sanctuary. The alternative of land exchange or other compensation
should be discussed, especially with regard to Santa Barbara Island which
is proposed for inclusion in the marine sanctuary, but was not included
in the State legislation which created the other four Oil and Gas Sanctuaries.

RESPONSE: In response to the State of California's concerns, NOAA has
proposed an addition to the proposed regulations, Section 936.12, Amendments,
which addresses these issues. The proposed addition to the regulations
provides that any significant change in the extent to which various activities
are prohibited within the sanctuary automatically will be considered to
have a direct effect on the coastal zone and will require that the
National Oceanic and Atmospheric Administration (NOAA) provide the State
with a consistency determination under the California Coastal Zone
Management Act.

In addition, the revised regulation provides that, should California
determine that certain activities no longer need to be prohibited (for
example, that technology has progressed to the point where hydrocarbon
production no longer poses unacceptable risks even in nearshore areas)
and propose to relax the restrictions on activities within State waters
imposed by State law, NOAA will propose similar changes to the sanctuary
regulations unless it determines such changes would be clearly inconsistent
with the sanctuary. While there would be no guarantee that such a change
would be adopted as proposed after the rulemaking procedures were completed,
this provision would provide California with a considerable measure of
assurance that the sanctuary will continue to respond to its coastal
issues and needs. In addition, California can always impose stricter
requirements on activities in State waters than provided by the sanctuary.
NOAA does not consider a discussion of land exchange or compensation
necessary in light of this proposed regulation.

COMMENT: The Resources Agency greatly appreciates having been given
an opportunity to review this report, and looks forward to working with
the project sponsor in developing, implementing, and enforcing a plan
that would effectively protect these resources.

RESPONSE: NOAA intends to continue close cooperation with the Resources
Agency.

CALIFORNIA DEPARTMENT OF FISH AND GAME: Leonard Fisk - 1/10/80

COMMENT: The DEIS is well done and it presents a good case for the sanctuary.

RESPONSE: No response necessary.

G-31

COMMENT: Good coordination has taken place with California State agencies.

RESPONSE: No response necessary.

COMMENT: Fish and game resources are adequately regulated at this time
and need no additional regulations.

RESPONSE: This is consistent with NOAA's proposal which leaves regulation
of fishing and plant harvesting to DFG and the Pacific Fishery Management
Council.

COMMENT: The California Department of Fish and Game is willing to cooperate
in the enforcement of the sanctuary.

RESPONSE.: See Section F-2-b and generic response F.

CITY OF DEL MAR, CALIFORNIA: Robert A. Nelson, City Manager - 12/6/79

COMMENT: Acknowledged receipt of the DEIS and had no comments.

RESPONSE.: No response necessary.

THE CITY OF SANTA BARBARA, CALIFORNIA: Hal Conklin - 1/13/80

COMMENT: While concurring with the basic findings of the DEIS, the Environ-
mental esources Management Committee and the City Council of Santa Barbara,
unanimously endorse alternative 4. Alternative 4 offers the best protection.

RESPONSE: See generic response A.

COMMENT: There should be no new restrictions on commercial fishing activities.

RESPONSE: NOAA is in agreement with this comment; the marine sanctuary
will not regulate fishing, but will rely on the comprehensive systems
in place and on future coordination with DFG and the PFMC.

SANTA BARBARA COUNTY BOARD OF SUPERVISORS: Dev Vrat - 1/11/80

COMMENT: The findings of the DEIS on identification of marine resources
and nearshore regulations are appropriate.

RESPONSE: No response necessary.

G-32

COMMENT: The proposed boundaries are unjustifiably limited. Increased
areas of coverage would expand the level of environmental protection
while only slightly increasing the costs and inconvenience to sanctuary
users. The county supports alternative 4.

RESPONSE: See generic response A.

COMMENT: The County endorses the lack of new regulations over commercial
and sport fishing.

RESPONSE: No response necessary.

COMMENT: The monitoring and coordination provisions would provide opportunity
to develop a broad regional perspective of ocean users.

RESPONSE: No response necessary

COMMENT: The DOI Lease Sale #68 could trigger a sale of State leases to prevent
drainage of reserves, and increased risks to marine resources. Only alternative
4 would allow management and balancing of'conflicting Channel uses.

RESPONSE: See generic response A.

BOARD OF SUPERVISORS OF SANTA BARBARA COUNTY: Robert Hedlund, Chairman 1/7/80

COMMENT: The boundaries of Alternative 2 are unjustifiably limited to
the area adjacent to the islands, fai'ling to recognize the integrity
of the complete Santa Barbara Channel ecosystem. The County supports
the selection of alternative 4 as the preferred sanctuary.

RESPONSE: See generic response A.

COMMENT: The County concurs with the level of regulations within the sanctuary.

RESPONSE: No response necessary.

COMMENT: The DEIS acknowledges the existence of the unique benthic and
@e-lagic links in the Santa Barbara Channel ecosystem. On page F. 135
the entire Channel'is cited as "an interrelated ecosystem". The DEIS
notes that the entire Channel includes most of the waters and airspace
utilized by resident and transient marine mammals, seabirds, and fishes
for primary habitat, foraging, or migrations (F-130): "...the increased
areas of coverage would expand the level of environmental protection
while only slightly increasing the costs and inconvenience to sanctuary

G-33

users..." (F-131); "...monitoring and coordination provisions would
afford sanctuary managers an opportunity to develop a broad regional
perspective of ocean users ... with a broad overview of interactions
between significant uses, resources, and interests, the risks of hidden
cumulative impacts could be highlighted, brought to the attention of
appropriate authorities and addressed." (F-135).

After identifying the significance of the entire Channel as a unified
marine ecosystem the DEIS proceeds to excuse these findings with the
simple but erroneous conclusion that because marine resources are
physically concentrated around the Islands, the previously identified
significant and interrelated ecosystem elements, the pelagic and deepwater
benthic communities, situated beyond the islands, need not be protected.
The proposed boundaries of preferred alternative No. 2 do not reflect
the findings of the DEIS. The document is internally inconsistent.

The alternative No. 4 is preferred for several reasons: Its boundaries
correspond to the integral ecosystem the sanctuary is intended to protect;
it provides more complete long-term management capability and monitoring
of cumulative re.source impacts; and it would mandate use of the shipping
lanes, thereby reducing oil spill threats to Channel resources.

RESPONSE: See generic response A.

COMMENT: It is important to ensure use of TSS lanes by oceangoing
vessels.

RESPONSE: See generic response G.

HERMOSA BEACH PLANNING COMMISSION: Edward S. Loosli - 1/18/80

COMMENT: This area is historically significant and extremely valuable
biol ogical ly.

RESPONSE: No response necessary.

COMMENT: Oil.and gas operations, discharging or depositing any substance
alteration of or construction on the seabed, navigation and operation
of oil tankers within the sanctuary boundary should be prohibited.

RESPONSE: NOAA's proposal prohibits discharging or depositing most
substances in the marine sanctuary. Oil and gas operations pursuant
to future leases in the sanctuary are also prohibited. Operations
pursuant to existing leases are allowed if additional onsite oilspill
containment equipment is provided. Alteration of or construction on
the seabed is prohibited within two nmi of the Islands. The nearshore
area has a very high concentration of benthic resources. Beyond two nmi
from shore, particularly important bottom habitat can be protected by
the permits required from the California Coastal Commission and the

G-34

Corps of Engineers. NOAA proposes to prohibit operations by tankers
and other vessels engaged in the trade of carrying cargo or supplying
offshore installations within one nmi of the Islands and rocks. See
generic response G and the discussion of the preferred alternative
in the HIS for the basis of the proposed regulations.

COMMENT: San Nicholas Island should be included in the proposed sanctuary.
The waters around San Nicholas are vital to the survival of hundreds of
species of marine mammals and birds.

RESPONSE: San Nicolas Island is on the List of Recommended Areas for
marine sanctuary status and may be considered as an active candidate
in the future. NOAA welcomes any information concerning the suitability
of the waters around San Nicolas as a possible marine sanctuary.

COUNTY OF VENTURA-FISH AND GAME COMMISSION: Austin R. Cline - 1/17/80

COMMENT: The DEIS failed to address the status of the marine fishery
in the study area. The Commission feels that this fishery is continuing
to decline and that it must be properly managed.

RESPONSE: In Sections E.2.c and E-3-c, the HIS addresses fishing in
the study area. NOAA's information does not indicate that the fishery
in the proposed sanctuary is declining. Fishing is currently managed
by the California Department of Fish and Game and the Pacific Fishery
Management Council and NOAA will cooperate with those agencies in
their future activities affecting the fishery.

COMMENTS: The Commission failed to develop a position with regard to
the recommended or other alternatives presented in the DETS.

RESPONSE: No response necessary.

CALIFORNIA LEGISLATURE: Omer L. Rains, Senator - 1/15/80

COMMENT: The more extensive marine sanctuary should be designated.
The 3,000 square mile biogeographic unit from Point Arguello-Point
Conception to Point Mugu should be included in the sanctuary boundaries.

RESPONSE: See generic response A.

G-35

ASSEMBLY-CALIFORNIA LEGISLATURE: Gary K. Hart, Assemblyman,
35th District - 1/21/80

COMMENT: Sanctuary designation would present a unique opportunity for
comprehensive management of the Channel's resources while allowing
for multiple uses in a manner mindful of economic needs and environmental
consequences.

RESPONSE: No response necessary.

COMMENT: The DEIS is an exceptionally comprehensive document which
reflects local concerns and suggested alternatives.

RESPONSE: No response necessary.

G-36

THE AMERICAN CETACEAN SOCIETY: Martin Byhower - Undated

COMMENT: Mr. Byhower supports the proposed sanctuary and offers his
assistance in promoting the preservation of the beauty and wealth of
life in the Channel Islands.

RESPONSE: No response necessary.

AMERICAN PETROLEUM INSTITUTE: J.R. Jackson, Jr., Chairman, National CZM
Steering Committee - 1/18/80

COMMENT: The offshore petroleum industry and the environment are
compatible, if not complimentary.

RESPONSE: While in some circumstances, offshore petroleum operations
under DUI and other agency regulation can be conducted without readily
apparent environmental damage, there remains potential for not fully
understood long term adverse effects from chronic disturbance and chronic
routine discharges of oil and drilling muds and cuttings. In addition,
depending on the time of year and wind and weather conditions, a blowout
or other catastrophic discharge of oil could cause significant environmental
damage. See Section F-2.c-l for further discussion of the relationship
between petroleum development and the living resources of the proposed
marine sanctuary.

COMMENT: Protecting the environment must be done with full consideration
of energy, economics and government bureaucracy. The sanctuary documents
totally ignore these three factors. The cost of excluding future petroleum
operations in the proposed sanctuary comes very high with no commensurate
savings or return. The high costs come from the alternative of either
turning to imports or going without energy. There is little, if any,
return in increased natural resources values.

The sanctuary documents do not make a convincing case that a marine
sanctuary is necessary.

G-37

RESPONSE: Section F.2.c.1, Socioeconomic Consequences addresses the
issues identified in this comment. See also Generic Response K.

COMMENT: The sanctuary would allow petroleum operations on existing
leases, but would prohibit operations on future leases. This distinction
does not make sense.

RESPONSE: The proposed regulations on hydrocarbon exploration and
exploration strike a balance between imposing economic costs and achieving
environmental protection. The proposed regulations protect the sanctuary
resources from possible major expansion of oil and gas development,
but permit the development of those tracts in which the oil and gas
industry has already invested. Given the fact that there are only
16 such tracts, all but two of which fall only partly in the proposed
sanctuary, and given the careful consistency review by the California
Coastal Commission, the environmental risk seems acceptably low.

ASSOCIATION OF SANTA BARBARA CHANNEL YACHT CLUBS: Frank Klatt, telephone
conversation - 1/4/80

COMMENT: Will the proposed rules exclude recreational vessels near the Islands?

RESPONSE: See generic response C.

ATLANTIC RICHFIELD COMPANY: F.W. Chapman - 1/10/80

COMMENT: NOAA should consider and attempt to quantify the ecological
impacts, not only of the oil and gas industry, but all other activities,
both commercial and recreational, within the proposed sanctuary.

RESPONSE: The HIS does attempt to identify the impacts of all activities
within the proposed sanctuary. Thus the potential impacts of dredging,
dumping waste, overflights are discussed. Quantification was undertaken
whenever possible.

G-38

COMMENT: NOAA should attempt to quantify the added benefits to be derived
from establishing a Federal sanctuary over and above the smaller State
sanctuaries already present in the area.

RESPONSE: Sections F.l.c and F.2 discuss the expected benefits of a
marine sanctuary designation. Many of these benefits do not lend themselves
to accurate or useful quantification.

CALIFORNIA MARINE PARKS AND HARBORS ASSOCIATION: WILLIAM BERSSEN - 1/10/80

COMMENT: The Association needs additional time to review the DEIS and
additional hearings should be held in Los Angeles and Long Beach.

RESPONSE: See generic response 1.

CALIFORNIA MARINE PARKS AND HARBORS ASSOCIATION, Inc.: Susan H. Anderson,
Executive Vice President, Southern Division - Undated

COMMENT: The proposal to establish a Channel Islands Marine Sanctuary does
not provide sufficient assurances that the traditional use of the Islands
by recreational boaters and commercial recreational craft both as destination
sites and harbors of refuge will be allowed to continue. Generally, while
an attempt has been made to exclude recreational boating from the proposed
regulations, the wording is sufficiently ambiguous that a very different
interpretation could be made of the intent of the proposal.

RESPONSE: See generic response C.

COMMENT: Article 4, Section 1, item d, should exempt recreational as
iWe'llas fishing boats from marine sanctuary regulation.

RESPONSE: NOAA has rewritten the regulation on vessel traffic to clearly
show that recreational boating will be allowed in the marine sanctuary.
It is not desirable to preclude all possibility of controlling recreational
boating in the future by exempting it in the designation document.
Although recreational boating does not now threaten the resources of the
proposed sanctuary, it is conceivable that in the future some problems
may arise if use patterns should change greatly. Any changes in NOAAOs
initial regulations would be subject to the Administrative Procedures
Act and full public participation, including a 60 day comment period.
In addition, any proposed regulation must meet the statutory standards
of reasonableness and necessity.

COMMENT: Scattered negative comments about boating activities provide
fuel for those wishing to use the sanctuary to restrict use of the Islands.

G-39

For example, on page F-101, the text reads "Under current human activity
levels casual littering, most notably by recreational boaters..." This is
a widely assumed premise without supporting facts. Even developed harbors
are plagued by refuse-much of which in fact comes from land --- side users,
beach users and is wind blown debris or storm drain runoff debris not
contributed by the boater.

RESPONSE: NOAA has attempted to eliminate such comments from the FEIS.
However, it should be noted that since the Channel Islands are not developed
and are only accessible by boat or airplane, any litter in the waters
around these Islands, unlike that near the mainland coast, is likely
to come primarily from vessels.

COMMENT: The fact that a "detailed management plan for the sanctuary will
not be prepared until after the sanctuary is officially designated"
provides an invitation for regulation and management that is inconsistent
with an interpretation in which the Office of Coastal Zone Management and
our organization and other boating interests may concur.

RESPONSE: Any management plan developed for the marine sanctuary will
be consistent with the regulations. As discussed above, the regulations
have been rewritten to show more clearly that recreational boating will
be allowed in the marine sanctuary. The California Department of Fish
and Game, which is developing a management plan for the marine sanctuary
under contract with NOAA, is working closely with the Sanctuary Programs
staff to ensure that the marine sanctuary objectives are interpreted
properly. The management plan for the sanctuary will be developed in
consultation with interested user groups and will be available for public
comment and review.

COMMENT: The EIS gives some recognition to recreational boating concerns.
There is no review of the importance economically, psychologically, or
socially. It does not point out the importance of the Channel Islands
in the pursuit of recreational boating. It should include an understanding
of the role and impact of the recreational boating industry in California
to put in perspective the impact which decreased or increased recreational
boating opportunities might have on our State.

RESPONSE: Section E-3-g- discusses recreational boating around the northern
Th-annel Islands and Santa Barbara Island. Since the marine sanctuary will
not decrease or increase recreational boating, it is not necessary to
discuss the impact such a change might have on the State of California.

COMMENT: OCZM did not schedule a hearing in the greater Los Angeles
area did not reach boating interests in these areas at an early
date. Thus we have not had the opportunity to be in on the several
discussions that have led to this proposal and have had to comment in
a hurried manner.

RESPONSE: See generic response I.

G-40

CALIFORNIA SEAFOOD INSTITUTE: John P. Gilchrist - 12/5/80

COMMENT: The fear of pollution by oil (either drilled or spilled)
constitutes the reasoning of the Department of Commerce for intervening
in State Affairs. The State of California has an oil and gas sanctuary
surrounding 4 of the 5 islands in the proposed sanctuary. The present
system for regulating oil and gas activities makes provision for oil
spill prevention, protection of sensitive areas, and preservation of
air and water quality. The present level of oil and gas activity within
or adjacent to the 6 nmi proposed sanctuary is minimal.

RESPONSE: The threat of oil pollution is in fact a major reason for
the proposal to designate a marine sanctuary around the northern Channel
Islands and Santa Barbara Island, but several other reasons are discussed
in Section F-2., in including the contribution a sanctuary might make to
research and education. Although the current level of oil and gas development
within the proposed sanctuary is minimal, there is no guarantee that it
will remain so in the future. DOI has three lease sales scheduled for
California in the next five years, one of which, OCS Sale #68, definitely
encompasses the proposed marine sanctuary. California's oil and gas
sanctuaries only include State waters (3 nmi) and would be threatened
by oil development on tracts just outside the territorial sea.
Section F-2.c.l. provides a more detailed discussion of the rationale
for a prohibition on hydrocarbon activities in the proposed sanctuary
pursuant to future leases.

COMMENT: Twenty-one Federal and State authorities and eighteen State
and Federal agencies now contribute to management of the Ch_.@el Islands.
Will NOAA act as "referee" when the eighteen agencies start quarrelling?

RESPONSE: One of NOAA's sanctuary management objectives is interagency
Eo-ordination. See also generic response B.

COMMENT: The entire area is now susceptible to a simple "limited entry"
system which is in.itself a "tool" of management.

RESPONSE: NOAA is not aware of any such "limited entry" system.

CARPINTERIA VALLEY ASSOCIATION: Mrs. George M. Sidenberg, Jr., President
1/19/80

COMMENT: The Association supports alternative #4 with restrictions on
expanded oil and gas development.

RESPONSE: See generic responses A and D.

G-41

CENTER FOR LAW AND SOCIAL POLICY: Clifton Curtis - 3/4/80

COMMENT: Under the Department of the Interior's proposed 5-year lease plan,
Lease Sale #68 is scheduled for 1982 off Santa Barbara. Within the proposed
alternative 4 sanctuary boundaries, that proposed sale would include tracts
which were rejected by industry in lease sale #48, tracts for which leases
have expired, and tracts which were omitted from lease sale #48 due to
their proximity to the Islands. For the reasons that have been presented
by the Coalition (pp 5-6), by Get Oil Out (January 23, 1980, submission,
pp 13-15) and by NRDC (February 1, 1980, submission, pp 6-7), no new
leases should be permitted anywhere within the proposed sanctuary.

RESPONSE: See generic response D.

CHANNEL ISLANDS YACHT CLUB: Jim Donlon - 1/10/80

COMMENT: Sanctuary designation is important.

RESPONSE: No response necessary.

COMMENT: Fisheries resources have been ignored in the proposal. Fishery
resources are depleted and some are near extinction. Protection of the
fish life should be part of the marine sanctuary. The Department of Fish
and Game should enforce sanctuary regulations.

RESPONSE: NOAA does not propose to regulate fishing, as it is already
regula by the Department of Fish and Game and the Pacific Fishery
Management Council. The health of the fishery in the proposed sanctuary
appears to be good. See generic response F and Section F-2-b.

CHEVRON U.S.A., INC.: D.T. Magee - 1/21/80,1/24/80

COMMENT: Chevron U.S.A. strongly endorses the comment submitted by
the Western Oil and Gas Association at the public hearing in Ventura,
January 10, 1980. For the sake of brevity we will refer to the WOGA
document in our comments below.

RESPONSE: See responses to the Western Oil and Gas Associations comments.

COMMENT:

The DEIS is not, as presented, a fair and impartial assessment of
the proposal, or the ecologic conditions in the area of the proposed
sanctuary. Specifically:

G-42

a. It fails to effectively and equitably compare the status quo
protection for the environment with the "preferred alternative";

b. It omits many important references to a large body of scientific
research showing that oil and gas development has not had, and will not
have, any significant or lasting harmful effect on the environment of
the Channel despite the long history of production in these waters;

c. It fails to mention the proliferation of marine life around
existing production platforms in the Channel, or the fact that they do
not disturb or interfere with marine life near or around them.

d. It cites biomagnification as a deleterious effect of the presence
of oil in the ocean but omits reference to the numerous studies disproving
this hypothesis (see Attachment R to WOGA's comment). More particularly,
it omits mention of the fact that, despite some 20-25,000 bbls. of oil
naturally seeping into the Channel annually, research has shown that
there has been no bioaccumulation by the marine organisms of the area.

e. It proposes to prohibit petroleum development on new leases
,within the proposed sanctuary while permitting it on existing leases,
without offering any reasonable explanation for this inconsistency.

f. It fails to cite the true magnitude of the proposed sanctuary
(1130 square nautical miles or 959,000 acres), thus shielding the reader
from an awareness of the gross dimensions of the proposal.

g. It denigrates existing authorities charged with protecting
the Channel environment by asserting that a new regulatory heirarchy
is needed, but does not cite a single instance where these agencies
are not adequately protecting the environment.

RESPONSES:

a. Sections F.2.b. and F.2.c. are in effect a comparison of the
preferred alternative with the status quo.

b. See generic response E.

c. The FEIS has been expanded to include a discussion of platforms
as artificial reefs. See also generic response E.

d. The FEIS has been expanded to include a discussion of oil
seeps in the Channel. See also generic response E.

e. See response to API's third comment.

f. Section C of the HIS states that the area of the proposed sanctuary
is 1252.5 square nautical miles.

g. See generic response B.

G-43

COMMENT: We do not believe the DEIS is an adequate decisionmaking document,
and consequently fails to fulfill the requirements of NEPA and the Council on
Environmental Quality. We therefore urge that further consideration of this
sanctuary proposal be postponed until a thorough, impartial, and correct
assessment of the Channel environment has been made, and presented in a
second DEIS which could then be reviewed by the public and concerned parties.

RESPONSE: See EPA's comment dated 1/3/80. The DEIS adequately addresses
the impacts of the proposed action and fulfills the requirements of NEPA.

COMMENT: The DEIS fails to establish the need for prohibition of petroleum
operations on leases executed on or after the effective date of the
regulations. Accordingly, Section 935.6(c) of the regulations should
be deleted and 935.6(a) should be either modified to include new leases
or, preferably, deleted since its only purpose would be to refer to applicable
regulations which would not be necessary to establish their validity.

RESPONSE: See Section F-2.c.1 of the FEIS and generic response E, both
of which discuss the basis for a prohibition on oil and gas development
in the sanctuary pursuant to future leases.

COMMENT: It is arbitrary and premature to solicit comments on proposed
regulations before designation of the sanctuary. The Marine Sanctuaries
Act provide!,,# that after the sanctuary has been designated the Secretary
shall issue necessary and reasonable regulations to control any activities
permitted within the designated sanctuary.

RESPONSE: NOAA has no intention of issuing the regulations for the
sanctuary until after designation in accord with section 302 (8) of the
Marine Protection, Research and Sanctuaries Act. However, waiting to
propose regulations until after designation as the commenter suggests
would result in a highly inefficient procedure. The impact of any
proposed sanctuary simply cannot be assessed without knowing the proposed
regulations. This commenter would have NOAA circulate a DEIS covering
only the designation, unable to describe the practical effect of the
designation. Then NOAA would begin rulemaking, presumably circulating
a second DEIS describing the real impacts of the sanctuary.

COMMENT: We recommend that Section 935.6(b) be changed to read:

"No person may engage in any hydrocarbon operation unless the following
oil spill contingency equipment is available at the site of such
operation, or can be shown to be readily accessible to the site:
(1) 1,500 feet of open ocean containment boom on a boat capable of
deploying the boom; (2) one oil skimming device capable of open
ocean use; and (3) sorbent material at hand capable of picking up
at least 15-bbls. of oLl." (Changes underlined.)

RESPONSE: NOAA has retained the original form of the language of this
regulation, but will consult further with the California Coastal Commission
to assure that the regulation is not at variance with Commission requirements.

G-44

COMMENT: Section 935.8 serves no purpose except to refer to the Marine
Sanctuaries Act and existing regulations. It therefore is unnecessary
and could be deleted.

RESPONSE: This section sets forth the possible penalties for violating
marine sanctuary regulations. Even though it refers to the Marine Protection,
Research and Sanctuaries Act, this information is an important part of
the regulations.

COMMENT: Legislation is pending before Congress to establish the Channel
Islands National Park, which would include the northern Channel islands
and the submerged land and waters within one nautical mile of such islands.
The areas of the proposed park and the proposed sanctuary therefore
overlap, which will require modification of the sanctuary regulations
if the park legislation is enacted before designation of the sanctuary.
This is another reason for deferring consideration of proposed regulations
until after designation of the sanctuary.

RESPONSE: The Channel Islands Park bill has been signed into law.
The administrative boundary of the Park extending one nautical mile
seaward does not confer regulatory authority on the National Park Service
(NPS) in this area. Therefore, overlap with the park boundary will not
create conflict between proposed marine sanctuaries regulations and Park
management, (see Sections F-l-b and F-2.b). NOAA, DF&G, and NPS have
cooperated in discussions of possible management arrangements in the area.
(See also comments by the National Park Service.)

COAST ALLIANCE: William Painter - 1/22/80

COMMENT: The proposed sanctuary would provide the Channel with needed
protection.

RESPONSE: No response necessary.

COMMENT: The 12-mile radius proposed in alternative 4 not only affords
the most protection to the Channel, but is also supported by the Santa
Barbara County Board of Supervisors and the California Coastal Commission.

RESPONSE: See generic response A.

COMMENT: We urge that sealanes be made mandatory and that seabed alteration
policy apply to sensitive areas outside a 2 mile zone around the Islands,
as recommended in the testimony of the Scenic Shoreline Preservation
Conference.

RESPONSE: See generic response G.

G-45

CONCERNED CITIZENS OF SILVER STRAND: Mr. & Mrs. Phillip G. Bardos - 1/18/80

COMMENT: The sanctuary proposal should emphasize alternative 4 since
the key issue is the protection and preservation of an entire interrelated
environment.

RESPONSE: See generic response A.

CORINTHIAN YACHT CLUB: Floyd Woodcock - 1/10/80

COMMENT: The regulations of small vessels (935.7) are too ambiguous and
could lead to the expansion of prohibited boating activities.

RESPONSE: See generic response C.

COMMENT: Permit procedures (935.9 and .10) are too ambiguous as they
relat@_to boating.

RESPONSE: No permit is necessary for boating in the proposed sanctuary.

COMMENT: A major part of the Islands is privately owned--the sanctuary
proposal shouid not interfere with the Nature Conservancy or other private
operations on the Islands.

RESPONSE: The marine sanctuary has no jurisdiction on land, and does not
conflict with current or projected operations on the Islands.

CROWLEY MARITIME CORPORATION-STEAMSHIP ASSOCIATION OF LOS ANGELES HARBOR:
Charles P. Sloecombe - 1/10/80

COMMENT: The location of the public hearings was not convenient or well
'T
publicized.

RESPONSE: See generic response I.

COMMENT: Severe negative impacts would result if Channel Islands waters
are c5sed to fishing, shipping and recreation.

RESPONSE: The proposed sanctuary will not restrict commercial shipping
within one nmi of the Islands (see Section F.2.c.4). It will not regulate
fishing or recreation.

G-46

COMMENT: The Vessel Traffic Separation Scheme must be preserved. Regulations
sho e left to the Coast Guard.

RESPONSE: See generic response G.

DEFENDERS OF WILDLIFE: John L. Mohr - 1/11/80

COMMENT:

The southern California Continental Borderland is biologically rich, with
an abundance of diverse species and a number of rare species, such as
monoplacophorans, vestimentiferans, and pogophorans. To protect the area,
a full channel sanctuary, DEIS Alternative 4, should be chosen.

In addition, the sanctuary should be extended southward to include a
significant portion of the Cortes-Santa Rosa Ridge. The sanctuary border
to the north and west of San Miguel Island should extend at least to
the 400 meter isobath.

RESPONSE: See generic response A.

COMMENT: The DEIS paid insufficient attention to fish species in the
proposed sanctuary area, and negligible attention to invertebrate species.

RESPONSE: See generic response J.

COMMENT: It is biologically inappropriate to "grandfather in" the kelp
industry, without an objective analysis of the biological events involved.

RESPONSE: The harvesting of kelp is regulated carefully by the California
Department of Fish and Game, which has not found indications of harm
to kelp or kelp bed communities from harvesting.

COMMENT: The DEIS lacks information on subsurface current regimens and
ijpwelling systems. These are of immense importance and should be taken
into account.

RESPONSE: Section E.l. discusses the currents and upwelling in the
study area.

G-47

DESOMOUNT CLUB: Evelyn Gayman, Conservation Chairman - 1/22/80

COMMENT: The sanctuary should be designated encompassing the waters of
the total Santa Barbara Channel from Point Conception to the Mexican
Border and 12 miles around the Islands.

RESPONSE: See generic response A.

COMMENT: It is vital that the CHANNEL ISLANDS MARINE SANCTUARY be
established as:

--Biologically the richest and most diverse maring habitat in
the U.S. and as
--needing the protection from oil drilling induced by thepanic
pressures for more fossil fuels, and as
--no longer protected by the "geographic remoteness" and as
--giving recognition to the outstanding value and vulnerability of
the islands and surrounding waters, and as
--establishing a single agency responsible for monitoring the
entire system.

RESPONSE: No response necessary.

COMMENT: Tanker traffic in the area would be disrupting and/or damaging
to many forms of life.

RESPONSE: NOAA's regulation prohibiting vessels engaged in the trade
of carrying cargo or of servicing offshore installations within I nmi
of the Islands (see discussion in Section F.2.c.4) addresses this problem.

COMMENT: No activities involving the recovery of oil from the Santa
Barbara Channel can compensate for the tremendous ecological damage
that can be incurred.

RESPONSE: See generic response E.

ECOLOGY CENTER OF SOUTHERN CALIFORNIA: Nancy Pearlman, Executive Director
- 1/20/80

COMMENT: The excellent Marine Sanctuary Program will protect a valuable
wildlife habitat. The proposed sanctuary should be permanently protected
and activities within 6 nmi of the Islands should be regulated.

RESPONSE: No response necessary.

G-48

ENVIRONMENTAL DEFENSE CENTER: Mark Eskenazi - 1/11/80

COMMENT: Alternative 4 would enable needed comprehensive planning and
coordination for permitted uses within the entire Channel area. Alternative 2
would foster a piecemeal and fragmented approach.

RESPONSE: See generic response A.

ENVIRONMENTAL DEFENSE CENTER: J. Marc McGinnes, Executive Director, 1/10/80

COMMENT: Alternative 4 will best enable and facilitate critically needed
comprehensive planning and coordination of the permitted multiple uses
within the entire channel area, which is Ilan interrelated ecosystem."

RESPONSE: See generic response A.

COMMENT: The Environmental Defense Center endorses the comments of Santa
Fa-rbara County and the Scenic Shoreline Preservation Conference.

RESPONSE: See the responses to the comments of Santa Barbara County and
the Scenic Shoreline Preservation Conference.

ENVIRONMENTAL DEFENSE NETWORK: Corey Dublin - 1/11/80

COMMENT: It is imperative that the whole Channel be included within the
Sanctuary boundaries for a broad based monitoring system.

RESPONSE: See generic response A.

G-49

COMMENT: Alternative 4 does not adequately address existing OCS leases.

RESPONSE: Alternative 4 requires that additional onsite oil spill
containment equipment be required for all offshore platforms in the
sanctuary (see Sections F.3 and F.4).

COMMENT: The Platform Hondo experience indicates that the oil companies
have not shown good faith -- moving their platforms outside State waters
to avoid regulations.

RESPONSE: OCS development beyond the territorial sea is regulated by
the U.S. Department of Interior and numerous other Federal agencies.
Furthermore, the California Coastal Commission can require that OCS
development, which is subject to Federal controls, be consistent with
California's coastal zone management plan (see Section F.I.).

EXXON COMPANY U.S.A.: J. R. Jackson, Jr. - 1/18/80

COMMENT: The Marine Protection, Research and Sanctuaries Act directs
the Secretary of Commerce to promulgate reasonable and necessary regula-
tions. In Exxon's opinion, these proposed regulations are neither
reasonable nor necessary. The Designation Document should describe those
"impacts" which do affect proposed sanctuary values rather than list
"activities" whiih may affect them. Further, this list should include
only those impacts which will require regulation rather than all those
which may require regulation. This same philosophy applies to the
implementation of the proposed sanctuary restrictions or prohibitions.

RESPONSE: The Designation document is not an environmental impact
analysis, but a charter which sets out a framework for marine sanctuary
regulations. Thus it is not appropriate for the Designation to describe
impacts; that is done in the EIS. Since the Designation document describes
the limits of activities NOAA may regulate in a marine sanctuary, it
should list all the activities which may foreseeably require regulation
as well as those which currently do.

COMMENT: The effects of oil spills: The casual reader of the DEIS would get the
erroneous impression that crude oil introduced into the Channel would be a
foreign substance that would cause untold harm over both considerable time

G-50

and distance. In only one reference (page F-75), is it even hinted
that natural seepage may possibly occur near the proposed sanctuary. The
DEIS is incomplete without discussing the locations, volumes and impacts
of the thoroughly studied natural seeps in the Channel and the researched
results of those studies. An excellent list of references on the impacts
of oil seeps and spills, compiled by Ed Mertens of Chevron, is being
submitted to NOAA by WOGA.

RESPONSE: The discussion of oil seeps has been expanded in the HIS
7-seeSection F.2.c.1). See also generic response E.

COMMENT: The extrapolation of data on hypothetical oil spills (page F-81)
to justify restraint of oil and gas activity in the Channel goes far
beyond any reasonable limits. The text states that "Probabilities range
as high as 68 percent that spills occurring on a proposed lease site (P9)
and 70 percent from existing leases (see E5 on figure F-11) will reach
seabird breeding and nesting areas." A footnote then disclaims this by
stating that the probabilities are not specific to haulout and nesting
areas on the Islands alone but to the entire Bight. A more accurate
probability table is found on Table F-7. It should be noted that for
each of the 5 major islands, the probability of landfall of a major
spill from all the original tracts included in proposed Sale #48 was
equal to or less than that from existing leases. It should also be
emphasized that a spill contacting an island is not tantamount to
contacting either a haulout or nesting area. Exxon knows of no bird
that nests below high tide where most spills come ashore.

RESPONSE: The sum of the probabilities of an oil spill from OCS Sale #48
and from all the pre-existing leases is greater than the probability of
an oil spill from the pre-existing leases alone. If an oil spill reaches
one of the Islands, it will affect the birds and mammals that use that
area. Marine mammals frequently haul out below high tide line, and birds
and mammals swim, feed, dive, and raft in the nearshore waters. Inter-
tidal organisms would also suffer greatly if an oil spill reaches Island
shores.

COMMENT: The California Coastal Commission is requiring (through
CZMA consistency provisions) exactly the same oil containment
equipment NOAA is proposing (in both the DEIS and Marine Sanctuary
regulations) for Exxon's exploration activities in the Santa Barbara
Channel. NOAA's implication that the State will not impose the same
requirements in all tracts near the Islands is unfounded. We are of
the opinion that the Coastal Commission will not lose sight of the
sensitive nature of the area.

.RESPONSE: NOAA's proposal to require additional onsite oil spill
containment equipment is endorsed by the California Coastal Commission.
Since all the tracts in the proposed sanctuary merit the additional oil
spill containment equipment required by NOAA, a general marine sanctuary
regulation will be more appropriate than case by case imposition of the
requirement through consistency review.

G-51

COMMENT: The FEIS for Sale #48 discusses in 'some depth the number of
vessels berthed and launched at Ventura Marina, Channel Islands Harbor
Oxnard, Port Huenene Harbor, Santa Barbara and Los Angeles. It also
discusses the probable distinations for most of these recreational
craft and their purposes. The interpretation and extrapolations of
the Sale #48 FEIS data should have been.included in the Channel Islands
DEIS, because it makes it apparent that the DEIS concern expressed over
50 Channel and Traffic Separation Scheme crossings per day by commercial
and petroleum craft compared to crossing by other vessels is without basis.

RESPONSE: Since commercial and petroleum c raft are generally.larger
and less maneuverable than recreational and fishing vessels, and
since the environmental consequences of an accident are likely to be
much more severe for a freight or petroleum carrying ship than for
smaller vessels not carrying hazardous crago, the distinction has a
basis. The proposed regulation prohibiting vessels engaged in the
trade of carrying cargo or servicing offshore installations from
entering the waters within one nmi of the Islands will not adversely
affect commercial shipping, since unlike fishing and recreational
boats, the affected vessels have no reason, to enter nearshore waters.

COMMENT: We strongly urge the shortening of the Appeals procedure of
935.11. As now written, there are 5 periods of 30 day5.each,,plus,one
that is indefinite in length during which "sufficient information" is
to be gathered. Each of these time limits may be extended another
30 days. To alleviate the problem, we propose modification to the
first sentence of Subpart (c) as follows:

"If a hearing ts requested or if the Administrator
determines that one is appropriate, the Administrator
may grant an informal heari.ng before a Hearing Officer
designated for that purpose within 30 days of the
Administrator's decision as outlined in Section 935-11,
Subpart. (b)" (emphasis added to denote modification),
after first giving notice of the time, place and subject
matter of the hearing in the.Federal Register."

Subsequent to the modification proposed above, the last sentence in Sub-
part (b) should be modified as follows:

"The Administrator will notify all interested persons of
the decision and the reason(s) therefore, in writing,
within 30 days of thereceipt of sufficient information."

RESPONSE: The statement that there are "5 periods of 30 days each"
is incorrect. If no hearing is needed, there are two periods of 30 days,
one a filing period for the appeal and the second to decide the appeal.
Neither seems unreasonable. If a hearing is needed it adds two more
periods, one to notify interested persons of the hearing and one for
the hearing officer to render his decision. It is difficult to see
how to shorten these limits, except the first, which the regulations
provide can be shortened wfien appropriate. In any event , the

G-52

commenter's proposed amendment does not seem to help. It places the
hearing after the Administrator's decision.

COMMENT: Neither Draft Designation Document, nor the general DEIS
text describe the onsite administrator of the sanctuary in any detail..
We believe that this important detail should be carefully spelled out.
As now portrayed, most of the authority appears to be with the very
authorities described in the Status Quo Alternative as inadequate.
Later, they are described as having the experience and knowledge
necessary to manage the sanctuary. The real authority must be
delineated.

RESPONSE: See generic responses F and B and Section F-2.b.

COMMENT: The DEIS discussions on rare, endangered and threatened species
within the proposed sanctuary are unclear. The question of the impact of
OCS petroleum activity or oil spills on cetaceans has not been fully
researched. However, existing data and information on past spills or
seeps shows it to be minimal. The existing data certainly does not
conclude there will be "significant" behavioral changes.

RESPONSE: Section F.2-c.1 discusses the possible effects of OCS development
on marine mammals.

COMMENT: The DEIS treatment of seabird endangered species as it appears
on page E-34 is also confusing. The only true seabird normally found in
the proposed marine sanctuary area is the California Brown Pelican. The
others listed are terrestrial and unlikely to be affected by either spills
or seeps. The pelican is a normal and frequent visitor to existing plat-
forms in the Channel.

RESPONSE: Nine of the 12 seabird species found in the Southern California
Bight breed on the Islands and offshore rocks of the proposed sanctuary.
Spills which reach the Islands, originating in the marine areas might
affect terrestrial endangered species and certainly could affect the brown
pelican. See Section E.2.b.

COMMENT: The DEIS on pages F-49 and F-50 makes the point that the present
multitude of regulatory authorities with different objectives and jurisdic-
tions bring about policy conflicts and lowered management effectiveness.
Exxon's concurs with this NOAA position. Article 5, Section 3, of the
Draft Designation Document, however, appears to add at least one more
layer of policy conflict and lower management effectiveness appreciably.

RESPONSE: See generic responses B and F.

COMMENT: On August 21, 1979, the Ninth Circuit Court ruled that jurisdic-
tion for air emissions on the Outer Continental Shelf lies with the DOI,

G-53

not the EPA. Consequently, the California ARB emissions standards are
not applicable to OCS operations and lines 3 through 10 on page F-26
should be deleted.

RESPONSE: Comment accepted.

COMMENT: Discharges are specifically described in the proposed regula-
tions 935.7(a)(1). While firmly believing in protecting the environment
from harmful discharges Exxon does not believe that the proposed regulations
(parts (B) and (C) as now written) are either necesary, reasonable or
enforceable.

RESPONSE: This comment is unclear. Parts (B) and (C) of Article 935.7
(a)(1) of the proposed regulations state that marine sanitary device
effluents and non-polluted cooling water discharges will be allowed in
the sanctuary. See Section F.2.c.2 for a detailed basis for the proposed
regulation of discharges.

COMMENT: Anchoring should be proposed as a regulated activity in order
to protect corals. The single paragraph in the DEIS on page E-51 on
Allopora is incomplete compared to other NOAA efforts to protect corals.
Allopora, the primary reason behind the Tanner-Cortez sanctuary recommenda-
tion, lives around the Channel Islands in exactly the places where anchoring
is most likely to occur.

RESPONSE: Unlike at other marine sanctuaries, existing and proposed,
which are intended to protect corals, the coral wfiich occurs at the proposed
Channel Islands marine sanctuary (Allopora californica) grows in scattered
formations, not in reefs. Consequently it is much less likely that
an anchor will damage the coral than at a reef such as Key Largo or
the Flower Garden Banks. Any danger to Allopora would come principally
from collecting, and would best be countered by effective enforcement.
However, if NOAA's monitoring program shows that the coral is sufficiently
concentrated for anchoring to pose a threat, NOAA could propose further
regulations to deal with that issue.

COMMENT: Exxon does not understand the statement found on page F-50
claiming the present regulatory system does not provide for the preservation
and protection of special marine habitats except for critical habitats
of endangered species. The Fish and Wildlife Coordination Act, 16 USC.
661-667e (FWCA) authorizes the "development, protection, rearing and stocking
of all species of wildlife, resources thereof, and their habitat, in
controlling losses of the same from disease or other causes,..." The
question arises as why the Fish and Wildlife Coordination Act was listed
as an existing Federal Authority in an earlier draft of the DEIS but
was omitted in the current document.

Contrary to the statement found on page F-50 that the Marine Mammal Protec-
tion Act was "not designed to protect their habitats from potentialy adverse

G-54

uses", Section 1361(2) of the Act says, "In particular, efforts should be
made to protect the rookeries, mating grounds, and areas of similar signifi-
cance for each species of marine mammal from the adverse effect of man's
actions."

Contrary to the conclusion on page F-50 that the Migratory Bird Treaty
Act does not protect the habitats from potentially adverse impacts,
it is Exxon's contention that it does.

As an alternative to marine sanctuary designation, under the terms of
16 U.S.C. 668dd-668jj, the Secretary of Interior's powers related to
all lands, waters and interests therein related to the conservation
of fish and wildfish can be culminated into a Natinal Wildlife Refuge.

Still another alternative to sanctuary designation not discussed in the
DEIS is the National Natural Landmarks Program. The purpose of this
program is to identify and designate nationally significant examples
of aquatic communities and habitats of native plant and animal species
that constitute the nation's natural heritage.

.RESPONSE: A description of the FWCA has been included in the FEIS.
It was omitted in the interest of brevity, as were other authorities
which are considered somewhat more indirect in their application. The
FWCA authorizes the Secretary of the Interior to "Provide assistance to.9
and cooperate with" other agencies in accopmlishing the objectives described
by the commenter. It is primarily a comment statute. The MMPA does not
provide specific procedures or authority to accomplish protection of
habitat such as that in the Endangered Species Act. However, even the
latter Act only addresses Federal actions, not State or private actions.
NOAA disagrees with the contention concerning the Migratory Bird Treaty
Act.

The Natural Landmarks Program has limited regulatory effect although Federal
action must not adversely affect such sites. It provides no protection
from State or private activities. While it is true that a National Wild-
life Refuge could conceivably provide some protection to the area under
consideration, the purposes and activities of the refuge system are more
focused and less compatible with multiple uses than the marine sanctuary
program.

COMMENT: The authors of the DEIS do not appear to fully appreciate nor
understand the impact of a Class I Clean Air Act designation for the
Islands. This designation would impose a 50 km. buffer zone in which no
significant deterioration would be allowed. As defined on page F-39,
this includes any stationary source with the potential of emittting
100 tons per year. This would apply not only to platforms in the Channel
but to developments on the mainland. The fact that most emissions from
either offshore platforms or mainland facilities would not ordinarily
come in contact with the Islands (according to the FEIS for Sale #48,
Table II. B-1), is apparently ignored. That fact that the emissions
from the numerous boats nearer the Islands will be exempt is questionable.

G-55

RESPONSE: NOAA did not propose Class I Clean Air designation for the
Islands or make any statements about mainland or vessel discharges in
that context. The DEIS merely noted that the Channel Islands National
Monument had been proposed for Class I designation, and that OCS
development near the Islands would increase the liklihood that Class I
air standards on the Islands would be exceeded.

COMMENT: Exxon does not believe that the foregone social value of the
proposed marine sanctuary is limited to $1 million as described on
page F-98. If the oil equivalent of oil and gas reserves of the 24 deleted
tracts is 7.3 million barrels, then the dollar value foregone is closer to
$124 million when the 'price of imported oil price is $30/Bbl and domestic
new oil is $13/Bbl. The cost of imported spot oil would be even greater.
This value may be low when compared to the social/ costs of going without.

RESPONSE: See generic response K.

COMMENT: In summary, Exxon doe's not believe that NOAA has made either a
clear convincing case that a Channel Islands Marine Sanctuary is a necessary
or justifiable major Federal action. Further, the proposed Channel Island
sanctuary regulations do not meet NOAA's own final criteria for sanctuary
regulations as published."

Exxon believes that NOAA should decide once and for all whether the primary
purpose of the sanctuary is either (1) protection and preservation of the
Channel Islands ecosystem or (2) enhancement and encouragement of recreational
and research efforts. The DEIS makes a fine case that recreation and ecosystem
protection are mutually independent and perhaps exclusive. The proposed
regulations encourage intensified use of all activities except petroleum.

RESPONSE: The proposed*regulations do not encourage any intensified use,
although some activities, such as fishing and recreational boating, are
deemed compatible and not regulated by the proposed sanctuary. Although
in some cases, resource preservation may conflict with recreation and
research activities, at the current level of use around the Islands,
both activities are still compatible with ecosystem protection. The
primary purpose of the sanctuary is clearly stated in Section D to be
resource preservation'.

NOAA is not aware of any conflict between the proposed sanctuary and the
marine sanctuary program's general regulations.

COMMENT: NOAA does not have the authority to restrict removal of cultural
or historical resources on the OCS under existing law. A Florida lawsuit
filed on December 4, 1979, may soon establish that the law of finds is
paramount to laws of historic preservation in territorial waters as well
as on the OCS. If protective restrictions similar to those placed on
the U.S.S. MONITOR in the Monitor Marine Sanctuary are imposed on historical
or cultural resources found in the Channel Island Marine Sanctuary, the
environmental and economic consequences will definitely not be minimal as
stated on page C-12.

G-56

RESPONSE: NOAA disagrees that it lacks the authority to protect cultural
or historical resources. Its position is widely sup.ported with respect
to the U.S.S. MONITOR. Commenter's contention that restrictions similar
to those protecting the MONITOR will have more significant consequences
than described is inconsistent with the contention that NOAA lacks
authority. However, no such additional consequences have been brought
to NOAA's attention.

COMMENT: On page F-61, the DEIS gives, as.one reason for creating the
sanctuary, the supposition that offshore oil activities would disturb
the breeding po.pulation.s of the 5 species of pinnipeds found on San Miguel
Island. However, it is noted on pages F-47 and F-48, the U.S. Navy
has established a Naval Danger Zone that extends 3 miles seaward of
the eastern half of San Miguel Islands where bombing practice takes
place approximately 200 times a year. Since such military activity
evidently does not affect the prolific marine mammal life on San Miguel
Island, it seems highly questionable that activity by the offshore
industry would impair this natural resource in any,way.

RESPONSE: The fact that pinniped communities survive in the.area despite
considerable military activity does not necessarily mean that the
pinnipeds are not adversely affected by military activities, nor does
it mean that additional activities, such as oil and ga.s development,
will have no additional effect, particularly if they affect areas away
from military activities.

COMMENT: The first sentence in Subpart (c.) of 935.9 provides the Assistant
Administrator open-ended power to set conditions on all permits. This
discretionary power is not in the spirit of *NOAA's proposal to allow
activities under Section 935.5 "subject to all prohibitions, restrictions
and conditions imposed by any other authority. (emphasis added)
Existing authorities have the power and expertise to protect the resources
of the Channel Islands, and therefore should set any necessary restrictions
on activities allowed in the sanct.uary, rather than NOAA.

RESPONSE: The Administrator's power to set conditions under Section 935.9
only exists when NOAA issues a permit and this will occur, of course,
only if an activity is prohibited by NOAA (section 935.7). Section 935.5
refers to activities not prohibited, by NOAA and merely states that these
are still subject to requirements established by other authorities.
It is totally consistent not to subject to additional permitting requirements
those activities otherwise adequately controlled while ensuring broad
discretion to condition the remaining activities to protect the Sanctuary

COMMENT: A definition of "hearing Officer" as referenced i-n Section
935.11 would be appropriate. The question arises as to whether that
officer comes from NOAA or an outside agency.

G-57

RESPONSE: NOAA is in the process of reviewing options for providing
hearing officers for a wide variety of programs. When it is possible
to be more specific, these regulations or a NOAA-wide regulation may
be appropriate.

FISHERMEN AND ALLIED WORKERS' UNION: John J. Royal, Executive Secretary
1/8/80

COMMENT: A public hearing should be scheduled and held in the Los Angeles/
Long Beach area so that local interest parties can conveniently testify.

RESPONSE: See generic response I.

COMMENT: The Union supports the comments submitted by the Pacific
Merchant Shipping Association.

RESPONSE: See responses to the Pacific Merchant Shipping Association's comments.

FRIENDS OF THE EARTH AND COAST WATCH: Robert Wilkinson - 1/11/80

COMMENT: A revised version of alternative 4, from Point Arguello, to
fifteen miles around the Islands to Point Mugu should be designated.
The DEIS makes a good case for alternative 4. Inclusion of the entire
Channel is crucial to preservation and restoration of the entire
Channel ecosystem'.

RESPONSE: See generic response A.

COMMENT: There should be no oil development within six miles around the
Islands.

RESPONSE: NOAA proposes to prohibit oil and gas development pursuant to
future leases in the sanctuary. See also Section F-3.
COMMENT: Dispersants are an insufficient solution to ;he problem of oil spills.

G-58

RESPONSE: See Section F-2.c.l. for a discussion on dispersants. NOAA's
proposed regulations prohibit oil and gas development pursuant to future
leases in part in order to minimize the occurrance of oil spills.

COMMENT: Tanker traffic should be required to use traffic safety lanes
and radar monitoring and control of vessels should be instituted in the
Channel similar to that in the English Channel.

RESPONSE: See generic responses G and H.

COMMENT: There has been inconsistent testimony that the State can handle
everything, yet the State's policy on sea otters had grave negative
consequences. The fishermen are only concerned that the Federal government
will add more controls -- too nearsightedly.

RESPONSE: The State's jurisdiction does not extend beyond 3 nmi from shore
Fs-eealso generic response B). The proposed designation document guarantees
that the marine sanctuary will not regulate fishing.

FRIENDS OF THE RIVER: Roberta Jortner - 1/11/80

COMMENT: The proposed sanctuary boundary that is not large enough will be
adversely affected by destructive processes outside its boundaries.

RESPONSE: See generic response A.

COMMENT: Comprehensive overall management will improve efficiency and
effectiveness within existing agencies.

RESPONSE: No response necessary

COMMENT: There should be a five-year moratorium on all new lease sales.

RESPONSE: NOAA considered but rejected a possible moratorium on all oil
and gas activities pursuant to future leases. See Section FA and generic
response D.

G-59

FRIENDS OF THE SANTA MONICA MAINTAINS, PARKS AND SEASHORE: Susan Nelson -
1/10/80

COMMENT: Alternative 4 should be approved. The sanctuary should be
extenTp-d down to the Point Mugu and Malibu Beach areas.

RESPONSE: See generic response A.

COMMENT: A merging of interests between oil development and environmental
prote n has been recognized in the DEIS and in the regulations.

RESPONSE: No response necessary.

FRIENDS OF THE SEA OTTER: Betty Davis 1/20/80

COMMENT: Regulations of petroleum development within the proposed sanctuary
shoul e more stringent. No production should be permitted within the
boundary, and no exploration permitted in any of the 15,tracts inside
the boundary until that part of the tract lying outside the boundary
has first been explored.

RESPONSE: See Section F-3. of the FEIS.

COMMENT: The Sanctuary plan should retain the option to more strictly
regula the direct and indirect habitat destruction caused by kelp
harvesting. Kelp harvesting should not be allowed within sanctuary
boundaries. If it must be, regulations on kelp cutting should be made
an integral part of the proposed regulations.

RESPONSE: Kelp harvesting is regulated by the California Department of
Fish and Game, which found no evidence that kelp or kelp bed communities
are endangered by the current level of kelp harvesting around the Islands.

COMMENT: Regulations should prohibit the placement of structures in the
VTSS-

RESPONSE: See generic response H.

NOAA considered the technical comments provided by Friends of the Sea
Otter and inserted them into the FEIS where possible.

GET OIL OUT: W. K. Rogers - 1/10/80

COMMENT: Get Oil Out supports comments submitted by the County of
Santa rbara.

G-60

RESPONSE: See responses to the comments by Santa Barbara County.

COMMENT: There should be no additional restrictions on commercial and
sport fishing.

RESPONSE: NOAA exempts fishing from marine sanctuary regulation.

COMMENT: Since most of the land is owned by the Federal government, they
sho-u-T-d-regulate it - rather than the oil industry by default.

RESPONSE: No response necessary.

COMMENT: The Channel is an interrelated, singular but complex
ecosystem where artificial boundaries would be ineffective in
controlling pollution or oil industry accidents. Therefore, alternative
4 should be selected. However, if there is no other choice, alternative
2 should be chosen.

RESPONSE: See generic response A.

COMMENT: There are onshore proven and potential sources of oil that
should be developed first - we will need oil in ten to fifteen years
when the oil industry will have learned how to exploit supplies safely
and how to control inevitable accidents. Numerous accidents and seepage
continue to occur in the offshore development. The risk for irreversible
impacts from oil development js not offset by the incremental availability
of oil for the U.S.

RESPONSE: The proposed regulations prohibit oil and gas development
pursuant to future leases within 6 nmi of t.he Islands. See also
generic response D.

GET OIL OUT: Edward H. Comer, Bruce J. Terris, Law Offices - 1/23/80

COMMENT: GOO firmly supports the creation of a Marine Sanctuary in
the Sant Barbara Channel. We agree with the information included
in the DEIS description of the environment, and support most of the
management controls recommended in the DEIS.

,RESPONSE: No response necessary

COMMENT: The proposed sanctuary area is too small. It should include
the entire Santa Barbara Channel, and regulations prohibiting oil and
gas activities on unleased lands should be applied throughout the Channel.
We submit that the entire Channel must be included in the sanctuary to
protect the resources surrounding the Channel Islands from serious and

G-61

irreparable damage from oil exploration, development or transportation
elsewhere in the Channel.

RESPONSE: See generic responses A and D.

COMMENT: We believe that the DEIS fails to identify properly all the
important resources located throughout the Channel. Large portions of
the DEIS address only animal and plant habitats located near the Channel
Islands and ignore similarly important biological and natural features
of other portions of the Channel. For example, as we have mentioned above,
kelp beds are an important biological and commercial resource. The DES
identifies only those beds near the Channel Islands and makes no mention
of the beds extending for many miles along the mainland coast of the Channel.
DEIS, P. E-49. The inclusion of information regarding the location of these
kelp beds is necessary to identify fully the resources of the Santa Barbara
Channel. In the absence of such data, the public and the decisionmaker
might well assume that all kelp beds are located around the Channel Islands
and that none exist elsewhere in the Santa Barbara Channel. This might
unfairly lead a-decisionmaker to favor a sanctuary restricted to areas
around the Channel Islands and prejudices the adoption of the alternatives
including the entire Channel as a sanctuary.

RESPONSE: NOAA has attempted to discuss more fully the resources of
Santa Barbara Channel in the FEIS.

COMMENT: The DEIS states that the 6-mile sanctuary limit is at best a
buffer zone which is intended to provide adequate time and space to clean
up an oil spill before it reached shore. Judging by past experience,
especially the 1969 oil spill at Santa Barbara, the 1978 spill near
Gaviota, and the 1979 spill at Ixtoc I, a 6-mile limit is not large
enough to provide effective protection.

RESPONSE: See the boundary discussion in Sections F-2. and F-4. See
also generic responses D and A.

COMMENT: The larger sanctuary we proposed would not prohibit recovery
of the "substantial economically recoverable petroleum reserves" mentioned
in the DES at p. F-133. Most of the tracts in the Channel are currently
leased.

Our sanctuary proposal does not prohibit oil and gas development on these
leases. Additional leases near Santa Barbara have already been informally
designated as a non-leasing area by the Department of the Interior and State
policy. Moreover, Figure E-17 (DEIS, p. E-63) demonstrates that many of
the unleased tracts in the Channel were recently offered in Lease Sale #48
in 1979, but were not leased by industry. Either the industry believes
the tracts contain insufficient resources to warrant leasing or the
industry lacks sufficient technology to develop the tracts safely. In
either case, prohibiting their development will have little adverse impact
upon the recovery of oil and gas resources in those areas at the present
time.

G-62

RESPONSE: The fact that many tracts offered in Lease Sale 48 were not
leased does not necessarily mean that those tracts cannot be developed
or do not contain exploitable reserves. Industry interest in those
tracts may depend at least in part on results from exploration on
existing leases. In addition, if current technology is inadequate
to safely develop some of the unleased tracts in the Channel, the
technology may improve. Finally, if oil prices continue to rise,
petroleum reserves that are may not now be profitable to develop may
become economically recoverable.

COMMENT: In order to prevent the possibility of a catastrophic accident
in the Channel which could spill into the marine sanctuary, we propose a
requirement that all vessels carrying petroleum products which do not
call upon a port within the Channel be prohibited from entering the
Channel and be routed outside the Channel Islands.

In addition, we propose that all oil and gas drilling activities be
prohibited from occurring within a quarter mile of the shipping lanes
or in the separation zone between lanes.

RESPONSE: See generic responses G and H.

COMMENT: The DEIS makes no mention of the consultation process required
by the Endangered Species Act and therefore it is not clear whether you
intend to initiate such consultation. Although implementation of a
marine sanctuary proposal will be beneficial to these endangered species,
nevertheless, prior to carrying out the proposal, NOAA is still required
to comply with the procedures established by Section 7 of the Endangered
Species Act, 16 U.S.C. 1536.

-We urge that consultation be begun as soon as possible in order to avoid
subsequent delays in the decisionmaking process.

RESPONSE: NOAA has consulted with the Office of Endangered Species in
the Department of Interior and with the National Marine Fisheries
Service in the Department of Commerce concerning the proposed action.
Both authorities responded in favor of marine sanctuary designation.

GREENPEACE (A Non-Profit Environmental Foundation): Beth Bosworth,
Director - 1/5/80

COMMENT: The description and impacts reflect positively on the varied
and unique marine ecology of the area. The proposed sanctuary meets the
criteria under the Marine Protection, Research and Sanctuaries Act. It
would unify protection of marine resources by having primary authority
over the myriad of agencies now governing the area. It would identify
and educate the public on the diversity of life in the Channel Islands,
and it could lessen the chance of a major oil spill by prohibiting
further lease sales.

G-63

RESPONSE: No response necessary.

COMMENT:. Greenpeace is especially concerned for-the health and safety
of dolphins, sea otters, lions and seals as well as the general well-being
of the entire marine ecosystem. Considering our uncertain economic
situation in regards to energy, and our reliance on oil, it would seem
premonitory to envision development of those leases within the very
near future. In light of this, alternative #3 would impose the most
stringent protective measures.

RESPONSE: Although the sanctuary regulations proposed under alternative 3
are more restrictive for operations on leases predating the promulgation of
regulations than those of the preferred alternative, NOAA has determined
that an overall sanctuary prohibition of exploration and development
activities on such leases is inappropriate at this time. See Section F.3
for a detailed comparison of alternative 2 and alternative 3.

COMMENT: It does not seem logical or prudent to proceed with any
hydrocarbon development considering the absence of any 1007. effective
means of controlling an oil spill.

RESPONSE: See Sections F.3 and F.4, specifically the discussion of alternatives 3
and 4, a discussion of the basis for NOAA's decision not to prohibit
oil and gas operations.

COMMENT:. Dredging activities in the development of pipelines could
very well disrupt the fragile marine environment.

RESPONSE: The environmental costs of pipeline construction must be
weighed against the risk of disturbance and oil pollution associated
with the continued barging of oil and gas ashore from offshore plat-
forms. In many cases, if sufficient quantities of petroleum are
produced, the laying of pipelines is environmentally preferable to
barging. Several Federal and State authorities must issue permits for
or otherwise review, the construction of pipelines, including the
U.S. Geological Survey, the Army Corps of Engineers, and the
California Coastal Commission. Thus any pipelines are reviewed
carefully for geological safety and environmental impacts.

HANNA-BARBERA'S MARINELAND - Brad Andrews, Curator of Mammals - 2/5/80

COMMENT: From time to time, Hanna-Barbera's Marineland obtains permits
from NOAA pursuant to the Marine Mammal Protection Act to collect live
marine mammals for display. In order to obtain such a permit, we submit
an application which contains very detailed information concerning our
need for the mammals, our facilities for collecting, transporting and

G-64

housing the mammals, our proposed manner of selecting a mammal so as not
to weaken the group he is a part of, the area in which we propose to
collect, the timetable for collection, etc. In short, we believe that
in this permit application we furnish to you includes the types of information
which will be required under 935.9 of the proposed rules.

RESPONSE: No response necessary.

COMMENT: The proposed rules, as presently written, could be interpreted
to prohibit collecting live marine mammals within the proposed Marine
Sanctuary without obtaining an additional approval by NOAA of the permit.
Indeed, the proposed rule could also be read to prohibit entering the
Marine Sanctuary for collection despite having obtained a permit from NOAA
which allows the collection. Marineland believes that such a result was not
intended by the drafters of the proposed rule. Neither of these inter-
pretations is necessary for, or helpful, to achieve the purposes of the
proposed rule. NOAA will already have had an opportunity to scrutinize
and to reject a proposed activity, based upon the same considerations which
will apply to permit applicants under the proposed rule.

Therefore, we respectfully suggest that the proposed rule be amended by
adding two additional clarifying sentences at the end of 935.10 as follows:

All permits, licenses and other authorizations issued by NOAA
pursuant to the Marine Mammal Protection Act are hereby certified
and shall remain valid. Any person in possession of permits,
licenses or other authorizations issued by NOAA pursuant to the
Marine Mammal Protection Act may conduct any activity in the
Sanctuary including any activity specifically prohibited under
935.7 if such activity is related to the conduct permitted in
such permits., licenses or other authorizations.

RESPONSE: The only regulation which might prohibit the commenters'
collection activities as described above would be the prohibition
on disturbing marine birds and mammals by overflights of less than
1000 feet. This could occur if collection is done by helicopter.
In such an event, the marine sanctuary authorities will coordinate
closely with the National Marine Fisheries Service to avoid
permitting delays or complications.

LEAGUE OF WOMEN VOTERS OF SANTA BARBARA: Mary Lou Casson 1/11/80

.COMMENT: Alternative 4 should be adopted.

BESPONSE: See generic response A.

.COMMENT: The League supports the findings of Al Reynolds of the County
of Santa Barbara.

G-65

RESPONSE: See the response to the comments made by Santa Barbara County.

LEAGUE OF WOMEN VOTERS OF VENTURA COUNTY: Joan Harris - 1/10/80

COMMENT: The cooperative management of the sanctuary is provided by
the proposal, as is needed.

RESPONSE: No response necessary.

COMMENT: Restrictions on oil and gas activities are necessary.

RESPONSE: NOAA's proposal provides such restrictions.

COMMENT: The description of alternatives is unbalanced in favor of
altern ive 2. The description of alternative 4 should be expanded.
alternative 4 should be chosen.

RESPONSE: See generic response A.

MERCK & CO., INC: Richard Trabert - 1/30/80

COMMENT: Although the discussion in the DEIS indicated that the proposed
marine sanctuary would not regulate kelp harvesting, the draft designation
document and proposed regulations failed to exempt kelp harvesting.

RESPONSE: NOAA has made the recommended changes in the proposed final
regula ns and draft Designation, with one exception. Although the
regulations permit overflights to survey kelp beds, the Designation does
not rule out the possibility of regulating such overflights in the future,
should they pose a threat to the marine sanctuary resources. Overflights,
although the customary and probably most economical method of surveying kelp
beds, are not absolutely necessary to the harvesting of kelp, and could
cause considerable disturbance in sensitive wildlife habitat. Any change
in the initial regulations of overflights would be subject to the
Administrative Procedures Act and a 60 day comment period.

MORE MESA LAND TRUST: Dr. Larry Rickford 1/11/80

COMMENT: Alternative 4 will protect the larger ecosystem of the Islands
and the Channel.

RESPONSE: See generic response A.

G-66

NATIONAL ASSOCIATION OF UNDERWATER INSTRUCTORS: John Wenzel, Secretary
1/19/80

COMMENT: OCZM should clarify what is meant by historical resources.

RESPONSE: The Department of Fish and Game is conducting a management
study for NOAA. This issue will be addressed in that study.

COMMENT: OCZM should develop a graduated scale of penalties for
violating regulations.

RESPONSE: See previous response.

NATIONAL COALITION FOR MARINE CONSERVATION PACIFIC REGION: Herbert R. Kameon,
President - 12/12/79

COMMENT: There is no provision for the damage that may be done by fishing
gear such as bottom draggers to the nearshore bottom environment. The
damage that may be done by fishing gear perpetually being dragged over
the bottom can be very serious. Perhaps some mechanism can be built
into the program that sets up a cooperative consultive effort in conjunc-
tion with the work of the development of fishery plans for harvesting in
this area.

RESPONSE: NOAA, DFG and PFMC will cooperate and consult to assure that
t-Fe -programs regulating fishing and the sanctuary objectives remain
d-ompatible.

COMMENT: It is recommended that San Nicolas Island, Santa, Barbara
Island, San Clemente Island and the Tanner and Cortes Banks be considered
for marine sanctuary status.

RESPONSE: The waters around Santa Barbara Island are included in this
sanctuary proposal. Tanner and Cortes Banks and the waters around San
Nicolas Island are on NOAA's List of Recommended Areas for marine
sanctuary status. NOAA received a recommendation for the designation
of the waters around San Clemente Island as a marine sanctuary, but
does not have sufficient information to determine whether the area
meets NOAA's marine sanctuary criteria. NOAA welcomes additional
information on the appropriateness of these areas as marine sanctuary
candidates.

NATIONAL PARKS AND CONSERVATION ASSOCIATION: William C. Lienesch,
Administrative Assistant - 1/28/80

G-67

COMMENT: The Channel Islands and the waters surrounding them are a
magnificent national resource. The preferred alternative is definitely
a step in the right direction. However, it does not provide sufficient
protection in terms of the geographic area covered by the designation
or the control of the activities permitted within the proposed marine
sanctuary. Alternative 4, with some modification will provide additional
necessary protection without imposing unreasonable regulations on the
various activities occurring in the area. The larger boundary will
protect a larger area. Alternative 4 would make sea lanes mandatory,
reducing chances of accidents.

RESPONSE: See generic responses A and G.

COMMENT: Alternative four is deficient in that it does not provide enough
protection over seabed alterations. Seabed alterations should be prohibited
where such alterations will cause degradation. There are important and
sensitive areas outside the two mile zone around the islands which should
be protected.

RESPONSE: See the comparison with the preferred alternative in
Section F-3.

NETWORK: Phylis Mottda 1/11/80

COMMENT: NETWORK supports the statement by the Scenic Shoreline
Preservation Conference, and Alternative 4, with a twelve to fifteen
mile radius around the Islands.

RESPONSE: See generic responses A and the response to Scenic Shoreline
Preservation Conference's comments.

COMMENT: There should be a five-year moratorium on oil lease sales
in the Channel to catch up on leases currently being processed.

RESPONSE: See generic response D.

NORCAL GRAPHICS: Marke E. Gibson - 12/19/79

COMMENT: On page F-82, reference to Figure 17 should be changed to
Figure 13.

RESPONSE: Comment accepted.

G-68

COMMENT: The commenter does not know of any verified instances where
the sea otter has been sighted below Pt. Conception.

RESPONSE: Table E-3 cites NOAA's sources for its information on marine
Ta-mmals.

NATURAL RESOURCES DEFENSE COUNCIL: Trent W. Orr - 2/1/80

COMMENT: Overall, NRDC supports the designation of the Channel Islands
marine sanctuary.

RESPONSE: No response necessary.

COMMENT: Alternative 4 should be designated because the island resources
cannot be isolated from the integrated ecosystem that the Santa Barbara
Channel constitutes.
RESPONSE: See generic response A.

COMMENT: NRDC supports the prohibition of oil and gas development
pursuant to future leases in the sanctuary. Ideally, no oil and gas
activity should be permitted in the sanctuary on existing leases either.
NOAA could condemn and repurchase existing leases, or impose the
restrictions suggested in alternative 3, or combine those two approaches.

RESPONSE: See the comparison with the preferred alternative in
Section F-3.

COMMENT: Oil and gas development pursuant to future leases should be
prohibited throughout the Channel. Conservation and improvements in the
efficiency of energy use would be a saner approach to the'energy shortage
than the inexorable exploitation of every possible oil resource.

RESPONSE: See generic response D.

COMMENT: No oil and gas activities should be allowed in the VTSS.

RESPONSE: See generic response H.

COMMENT: Adherence to the VTSS should be mandatory.

RESPONSE: See generic response G.

COMMENT: The EIS should discuss the drawbacks and advantages of
pipelines as compared to banges and tankers.

G-69

RESPONSE: See Section F.2.c.l. NOAA feels that the case by case
review of pipeline permits by the California Coastal Commission and other
authorities provides currently sufficient consideration of the costs and
benefits of pipelines as compared to other methods of transporting oil
and gas. NOAA's proposed regulations would not restrict dredging or
other construction for laying pipelines beyond those restrictions imposed
by other agencies.

COMMENT: The DEIS should discuss the impact of the military's
activities in the area. Relocating certain practice exercises may not
jeopardize national defense.

RESPONSE: NOAA's proposed research and monitoring program (see Section F-2.b)
may be able to provide further information on the impacts of military
activities. once the sanctuary is designated this informationwill be
discussed with the authorities responsible for the exercises and any
necessary mitigation will be considered. Because the Southern California
Bight is a very heavily used area, movement of established military
exercises will require extensive consideration of impacts on these other
uses.

COMMENT: NRDC agrees with the decision not to regulate commercial
fishing or kelp harvesting, but hopes the sanctuary manager will communicate
with the agencies regulating fishing if concerns arise.

RESPONSE: This is consistent with NOAA's proposal. The close cooperation
with the California Department of Fish and Game will facilitate such
communication.

COMMENT: NRDC supports the proposed prohibition on construction and
alteration of the seabed within 2 nmi of the Islands. However, the impact
of construction and seabed alteration beyond 2 nmi should be considered,
and the blanket exemption for seabed alteration related to hydrocarbon
activities should be narrowed.

RSPONSE: The case by case review of seabed alteration and construction
activities provided by the California Coastal Commission's and the Corps
of Engineers review currently provides a sufficient level of protection
for the concentration of benthic resources beyond 2 nmi. NOAA removed
the exemption for hydrocarbon development related activities and now only
excludes the laying of pipelines and navigation aids from the proposed
regulation.

COMMENT: More information should be provided on the proposed management
plan.

RESPONSE: See generic response F.

G-70

PACIFIC COAST FEDERATION OF FISHERMEN'S ASSOCIATION, INC.: Zeke Grader,
General Manager - 1/22/80

COMMENT: The association is represented in the comments submitted by
9r. -Smith on behalf of the Commercial Fishermen of Santa Barbara.

RESPONSE: See response to comments by the Santa Barbara Commercial
Fishermen.

PACIFIC MERCHANT SHIPPING ASSOCIATION: Phillip Steinberg - 1/2/80

COMMENT: There is a need to preserve vessel traffic routes in order to
avoid collision or groundings.

RESPONSE: NOAA's revised designation document precludes regulation by
the sanctuary of vessel navigation within a designated VTSS or PAR. See
also generic response G.

COMMENT: The added layer of government is inadvisable. Vessel operations
and navigation should be left to the U. S. Coast Guard to avoid confusion
to the maritime user and needless duplication of government resources.

RESPONSE: See generic responses B, G, and H.

RECREATIONAL BOATING COUNSEL: George L. Fisher, Executive Director -

COMMENT: The Counsel is alarmed by the third layer of bureaucratic controls
on top of the State of California and county controls.

RESPONSE: See generic responses B and C.

RESOURCES PARTNERSHIP: Dr. Ruthann Corwin

COMMENT: The so-called "preferred alternative" represents protection
for the resources that is only greater in degree rather than in kind from
existing authorities.

RESPONSE: See Section F.2.b for a discussion of NOAA's management goals,
which are not parallelled by any existing authority.

G-71

COMMENT: The EIS does not adequately address itself to the long-term
cumulative impacts of human activities in the Santa Barbara Channel,
and therefore fails to explain the selection of the "preferred alternative"
over the other alternatives which provide much fuller protection for the
resources.

RESPONSE: See generic response A.

COMMENT: The most comprehensive protection is provided by alternative 4.
The reasons for its rejection.do not square with the facts regarding the
potential hazards to the resources.

RESPONSE: See generic response A.

COMMENT: The increase in tanker traffic and oil and gas recovery operation
in the Santa Barbara Channel area increases the chance of oil spills. Oil
spills do not respect sanctuary boundaries. The on-site oil spill contain-
ment equipment listed on page 90 will provide protection from only small
spills in calm weather. The EIS is deficient in describing the actual
effectiveness of this equipment.

RESPONSE: Section F-2.c.l. describes the effectiveness of oil spill
containment equipment. See generic response D and Section F-3 for a
discussion of why NOAA does not propose to prohibit oil and gas develop-
ment on a Channel wide basis.

COMMENT: The concept of coordinated management has a hollow ring as
applied to a six mile sanctuary area. If coordination is not provided
for a larger area, the sanctuary manager could be left guarding a
sanctuary whose resources have disappeared from causes external to
NOAA's management.

RESPONSE: See generic response A.

SANTA BARBARA AUDUBON SOCIETY: Toni Sollen 1/11/80

COMMENT: The sanctuary boundary should extend six miles around the
Islands and there should be no mineral exploitation within this
boundary.

RESPONSE: See Section F-3 of the HIS for a discussion of why NOAA proposes
to allow oil and gas activities on existing leases and seabed alteration
beyond 2 nmi from the Islands.

G-72

COMMENT: Alternative 4 is reasonable.

RESPONSE: See generic response A.

.SANTA BARBARA COMMERCIAL FISHERMEN: Thorn Smith - 1/18/80

COMMENT: Existing regulatory authority, divided among 11 Federal, 7

State, and many local agencies, is adequate to protect the area. The
Secretary of the Interior has taken steps to avoid adverse impacts
from oil development.

.RESPONSE: See generic response B.

COMMENT: NOAA promises to exempt fishing activities from sanctuary
regulations are not reliable, judging by experiences with other government
agencies. The California DF&G allowed the sea otter to destroy the Central
California abalone fishery, despite promises to the contrary. DOI promises,
that establishment of the National Monument on Santa Barbara and Ancapa
Islands would not interfere with commercial fishing, have been broken.
Judging by these cases, we lack faith in NOAA assurances.

.RESPONSE: NOAA's designation document excludes fishing from sanctuary
regulations and ensures that the marine sanctuary cannot exclude fishing
from sanctuary regulation and regulate fishing. In order to change this
exemption of fishing the designation process must be repeated, including
the distribution of EIS's, public hearings, Presidential approval and
gubernatorial concurrence as to regulations in State waters.

.COMMENT: We do not understand what the term "monitoring" means, as used
on page F 112 of the DEIS. Language in the DEIS about monitoring, research
and enforcement can lead to indirect management of living marine resources.

RESPONSE: Monitoring means observing over time. Thus, one of the
reponsibilities of the sanctuary manager will be to assemble information
on the heath and status of sanctuary resources over time. Data gathered
from monitoring will be available to DFG to utilize in its decision-
making on fishery issues.

COMMENT: The DEIS proposal to encourage and support "research" and
"'e-nforcement" might lead to further time and area closures, which
fishermen cannot afford.

G-73

RESPONSE: The marine sanctuary has exempted fishing from potential
sanctuary regulation and thus closures could not be legally instituted.
If existing authorities, including the Department of Fish and Game and
the Pacific Fishery Management Council, decide to close an area to
fishing because of information obtained by sanctuary-sponsored research
it will be in order to preserve the fishery in the long run, in accordance
with DFG's and PFMC's mandate. Likewise, if sanctuary funds augment
enforcement of regulations imposed by the existing authorities on
fishing, the improvement will be in the immediate interest of law-abiding
fishermen and in the long term interest of all who depend on the fishery.

COMMENT: A representative of commercial fishing interests should be
appointed to any board, commission or other authority given the
responsibility for administration of NOAA funds.

RESPONSE: See Section F-2-b- of the FEIS.

SANTA BARBARA MUSEUM OF NATURAL HISTORY: F. G. Hochberg, Curator and
Head, Department of Invertebrate Zoology - 1/11/80

COMMENT: The Transition Zone increases the number of species and
uniqueness of the.species in the area. There is a new species of
finned Octopod which is known to occur along the slopes of the
basin in the center of the Santa Barbara Channel. The new species of
colonial soft coral occurs only in the intertidal at Point Conception.

REPONSE: No response necessary.

COMMENT: The distribution of endemic plants and animals does not stop
at a distance of 6 miles from the Islands. In order to provide maximum
protection for these species, it seems only logical to set boundaries
which will encompass the entire range of these species. The sanctuary
should represent a natural biogeographic unit.

RESPONSE: See generic response A.

SANTA BARBARA MUSEUM OF NATURAL HISTORY: Charles D. Woodhouse, Jr.
Phd, Assistant DT-rector and Curator, Vertebrate Zoology - 1/10/80

COMMENT: The region is unique in a biological context and exhibits
characteristics which are not found elsewhere in the coastal waters of
of the United States.

RESPONSE: No response necessary.

G-74

COMMENT: The six mile perimeter around the Islands is not representative
of a natural biogeographic unit that would be consistent with the concept
of conserving the region's marine life.

RESPONSE: See generic response A.

COMMENT: The DEIS implies that the faunal assemblage is one of the major
reasons for establishing a sanctuary. The Island shorelines serve as important
habitat for resting or breeding marine birds and pinnipeds, and any sanctuary
should incorporate these area. However, cetaceans, pinnipeds, and marine
birds use the entire channel as well as the offshore banks and rocks to the
north and south of the northern Channel Islands as feeding and nursery grounds.
Gray whales, cows and calves, as well as female sea lions and their pups frequent
the area and do not appear to confine their activity to waters within six miles of
the islands. The sanctuary should include not only the islands but also the
upwelling area west of Point Conception and or the Santa Rose-Cortes Ridge - Santa
Cruz basin - Santa Cruz Ridge System to the south.

RESPONSE: See generic response A.

SCENIC SHORELINE PRESERVATION CONFERENCE: Fred Eissler - 1/11/80

COMMENT: The National Chapters of the Sierra Club, Friends of the Earth,
the National Wildlife Federation, the American Littoral Society, Funds
for Animals, Defenders of Wildlife, the Environmental Defense Fund,
Monitor International, Friends of Wildlife and the Society for Animal
Protection Legislation all endorse this comment.

RESPONSE: No response necessary.

COMMENT: The two theories in the DEIS are in conflict, i.e., that resources
are concentrated on the Islands and the Channel is an interrelated ecosystem.
Most data applies with greater cogency to the Channel as a whole. The DEIS
supports alternative 4.

RESPONSE: See generic response A.

COMMENT: A formal EIS should be completed on alternative 4 within sixty
days and a greater consideration be given to this alternative, which does
not delay the proposed action.

RESPONSE: Writing another DEIS would delay the proposed action by four
months at the very least. This EIS adequately addresses alternative 4.

G-75

COMMENT: Senator Rains substantially supports the Santa Barbara County
position.

RESPONSE: No response necessary.

SEA LAND SPORT FISHING AND SPORT FISHING ASSOCIATION OF CALIFORNIA: Fred Benko
f -/11 /80

COMMENT: Designation of the sanctuary will put another unnecesary
layer of management on ocean resources.

RESPONSE: See generic response B.

COMMENT: If there is going to be a sanctuary, alternative 4 should be chosen.

RESPONSE: See generic response A.

COMMENT: The oil platforms are valuable to the Channel fisheries and
beneficial. There is little evidence of oil damage, but a great danger
from oil tanker traffic. Tanker lanes should be moved outside of Channel.

RESPONSE: See generic response G. NOAAfinds that within 6 nmi of this
sensitive wildlife habitat, the risk of pollution and disturbance posed
by OCS development outweighs the the benefits of artificial reefs provided
by the platforms.

SEAWORLD: Barbara Hefferman - 1/9/80

COMMENT: The regulation of vessel traffic in the Channel Islands
marine sanctuary boundaries must be clarified.

RESPONSE: See generic response'C.

SIERRA CLUB: Ted Salzberg - 1/10/80

COMMENT: Alternative 4 should be chosen. A small sanctuary is insufficient,
considering the potential for damage from activities around the Islands.

RESPONSE: See generic response A.

G-76

SIERRA CLUB - SANTA MONICA MOUNTAINS TASK FORCE: Jo Kitz - 1/10/80

COMMENT: Alternative 4 should be approved with a slight alteration--
more of the tidelands on the mainland side should be included in the
Sanctuary.

RESPONSE: See generic response A.

COMMENT: The real impacts of human uses need to be assessed. If a moratorium
on certain uses is necessary until more information is available, this should
be done through the sanctuary, due to the significance of the resources.

RESPONSE: The EIS assessed the impacts of human activities and proposes
regulations to protect the resources.

SOUTHERN CALIFORNIA CRUISER ASSOCIATION: Thomas W. Collins 1/4/80

COMMENT: The association will be adversely affected by any proposed
restrictions to navigation in waters surrounding the Channel Islands.

RESPONSE: See generic response C.

COMMENT: The hearings are too far distant from areas where the operators
base their craft. Hearings should be held in Los Angeles and Long Beach.

RESPONSE: See generic response I.

SOUTHERN CALIFORNIA CRUISER ASSOCIATION: Jack West - 1/21/80

.COMMENT: Article 4 (Scope of Regulations) Section 1, sub-point d, published
in Vol. 44, No. 235 of the Federal Register, specifically states that
navigation and operation of vessels (other than fishing vessels) are
subject to regulation. We strenously object to this because it is an
encroachment on the responsibilities of the U.S. Coast Guard which takes
precedence over any other Federal agency with respect to vessel navigation
and operation.

RESPONSE: After consultation with the Coast Guard, NOAA has rewritten
the designation document to exempt navigation in, or within a 500 m buffer
on either side of, any Vessel Traffic Separation Scheme or Port Access
Route designated by the Coast Guard from any potential marine sanctuary
regulation, unless the VTSS or PAR or buffer zone is within 1 nmi of the
islands. NOAA regulations in the marine sanctuary therefore can not
conflict with these Coast Guard initiated controls on navigation.

G-77

Although the navigation and operation of vessels other than fishing
vessels would be subject to regulation, NOAA proposes only to regulate
the approach of vessels engaged in the trade of carrying cargo or servicing
offshore installations within one nautical mile of the Islands.

COMMENT: Article 6, point 2 (same issue of Federal register) states
T'lu-nnecessary operation of vessels or aircraft in the vicinity of important
habitats within 1 nmi of the Islands". We object to this on the grounds
that NOAA has no capability of deciding what is or is not necessary.
Only the master of a vessel has that right.

RESPONSE: In the Federal Register notice, the discussion of the proposed
regulations did refer to "unnecessary operation of vessels..." NOAA has
changed this language so that it is now clear that only vessels engaged
in the trade of carrying cargo or servicing offshore installations would
be prohibited from the waters within I nmi of the Islands. Furthermore,
Section 935.7 of the regulations states that activities necessary to
respond to an emergency threatening life, property, or the environment
are exempt from iregulation. In such an emergency, the master of any
affected vessel would thus have the right and responsibility to decide
what actions would be necessary unrestricted by sanctuary regulations.

COMMENT: Section 935.7, Point 3 (unnecessary operation of vessels and
aircrTft) published in the Register is ambiguous and contradictory. We
interpret it to say that only vessels engaged in transporting persons
or supplies to an Island can come within the I mile zone surrounding
an Island. We object to this prohibition because it is often necessary
to anchor close in-shore during storm conditions.

RESPONSE: See previous response.

COMMENT: Page C-8 of the Draft Environmental Impact Statement, discussing
vesseT-traffic, contradicts the statement in the Federal Register and
leaves unclear the right of certain vessels to.come within (closer than)
1 mile of an Island, for the same reason as stated in point #3 above.

RESPONSE: See previous response

COMMENT: Page F-59 of the Impact Statement, last paragraph, names five
activities that NOAA proposes to regulate. We object to NOAA having
anything to do with such activities because county, State and Federal
agencies now have regulations concerning them. There is no need whatsoever
for another layer of government to create regulations on these activities.

RESPONSE: See generic response B.

COMMENT: Page F-103, point 4, of the Impact Statement regarding operations
of vessels is ambiguous with respect to operation of vessels within 1
mile of an Island. Unless it is rewritten in clear understandable

G-78

English that says what classes of vessels can navigate within the 1 mile
boundary, we object to the entire concept of the Sanctuary.

RESPONSE: The regulation has been rewritten. See generic response C.

COMMENT: Page F-112, sub-point d (Management), would result in an entirely
Fe-wlayer of personnel to police and enforce the proposed regulations.
We object to the added cost to the public for a group of people empowered
to enforce the regulations because there already exists county, State or
Federal agencies capable of performing the same duties.

RESPONSE: See generic response B.

COMMENT: Inadequate notice of the public hearings was given to affected
\Fe-ssel operators, we demand that additional hearings be held in the Los
Angeles/Long Beach area.

RESPONSE: See generic response I.

SOUTHERN CALIFORNIA GAS: Spurgeon - 1/23/80

COMMENT: The DEIS does not justify the need for a sanctuary. Existing
regulation provides adequate protection for the area.

RESPONSE: See generic response B.

COMMENT: Better coordination among regulatory agencies is possible
without sanctuary establishment. The DEIS does not indicate how sanctuary
establishment would enhance enforcement.

RESPONSE: See generic responses B and F.

COMMENT: Any decision concerning the sanctuary should await the vote
on the pending Channel Islands National Park legislation.

RESPONSE: The marine sanctuary will complement the Channel Islands
Na-tional Park, which was signed into law in April 1980.

SOUTHERN CALIFORNIA PETROLEUM CONTINGENCY ORGANIZATION
ATLANTIC RICHFIELD COMPANY: Tack -Hundley - 1/10/80

COMMENT: Sanctuary proposals must meet the criteria in the Act - they
should be established where the need exists, based on firm scientific
evidence.

G-79

RESPONSE: This proposal meets the criteria in the Act and in the marine
sanctuary program's general regulations.

COMMENT: The proposal would withdraw 800,000 acres within an "oil
province" where hydrocarbons are known to exist. It is irresponsible to
withdraw this much area from oil and gas exploration and development.
The DEIS reference to oil spill clean up fails to discuss recommendations
for use of dispersents and protective measures, now accepted by agencies.

RESPONSE: The discussion of dispersants has been expanded in the HIS
(Section F.2.c.1). See generic response K.

SPORTSMEN'S COUNCIL OF CENTRAL CALIFORNIA: Stanley R. Radom - 12/4/79

COMMENT: The wording on page F-59 will have to be strengthened. The
words "NOAA proposes to subject only...," should be changed to "NOAA
will subject only..."

RESPONSE: The wording used reflects the fact that until such time as
designation occurs, the regulations analyzed in the EIS are proposed
rather than final.

COMMENT: Explain why the Central California Coastline was not considered
with equal weight with the Channel Islands. There are many who feel the
sanctuary designation is needed much more along the coastline than the
Channel Islands.

RESPONSE: Monterey Bay, which is also an active candidate for marine
sanctuary designation, is the only site on the Central California coastline
recommended to NOAA for marine sanctuary status. NOAA will review any
additional site recommendations submitted.

COMMENT: The environmental consequences portion of the DEIS is weak
and sketchy. It should show the significant adverse environmental
impacts that would result if the sanctuary is not designated.

RESPONSE: This section (Section F-l-c) has been rewritten to show more
clearly the environmental consequences of the current regulatory system.

COMMENT: There should be an explicit statement that persons and organizations
tF-atare best qualified on scientific and management bases will be used
to optimize long term benefits to the marine resources and the public.
Public input insofar as management of public submerged lands is also
an essential part.

G-80

RESPONSE: See generic response F and Section F.2-b.

COMMENT: Research zones or complete closures without scientific reasons
justifying such action would be adamantly opposed by sports fi�hermen
.and commercial fishermen.

RESPONSE: NOAA's preferred alternative does not include the designation
of research zones or fishing closures.

SPORTSMEN'S COUNCIL OF CENTRAL CALIFORNIA AND CALIFORNIA WILDLIFE FEDERATION:
Stanley R. Radom, Director of Public Lands Committee, and D gate on
Statewide Fisheries - 1/11/80

COMMENT: The Channel Islands marine resources are not@in jeopardy and
there is no justification for a new layer of Federal government. The
DEIS makes a good case for the status quo.

RESPONSE: See generic response B.

COMMENT: The DEIS downgrades the State' 's Department of Fish and Game
and the National Park Service because of limited patrol boats. If this
is a serious deficiency, Federal funds should be provided for boats and
personnel rather than creating a 1200 square mile sanctuary.

RESPONSE: NOAA will provide funds for enforcement in the proposed marine
sanctuary. However, the sanctuary will provide a variety of benefits in
addition to improved enforcement (see generic response B and Section F.2).

COMMENT: DEIS (p.F.111) language should be strengthened and clarified
to state: "Management of living marine resources will remain under the
jurisdiction of the California legislature and the California Fish and
Game Commission, with implementation and enforcement by the California
Department of Fish and Game. Regulations will be those adopted by the
California Fish and Game Commission under authority of the California
Fish and Game Code, Title 14 of the California Administrative Code, and
California Penal Code."

RESPONSE: NOAA clearly and repeatedly states that the marine sanctuary
will not regulate fishing. It does not seem appropriate for NOAA to
dictate which exact State authorities will regulate fishing, since the
State may modify its system in the future.

G-81

STAUFFER CHEMICAL COMPANY: Bela Szelenyi - 1/31/80

COMMENT: Kelp harvesting should be specifically mentioned in the DEIS
and the regulations as an allowed activity, and the Draft Designation
Document and proposed regulations should be changed accordingly.

RESPONSE: NOAA has rewritten the draft Designation and final proposed
regulations to allow kelp harvesting activities.

TEXACO, INC: William K. Tell, Jr. - 1/21/80

COMMENT: The Secretary of Commerce's determination to designate a marine
sanctuary must, by 16 U.S.C. 1432, be a decision of necessity - nothing
less. Designation proposals must show clearly that 7-e 'recited values
are not and cannot otherwise be protected, and in that event, the sites
must be limited and specific. The Channel Islands DEIS does neither.

RESPONSE: Title III of the Marine Protection, Research and Sanctuaries
Tct -states that the Secretary may designate as marine sanctuaries those
areas which he determines necessary to preserve or restore their ecological
conservation, recreational, or esthetic values. The Act does not demand
that he prove the sites could not conceivably be protected otherwise.
Research, monitoring, assessment, education, and long term planning are
necessary to preserve the extraordinary ecological and other values of this
area (See Section F.I.c). Marine sanctuary designation will provide these.

COMMENT: The proposed sanctuary and its regulations are primarily designed
to restrain oil and gas operations. However, the California Legislature
has already established oil and gas sanctuaries out to 3 nmi of the northern
Channel Islands, and operations continue to be excluded there. Data from
the EIS for OCS Sale No. 48, prepared a year or so ago by the Department
of the Interior, indicates that practically all of the marine birds,
mammals and endangered species sought to be protected by NOAA are in
fact within the 3 nmi State protective limits.

RESPONSE: There is no oil and gas sanctuary around Santa Barbara Island.
Furthermore, the State oil and gas sanctuaries may be subject to leasing
if petroleum extraction from leases on the Federal OCS threatens to
drain State resources. Thus, it is important that no hydrocarbon development
occurs immediately outside State waters in order to maintain the integrity
of the State's oil and gas sanctuaries.

The main breeding and nesting habitat of the marine birds and mammals
in the area is within 3 nmi of the Islands and on the Islands themselves.
However, key foraging areas extend at least to 6 nmi and, in addition,
a buffer zone is needed between potentially threatening activities and
the sensitive nearshore habitat zones.

G-82

COMMENT: The DEIS and the proposed regulations will cause an undetermined
quantity of oil and gas reserves to be sacrificed.

There is no merit whatsoever in NOAA's contention that the sanctuary
reserves will be "preserved for future use." Such a statement runs
counter to the statutory requirements for designating marine sanctuaries.
If the Section 302(a) necessity can in fact be determined now, it cannot,
under the Act, ever dissipate.

The issue is simple. Shall this extremely important oil and gas area
be available for development or not? The DEIS and the proposed regulations
would clearly result in an increase in U.S. imports of OPEC oil rather
than allowing development to proceed in th 'e Channel Islands area under
the multitude of protective regulations already in place. -

RESPONSE: The hydrocarbon resources in the proposed sanctuary will not
be destroyed by the action under review, therefore, they could be available
for extraction in the future if technology improves and needs increase.
There is no statutory provision prohibiting modification of sanctuary
regulations if conditions are significantly altered. In addition, there
has been no showing that the resources within the proposed sanctuary
are extremely important.

COMMENT: In all, there are eleven Federal, seven State and a multitude
of regi nal and local government agencies vested with regulatory authority
in the area. There are no serious gaps in the existing protective
network, and there is no indication that any of the agencies are failing
to meet their responsibilities. Another layer of regulatory authority,
vesting powers in a superagency to override others, is not warranted.
It is altogether improper to suggest that total withdrawal is needed
because existing controls are not centrally coordinated. To do so is
to suggest that all functional and jurisdictional rulemaking is useless
in public administration.

RESPONSE: See generic response B.

UNIVERSITY OF CALIFORNIA - IRVINE: School of Biological Sciences -
George L. Hunt, Jr. - 1/23/80

COMMENT: The Channel Islands are not only of great scenic and recreational
value, but they also support a large and varied fauna and flora. A
marine sanctuary for the northern Channel Islands and Santa Barbara
Island would aid in the protection of marine mammals and birds.

RESPONSE: No response necessary.

G-83

UNIVERSITY OF CALIFORNIA - SANTA CRUZ: Burney J. LeBoeuf, Professor of
Biology

COMMENT: The Channel Islands are a unique'biological resource extending
the sanctuary six nautical miles seaward from the mean hi' h watermark
9
of the Islands. Alternative 2 is recommended.-

RESPONSE: No response necessary.

VENTURA COLLEGE:', Bill. Muller 1/11/86

COMMENT: The implication that the State of California and its agencies
cannot protect and manage thes e natural i6sour'c'es..is objectionable.
RESPONSE: @tee generic res'onse'B.,
p

COMMENT: The DEIS has not demonstrated the need for additional supervision
in the Islands. There is already sufficient regulatory protection.

RESPONSE: See generic response B.

VENTURA COLLEGE: John Tallman '1/11/80

COMMENT: An enormous amount of monpy,has been wasted on the report
which is grossly inadequate, fu,l.l of'errors.and outdated.

RESPONSE: In the absence of more specific criticisms, NOAA cannot
respond to,thi.s comment.,

COMMENT: The DEIS'is biased for the proposed alternative.

RESPONSE: Based on NOAA's analysis, the preferred alternative appears
to be the best option.

COMMENT: There is nothing in the DEIS that justifies the need for a
sanctuary.

RESPONSE: See generic response B.

COMMENT: The Coast Guard, the Rangers and the State Fisheries do an
outstanding job of regulating this area. There is no need for further
coordination.

G-84@

RESPONSE: See generic response B.

COMMENT: The DEIS has too much emphasis on regulation of oil interests.
It is an attempt to restrict oil development under the guise of a sanctuary.
Oil development and fishery resources are compatible.

RESPONSE: See generic response E.

VENTURA COLLEGE WELL CONTROL SCHOOL AND THE INTERNATIONAL ASSOCIATION-
OF DRILLING CONTRACTORS: Peter R. Wygle - 1/11/80

COMMENT: Charges by GOO, the Sierra Club and Friends of the Santa Monica
Mountains of "proven ecological damage" from oil activity are unsubstantiated.
General studies have been made showing examples of positive or neutral
effects of oil development on the marine environment.

RESPONSE: See generic response E.

COMMENT: Onshore oil resources are not sufficient. OCS resources must
be developed. No company would undertake increased risks and costs
offshore, if onshore resources were available.

RESPONSE: OCS resource development must be weighed against environmental
@Fa-lues. In this case, NOAA proposes that currently the latter outweigh
the former (see Section F-2-C-1).

COMMENT: Forcing directional drilling by denying access to a site
courts ecological disaster. The danger of hole trouble increases with
the distance from drilling site.

RESPONSE: Directional drilling is standard practice by industry although
it does appear that at a certain distance technological problems and
time onsite may increase. NOAA's regulations may increase the distance
through which drilling is required, if any commercially exploitable
resources are to be reached from outside the sanctuary. At this time,
there appears to be very little industry interest in these unleased
tracts within the proposed sanctuary and the likely increase in required
slant drilling is minimal.

VENTURA YACHT CLUB: George Jarvis 1/10/80

COMMENT: The implied restrictions to recreational boating in the
sanctuary are not acceptable.

G-85

RESPONSE: See generic response C.

COMMENT: Is $50,000 adequate to enforce the sanctuary?

RESPONSE: See generic response F.

WESTERN OIL AND GAS ASSOCIATION: Ed Taaffe - 1/11/80

COMMENT: The DEIS does not quantify the size of the various alternatives.
The preferred Alternative would enclose approximately 1,130 square nautical
miles or 959,000 acres. It is not the intent of Congress to remove
vast ocean areas from commerce.

RESPONSE: The preferred alternative encompasses 1252.5 square nautical
miles. This area is not excessive to protect the sensitive marine
resources of the nearshore waters around the northern Channel Islands
and Santa Barbara Island. Neither Title III of the Marine Research,
Protection and Sanctuaries Act nor its legislative history indicate
this area is inappropriately large for sanctuary status. Finally,
,though certain uses of the proposed sanctuary are restricted, commercial
fishing, recreation, and commercial shipping are allowed either throughout
or in most of the proposed sanctuary.

COMMENT: There is no demonstrated need for the sanctuary, especially
one as large as proposed. Congressman Breaux has indicated Congressional
intent that sanctuaries should be in relatively small areas.

RESPONSE: See generic response B.

COMMENT: Proposed contingency measures for oil spills are unnecessary
and redundant, since they are already enforced on drilling operations
in the Channel.

RESPONSE: The onsite oilspill containment requirements exceed those
imposed-by the Department of the Interior. The California Coastal
Commission has through its consistency certification required the
same onsite equipment on several tracts. NOAA finds that given the
sensitivity and importance of Island resources and the distance from
the oil spill cooperatives (Clean Seas and SCPCO) on the mainland, all
the tracts in the proposed sanctuary warrent that extra onsite contingency
equipment.

COMMENT: DEIS fails to follow Title III of the Act, NEPA and CEQ guidelines.
The format of the DEIS and published regulations suggest that NOAA has

G-86

already decided on the proposed action. Regulations should not be
prepared prior to the completion of the NEPA process.

RESPONSE: See response to.Chevron's fifth comment.

COMMENT: The proposal does not adequately consider the national interest
as it applies to the development of energy supplies. The de facto withdrawal
of lands from leasing by NOAA, contradicts the intent of the OCS Lands Act.

RESPONSE: See the response to the first comment by the Department of
7n-e r -gy

COMMENT: Archaeological sites are already protected by the Department
Ff -the Interior requirements for drilling activities.

RESPONSE: DOI's lease stipulations only protect historical resources
from OTT activities. NOAA's proposed regulation will provide protection
from private collecting or damage.

COMMENT: The DEIS fails to incorporate WOGA's earlier suggestions of
D-une7 and June 8, 1979.

RESPONSE: NOAA took the comments received at the June 7 and June 8
public meetings into consideration in the preparation of the DEIS.

COMMENT: The rationale for allowing continuation of existing oil and
gas operations, while prohibiting new operations or leases after the
date of the sanctuary does not make sense. WOGA objects to these
prohibitions.

RESPONSE: See the response to the third comment by the American Petroleum
rn-stitute.

COMMENT: The DEIS should quantify threats from increased pressure of
Fu-man activities and recognize the decrease in tanker traffic incident
to the proposed construction of the Northern Tier Pipeline and the
study of the Santa Barbara pipeline.

RESPONSE: NOAA has attempted to quantify the threats from human activity
wherever possible. The proposed construction of the Northern Tier
pipeline is discussed in Section E.3.

COMMENT: With the exception of oil and gas operations, there is virtually
no difference between the "preferred alternative" of the DEIS and the
status quo. The existing authorities and agencies are fully sufficient

G-87

to protect the proposed sanctuary. Additional funding and personnel
should be provided, if needed, without another costly regulatory regime.

RESPONSE: See generic response B.

COMMENT: WOGA is not opposed to sanctuaries, provided they meet the
criteria of Title 111, i.e., a definite need is established and they
encompass only the areas necessary to satisfy the need. The Channel
Islands proposal fails to meet these standards.

RESPONSE: This proposal fulfills the criteria both of Title III of
the Marine Protection, Research, and Sanctuaries Act and of-the general
regulations of the marine sanctuaries program.

COMMENT: There is no demonstrated need for the sanctuary, especially
one as @arge as proposed. Congressman Breaux has indicated Congressional
intent that sanctuaries should be in relatively small areas.

RESPONSE: See generic response B. Congress has not established any
size limits for marine sanctuaries. The sanctuary is as small as
possible for providing protection to sanctuary resources. See also
.comment by Congressman Beilenson.

WESTERN OIL AND GAS ASSOCIATION: Mertens 1/10/80, 1/11/80

COMMENT: The failure of the DEIS to discuss Santa Barbara Channel
offshore platforms in any detail neglects the documented beneficial
effects of these platforms. Further, the fact that platforms function
as an artificial reef is not acknowledged and is therefore denied to
decisionmakers concerned with this proposed marine sanctuary.

RESPONSE: The role of offshore platforms as artificial reef has been
addressed in the FEIS. See also generic response E.

COMMENT: The DEIS study of oil spill 'trasectories (pp. F-77 to F-85)
assumes that oil is a complete inert material and undergoes no change
once it is spilled. This assumption does@not take into account evaporation
and weathering, nor the natural dispersion that occurs. Both of these
are extremely important mitigating phenomena.

RESPONSE: The effect of evaporation, weathering, and natural dispersion
on spill-ed oil was an important factor in NOAA's analysis and choice of
the preferred alternative. See Section F..2-c-l-

G-88

COMMENT: Throughout section F of the DEIS, the author(s) assert that
the presence of oil in ocean iwaters is deleterious to marine I.ife.
However., Straughan (7) who conducted-an extensive three-year study
of the sublethal effects on marine life of natural chronic exposure
of oil in the Santa Barbara Channel, concluded that:

(1) There was no evidence that exposure to the natural oil
seepage affects the growth rate-of t.he marine organisma.
(2) No change in total bi-omass or in bio.mass'of ma Jor groups
could be related to the presence of hydrocarbons in.
sediments; and

(3)@ Given the en.vironmenta.1 factors present in the . area,
all species that she expected'..to be-An the .area are
indeed present.

Thus, the author(s) of the DEIS have-failed to acknowledgethe heavy
influx of@oil from seepage into the Santa Barbara Channel, some of
which is even within the confines of the proposed sanctuary.. Nor
do they acknowledge that despite this heavy influx, the area is rich
and varied.in marine li.fe.,.Thi,s evidence strongly suggests that offshore
operations would-have-minimal, if any, adverse effect upon the local
marine life...

RESPONSE: The discussion of oil seepage has been expanded in Sec,tion
F.2.-c-.1 of the FEIS. See also generic response E.

WHALE CENTER: Maxine McCloskey, Executive Director 2/1/80

COMMENT:. This area is important to several populations.of whales and.
dolphins. It is the home.range for.several local dolphin populations,
the seasonal feeding, gr'ounds for,pilot whales,and is al.so of'great
importance to several endangered whales. At various times of the year,
the right whale, blue whale,fin whale, humpback whale and the California
gray whale are found around the Channel-Isl.ands. The 'disruption of the.
ecology of this area will have detrimental effects throughout these whale
populations and the Channel Islands in general. For these reasons,
Alternative 4 would be the most effective, and desirable.. This
would place a 12 nautical bile,boun 'dary around the sanctuary and add
an extra safety zone to cusion the effects of oil mining,' an oil spill,
and other intrusions.

RESPONSE: See generic response A.

G-89

F.E. BERNSTEIN - 1/13/80

COMMENT: She supports the establishment of the marine sanctuary. The
larger the sanctuary, the better protection it will provide.

RESPONSE: See generic response A.

ATLEE CLAPP - 1/11 /80

COMMENT: Sanctuary status for the Channel will help coordinate the
many activities taking place.

RESPONSE: No response necessary.

COMMENT: No oil.activity should be permitted within six miles of the Islands.

RESPONSE: See Section F-3.

COMMENT: Alternative 4 should be considered.

RESPONSE: Alternative 4 was considered. See generic response A and Section F-4
Tor a-discussion of the basis for choosing alternative 2 over alternative 4.

AL EBLING - 1/11/80

COMMENT: The Channel needs a sanctuary larger than the proposal,
if it n eds one at all. The health of the kelp bed community depends
on the mid-Channel planktonic communities. They cannot be separated.
The behavior of water flows and currents supports a Channel-wide sanctuary
boundary. The Channel waters present an ideal area for research.

RESPONSE: See generic responses A and B.

TED FLESHER - 1/10/80

COMMENT: The sanctuary should not be designated because of the potential
that boating regulations will be added in the future.

RESPONSE: See the response to the second comment by the California
7
Marine arks and Harbors Association.

G-90

CLARA ANN FOLK - 1/17/80

COMMENT: The proposed sanctuary area is where much of the world's marine
mammal-life lives, plays or passes through. We humans must be able to
drill for oil, build factories, and discharge materials somewhere else
than in this unique area.

RESPONSE: The proposed sanctuary prohibits oil and gas development
pursuant to future leases, construction within 2 nmi of the Islands,
and discharges.

PETER GROSS - 1/11/80

COMMENT: Energy conservation, solar heating, wind and biomass energy
will supply more energy, faster, more economically and with less destruction
than expanded production of fossil fuel.

RESPONSE: NOAA supports greater reliance on energy conservation and
alternative energy sources than fossil fuels, but the marine sanctuary
program cannot direct the nation's energy policy.

COMMENT: A marine sanctuary can be provided to protect the entire
Channer without sacrificing other things.

RESPONSE: See generic response A.

COMMENT: Alternative 4 will provide minimal protection, an indefinite
moratorium on lease sales for more drilling in the Channel, and a five-
year moratorium on licensing a LNG terminal at Point Conception.

RESPONSE: NOAA considered a moratorium provision in its review of
alternative 4 but did not include a leasing moratorium or a moratorium
on the licensing of a LNG plant in this version of a sanctuary. See
Section F-4 and generic response D.

RICK HAMNER AND ASSOCIATES: Rick Hamner - 1/23/80

COMMENT: The,scope of the regulations appears to allow future control
of small boat navigation, anchorage and Island access and other activities
without any additional local input or involvement.

RESPONSE: See generic response C. Any change in marine sanctuary
regulations must be proposed under the Administrative Procedure Act and
subjected to public review and a 60 day comment period.

G-91

COMMENT: The added layers of remote Federal government regulations are
objec nable; less government, more local in better touch with the
community, is appropriate.

RESPONSE: See generic response B. The sanctuary mana ger will consult
and coordinate closely with State and local agencies-and members of the
community. See Section F.2-b of the FEIS.

MR. & MRS. JOHN' D. HARMS, Carmel, CA. - 1/14/80

COMMENT:. They supportidea of the proposed ChanneT.Islands Marine Sanctuary
which uld extend six miles out. These important 'wildlife areas are
seriously endangered by the prospect of offshore oil drilling and other
human activities. If the waters surrounding these northern Channel Islands
are designated as a marine sanctuary it would give national recognition
to the natural values involved. The regulations that would follow would
reduce adverse environmental impacts. These regulations must be stringent.

RESPONSE: The marine sanctuary boundaries and regulations proposed by
NOAA are designed to protect the natural resources of this important
area, taking into account the level of economic impact.

COMMENT: The California brown.pelican, which nests on Anacapa, would
benefit from sanctuary designation.,

RESPONSE:. No response necessary.,

MYRNVLEFFERTS Simi Valley, CA.

COMMENT: The sanctuary, if established, will help reduce adverse
environmental impacts, especially from gas and oil activities.

RESPONSE: No response necessary.

PHILIP R. LEVER 1/13/80

COMMENT: He endorses the sanctuary. It should have extended boundarie's
and tougher regulations.

RESPONSE: See gener-ic responses A and.E and.Section F.3.

G-92

HELEN MATELSON - 1/14/80

COMMENT: The waters of the Santa Barbara Channel Islands must be saved
T-ro-m-oTfshore drilling.

RESPONSE: See generic response D.

ADAM C. McOUAT - 1/23/80

COMMENT: There are approximately ten thousand members of the boating
puST-icon the west coast, between Santa Barbara and San Diego who use
the Channel Islands as their only source of cruising activities. This
would leave the boating public with Catalina Island as the sole source
of cruising. Please realize what you are doing to the largest recreational
group on the Pacific coast.

RESPONSE: See generic response C.

JOHN MORGAN - 1/10/80

COMMENT: Oil companies have misrepresented the damage that has taken
place d e to oil development in the Channel, especially in Mussel Shoals.
Mussels have been eliminated by oil activity. Much of the oil damage
is due to pollution from water separated from oil and put back into the
water.

RESPONSE: The proposed regulations would prohibit oil and gas development
pursuant to future leases in the sanctuary. Section F-2.c.1 and generic
response E discuss the possible effects of oil and gas development.

TIMOTHY M. MURPHY AND 30 FRIENDS - 1/28/80

COMMENT: Mr. Murphy and 30 friends signed a letter supporting the proposed
sanctuary. They feel that only with national status will this vital
marine environment be protected.

RESPONSE: No response necessary.

COMMENT: The following activities within the sa nctuary should be closely
monitored: oil and gas operations, dumping, alteration of or construction
on the seabed, navigation and overflights less than 1,000 feet.

G-93

RESPONSE: All the above listed activities would be subject to the proposed
marine sanctuary regulations.

SCOTT T. OLSON - 12/18/79

COMMENT: He wholeheartedly supports the proposed sanctuary. Regulations
regarding any commercial exploration of resources should be very stringent.
Preservation and protection of the unique and fragile biota of the Channel
Islands area is important.

RESPONSE: No response necessary.

CHRISTOPHER P. ONUF - 1/11/80

COMMENT: DEIS ma"kes a compelling case for sanctuary status, but alternative 2
does n6l provide the scope needed for management. The mainland side is also
rich in kelp bed and wildlife resources and, therefore, should be included.
The proposal should include important coastal wetlands on the mainland
side, i.e., Mugu Lagoon, Carpenteria Marsh and Goleta Slough and smaller
areas. Alternative 4 boundaries more accurately define the area where
resources apply. This alternative should be approved.

RESPONSE: See generic response A.

COMMENT: Regulations of discharges into Channel and of oil and gas
activiTies are in the best interest of the commercial fishing industry.
Figure E.20 (p. E.71) shows that the most heavily fished areas are close
to the mainland shore rather than near the Islands. Protection of
commercial fisheries is a legitimate objective of a sanctuary program,
but alternative 2 would not apply to the most heavily fished areas.

RESPONSE: See generic response A.

WILLIAM RUBIN - 1/11/80

COMMENT: The entire Channel needs the protection the sanctuary provides.
The sanctuary would not interfere with the management responsibilities
of other agencies but is complementary and supportive of single purpose
agencies.

RESPONSE: See generic response A.

G-94

COMMENT: Oil development is only the beginning of mining, mariculture
and other ocean developments. The sanctuary brings balance between resource
development and marine habitat protection.

RESPONSE: No response necessary.

RICHARD SPOTTS - 1/21/80

COMMENT: The Channel Islands and surrounding waters possess significant
and unique values. It is clear that these values are threatened by
the cumulative increase of human developmental activities in these areas.
Strict regulations and generous sanctuary boundaries are necessary.

RESPONSE: No response necessary.

MRS. J.R. STALLINGS, Cheyenne, WY - 1/17/80

COMMENT: The waters surrounding the Channel Islands possess significant
wildlife values which are jeopardized by the cumulative increase of human
development activities. The sanctuary will protect this area.

RESPONSE: No response necessary.

DYANNE TABIN AND FAMILY - 1/11/80

COMMENT: The waters surrounding the Channel Islands have important
and vital wildlife values that are clearly jeopardized by the cumulative
increase of human developmental activities in the area (such as offshore
drilling).

RESPONSE: No response necessary.

COMMENT: We need stronger regulations and extended boundaries.

RESPONSE: See generic responses A and E and Section F.3.

G-95

GARY VESPERMAN, San Mateo, CA - 1/18/80

COMMENT: The benefits of preserving important resources should far
outweigh any other costs. Alternative 2 is acceptable. The loss of
the hydrocarbon resources to future generations looks like a very
acceptable cost to our generation.

RESPONSE: No response necessary.

EDWARD AND SARAH ZAWASKI - 1/17/80

COMMENT: The proposed Channel Islands marine sanctuary should be designated.

RESPONSE: No response necessary.

G-96

H. Literature and Personal Communications Cited

a. References

Allen, A. A. 1969. Santa Barbara Oil Spill. Statement presented
U.S. Senate Interior Committee Subcommittee on Minerals,
Materials, and Fuels. 11 p.

American Petroleum Institute. 1978. Oil and Gas Well Drilling
Fluid Chemicals. American Petroleum Institute. Washington,
D.C. API Bul . 13F. 9 p.

Anderson, E K. and W. J. North.. 1967. In situ studies of spore
p@oduction and'dispersal in the-g'i'an-E-kelp, Macrocystis.
In Proceedings: International Seaweed Symposium (Editors,
E. G. Young and J.L. McLachlan). Pergamon Press, New York.
5:73-86 (424 p).

Anderson, E.K. and I.T. Anderson. 1976. Distribution and Status of
Brown Pelicans in the California Current. American Birds,
30(l):3-12.

Anderson, E.K., L.G. Jones, and C.T. Mitchell. 1969 Evaluation of
ecological effects of liberated oil in the Santa Barbara
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H-1

California Coastal Commission (CCC), 1978. Consistency Certification
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California Coastal Commission (CCC), 1979a. Consistency Certification
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California Coastal Commission (CCC), 1979b. Coastal News. Vol. 2,
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California Coastal Commission (CCC), 1980. Consistency Certification
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California Coastal Zone Conservation Commission, 1975. California
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Californfa Department of Fish and Game (DFG), 1976. Coastal County
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California Department of Fish and Game (DFG), 1979. Preliminary
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California Department of Fish and Game (DFG), In Process. Atlas
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California Department of Fish and Game and Department of Commerce,
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California Fish and Game Commission, 1978. Orders, rules, and
regulations for 1978: Title 14 - Natural Resources;
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California Office of Planning and Research, 1977. Offshore oil
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II. Prepared by OCS Task Force.

K-2

California Department of Parks and Recreation (DPR), 1974. Cal i fo rni a
Outdoor Recreation Resources Pl an.

California Department of Parks and Recreation (DPR), 1979. State
Parks System, Underwater Parks Master Plan (preliminary).
January, 1979. 69 p.

California State Water Resources Control Board, 1976. Areas of
Special Biological Significance.

California Water Resources Control Board, Annual Report, 1978.

California State Water Resources Control Board. 1978. Water
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Cherny, J.J., et. al., 1978. Marine Traffic Data of Southern
I
CaliTornia, Prepared for U.S. Dept. of Transportation,
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Chevron, 1978. Environmental Report for Tracts 204, 208, and 209.

Clark,, J. and C. Terrell, 1978. Environmental planning for off-
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H-3

Daugherty, A.E. 1965. Marine Mammals of California 1972 Revision.
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Dewling, R.T. and C.E. Silva. 1979. Impact of Dispersant Use During
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ECOMAR. 1978. Tanner Bank Mud and Cuttings Stude. Prepared for
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Ehorn, W. 1978. Public Workshop Comment. Proceedings of Public
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Evans., W.E. 1975. Distribution, Differentiation of Populations,
and other Aspects of the Natural History of Delphinus
delphis Linnaeus in the Northeastern Pacific. Ph. D.
Dissertation.

H-4

Executive Order 6896. 1934. Office of the President of the United
States.

Fairchild, E.J., R.L. Lewis, and R.L. Tatkin. 1977. The Registry
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Federal Register, Volume 44, Number 177. September 11, 1979.
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Fitch, J.E. 1960. Offshore Fishes of California. State of
California,'Department of Fish and Game. 79 p.

Gresst F. et. al. 1973. Reproductive Failure of Double Crested
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Wilson Bulletin 85: 197-208.

Hanshew, R. 1970. California Coastline Recreation Tip No. 2,
September, 1970. State of California, Department of
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Hedgpeth, Joel W. 1957. "Marine Biogeography" in Treatise on
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of America. Memoir 67. The Geological Society of
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Horn, M.M. 1974. Fishes of Southern California: A Literature
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Hyland, J.L., 1977. A review of oil polluting incidents in and
around New England. U.S. Environmental Protection Agency,
Ecological Research Series--EPA-600/3-77-064. 35 pp.

Jones, G.F. and K. Fauc hauld. 1977. Benthic Macrofauna. Bureau
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Vol. III, Sec. 2.4:412 p.

Leighton, D.L., L.G. Jones, and W.J. North. 1967. Ecological
Relationships between Giant Kelp and Sea Urchins in
Southern California. In Proceedings: International
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McLachlan). Pergamon Press, New York. 5:141-153
(424 p.).

H-5

McMullen, John J. Associates, 1977. Environmental Impact Report
for Point Conception LNG Import Terminal-Draft Vessel
Traffic Analyses. Prepared for California Utilities
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Miller, D.J. and R.N. Lea. 1972. Guide to the Coastal Marine
Fishes of California. State of California, The Resources
Agency, Department of Fish and Game, Fish Bulletin 157:
1-235.

National Academy of Sciences. 1975. Petroleum in the Marine
Environment. Washington, D.C.

National Marine Fisheries Service. 1978. The Marine Protection
Act of 1972 Annual Report. U.S. Department of Commerce.
National Oceanic and Atmospheric Administration. U.S..
Government Printing Office. GPO #0-261-238/190.
Washington, D.C. 183 p.

National Oceanic and Atmospheric Administration. 1979. Georges
Bank Marine Sanctuary Is.sue Paper. Office of Coastal Zone
Management. Washington, D.C. July 27, 1979.

Neal , M.J.' and P.E. Sorenson. 1970. The Economic Cost of the
Santa Barbara Oil Spill in Santa Barbara Oil Spill
Symposium, Offshore Production, An Environmental
Inquiry - December 16-18, 1970. UX. Santa Barbara.
Sponsored by NSF and the Marine Science Institute. UCSB.

Nelson-Smith, A. 1973. Oil Pollution and Marine Ecology, Chapter
F: Birds and Mammals. Plenum Press, New York. 260 p.

Neushul, M. and F.T. Haxo. 1968. The Life History of Macrocystis
in the Sea. In Utilization of Kelp-bed Resources in
Southern CaliTo-rnia (Editors, W.J. North and C.L. Hubbs).
State of California, The Resources Agency, Department
of Fish and Game, Fish Bulletin No. 139:13-15.

New England River Basins Commission (NERBC), 1976. Onshore
facilities related to offshore oil and gas development.
Boston, Mass.

Nickerson, R. 1977. Brother Whale. Chronicle Books, San
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NDrth, W.J. and C.L. Hubbs (Editors). 1968. Utilization of Kelp-
bed Resources in Southern California. State of California,
The Resources Agency, Department of Fish and Game, Fish
Bulletin No. 139, 264 p.

H-6

Offshore Operators Committee. 1978. Comments on EPA Draft Document
"Permit Conditions for NPDES Permits at the Flowee Garden
Reefs, Gulf, of Mexico.' OCS - August, 1978."

Oil and Gas Journal. 1979a. Vol. 77, No. 28, July 9, 1579,
pp. 48-50.

Oil and Gas Journal. 1979b.. Vol. 77, No. 43, October 28, 1979,
pp. 30-1.

Otteman, L.G. 1976. Letter commenting on EIS for BLM OCS Sale
No. 44 to New Orleans OCS Office. Bureau of Land
Management.

Pacific Fishery Management Council. 1978a. Final Environmental
Impact Statement and Fishery Management Plan for the
Northern Anchovy Fishery. Prepared by the Pacific
Council and NMPS, Terminal Island, CA. 131 p. plus
appendices.

Pacific Fishery Management Council. 1978b. Draft Environmental
Impact Statement and Fishery Management Plan for the
California, Oregon and Washington Groundfish Fishery.
Prepared by the Pacific Council and NMFS, Seattle,
WA. 165 p.

Pacific Fishery Management Council. 1979. Draft Fishery
Management Plan for the Jack Mackerel Fishery.
Prepared by the Pacific Council and NMFS, Terminal
Island, CA. 90 p.

Pearse, J.S., M.E. Clark, D.L. Leighton, C.T. Mitchell and W.J.
North. 1970. Marine Waste Disposal and Sea Urchin
Ecology. Appendix to: Kelp Habitat Improvement Project,
Annual Report, 1969-70, pp. 1-87. Ed. by W.J. North,
Pasadena, CA. California Institute of Technology.

Pfeiffer, Colonel Robert M. 1979. Letter to Center for Natural
Areas Concerning Marine Sanctuaries in California. U.S.
Air Force, The Joint Chiefs of Staff. Washington, D.C.

Pirie, O.M., M.J. Murphy and J.R. Edimisten. 1974. California
Nearshore Surface Currents. Proceedings, NASA Earth
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Vol. 2-B, pp. 195-216.

H-7

Quast, J.C. 1968. Fish Fauna of the Rocky Inshore Zone. In
Utilization of Kelp-Bed Resources in Southern California.
Fish Bulletin 139. Edited by W.J. North and C.L. Hubbs.
California Department of Fish and Game. Sacramento,
California. pp. @5-55..

Reeves, R.R. 1977. The Problem of Gray Whale (Eschrichtus
robustus) Harassment: At the Breeding Lagoons and
Uu_rTin_g_1Wi g ration. Marine Mammal Commission, Report
No. MMC-76/06. Washington, D.C. 60 p.

Resources. 1978. Santa Barbara Channel Marine Sanctuary--
Nomination. Prepared for the County of Santa Barbara,,.
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Santa Barbara News-Press, 1979. "It would all be gone in a week,
Report Says." April 22, 1979 (pp A-1 and A-10).

Science Applications. 1978. Archaeological Literature Survey
and Sensitivity Zone Mapping of the Southern California
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U.S. Bureau of Land Management. Pacific OCS Office. Los
Angeles,'CA.

Sheen Technical Committee. 1976. Environmental Aspects of Brill-
ing Muds and Cuttings from Oil and Gas Extractio *n Operators
in Offshore and Coastal Waters. (Offshore Operators
Committee). Houston, Texas. 50 p.

Siva, J. 1976. Oil Spi 11 Response Planning for Biologically Sensitive
Areas of the Santa Barbara Channel. Atlantic Richfi,eld Co.,
Los Angeles, CA. 31 p.

Slack, J., R.T. Wyant and K.L. Lanfear. 1978. An Oil Spill Risk
Analysis for*the S. California (Proposed Sale No. 48) Outer
Continental Shelf Lease Area. USGS, Reston, ".

Smith, D. and G. H. Holliday. 1979. API/SC-PCO Southern California
1978 Oil Spill Test Program. In Proceedings: 1979 Oil
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Smith, E.J. Jr., D.H. Fry, Jr., H.W. Frey, J. Speth, A. Rutsch, and
L. Fisk. 1976. Coastal County Fish and Wildlife Resources
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H-8

Southern California Ocean Studies Consortium. 1974. A Summary of
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University of California,'Santa Cruz. 1976. Draft Final Report
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III-1 to 111-269 *
Part II Cetacea by Kenneth S. Norris,, T.P. Dohl, R.C.''
Guess, L.J. Hobbs, and MA. Honig., pp. 111-270
to 111-441.
Part III Seabirds by K: T. Briggs, H.L. Jones 'G.L. Hunt,
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University of California, Santa Cruz. .1978. Draft Final Report,
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U.S. Army Corps of Engineers. 1976. Waterborne Commerce of the
United States.

U.S. Bureau of Land Management. 1975. Final Environmental State-
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Interior. Pacific OCS Office. Los Angeles, California.

U.S. Bureau of Land Management (BLM), 1975. Final Environmental
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U.S. Bureau of Land Management (BLM), 1978a. Status of Leases
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U.S. Bureau of Land Management (BLM), 1978b. Pacific Outer
Continental Shelf Reference Paper No. VI. U.S.
Department of the. Interior, BLM - Los Angeles, CA.

H-9

U.S. Bureau of Land Management (BLM), 1978c. Pacific Outer
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U.S. Bureau of Land Management (BLM), 1979. Final Environmental
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United States Departments of Interior and Transportation, 1972.
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U.S. Department of the Interior. 1978. Study Design for Resource
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U.S. Department of Interior (DOI), 1979a. "Andrus Seeks Governorl s
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U.S. Department of Interior. 1979b. Secretarial Issue Document:
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U.S. Department of the Interior. 1979c. Decision Document on 5-
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U.S. General Accounting Office. 1979. Progress and Problems of
Fisheries Management under the Fi.shery Conservation and
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U.S. Geological Survey (USGS), 1975. Map Showing Oil and Gas Fields,
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U.S. Geological Survey. 1976. Final Environmental Statement --
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U.S. House of Representatives, H.R. 3757, 1979. (A bill amending the
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U.S. House of Representatives, H.R. 1056, 1979. (A bill to prohibit
vessels transporting Alaskan oil from using routes through
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H-10

U.S. National Park Service'(NPS), 1976. Management Statement for
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U.S. National Park Service MIS), 1978. Management Statement for San
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U.S. Senate, S. 1104, 1979. (a bill to establish a National Park in
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Woodhouse, Charles, R.K. Cowi n and L.R. Wilcoxon. 1977. A Summary
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Atlantic City, NJ. June 27-30, 1978.

H-11

b. Personal Communications Cited

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H-12

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H-13

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H-14

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Whelen, N. 1980. Park Ranger, Channel Islands National Park.
Ventura, CA. March 14, 1980. (T); April 1, 1980 (T).

Wooten, Major R.C. 1979. U.S. Department of the Air Force.
Project Director, Space Shuttle Noise Impact Study.
Los Angeles, CA. May 25, 1979(T).

H-15

Section I. Li st of Preparers

Many persons participated in the preparation of the DEIS on which
this document was based. -A major portion of the environmental
analysis was performed under contract with the Center for Natural
Areas, 1525 New Hampshire Avenue, N.W., Washington, D.C. 20036.
.The following persons have made major contributions to the effort.

Center for Natural Areas

John T. Epting, Resource Planner
Thomas E. Bigford, Office Director and Marine Affairs Specialists
David W. Laist, Coastal Ecologist
Kermit Rader, Environmental Attorney
Joel E. Blumstein, Environmental Attorney
Brian J. O'Sullivan, Environmental Planning Analyst
George Robertson, Resource Management Specialist

The following persons made major contributions to both the DEIS and to
this document.

Office of Coastal Zone Management Sanctuary Programs Office

JoAnn Chandler, Director
Dr. Nancy Foster, Deputy Director
Diane Mayerfeld, Program Analyst
John Milholland, Attorney

J. APPENDICES

J-1

APPENDIX 1

Proposed Final Designation Doomient. and Proposed Regulations

Proposed Final Designation'Document

Designation Of The Channel Islands Marine Sanctuary.

Preamble
Un@er 'the authority of the Marine Protection, Research and
Sanctuaries Act of 1972, P.L. 92-532, (the Act) the waters surrounding
the northern Channel Islands and Santa Barbara Island are hereby
designated a Marine Sanctuary for the purposes of preserving and
protecting this unique and fragile ecological community.

Article l.- Effect of Designation

Within the area'designated as The Channel Islands Marine Sanctuary
(the Sanctuary).. described in Article 2, the Act authorizes the promul-
gation of such regulations as are reasonable and necessary to protect
the values of the Sanctuary. Article 4 of the Designation lists those
activities which may require regulation but the listing of any activity
does not by itself prohibit or restrict it. Restrictions or prohibitions
my be accomplished only through regulation, and additional activities
way be regulated only by amending Article 4.

Article 2. Description of the Area

The Sanctuary consists of an area,of the waters off the coas
of California, of approximately 1252.5 square nautical miles (nmi
adjacent to the northern Channel Islands and Santa Barbara Island
seaward to a distance of 6 mi. -Zhe precise boundaries are defined
by regulation.

Article 3. Characteristics of the Area '1hat Give it
Particular Value

The Sanc tuary is located in an area of upwelling and in a tran-
sition zcae between the cold waters of the California Cur-cent and
the warmer Southern California Countercurrent. . Consequently, the
Sanctuary contains an exceptionally rich and diverse biota, including
30 species of marine mammals and several endangered species of marine
manmls and sea birds. The Sanctuary will provide recreational
experiences and sc.-Lentific research cpportunities and generally will
have special value as an ecological, recreational, and esthetic
resource.

-Article 4. Scope of Regulation

Sectfon 1. Activities Subject to Regulation. In order to protect the
distinctive va7ues of the Sanctuary, the following activities may be
regulated withi'n the Sanctuary to the extent necessary to 'ensure the
protection and preservation,of its marine features and the ecological,
recreational, and esthetic val.ue of the area:

a. Hydrocarbon operations

b.- Discharging or depositing any substance or object

c. Dredging or alteration of, or-constructloh on, the seabed

d. Navigation of-vessels except fishing vessels or vessels
travelling within a vessel traffic separation scheme or
port access route designated by the Coast Guard outside
of I nmi from any island

e. Disturbing marine mammals or birds by overflights below
1000 feet,
f. Removing or otherwise deliberately harming cu-1tural or historical
.resources

Section 2. Consistency with International Law. The regulations governing
the activiti isted in Section I of this article will apply to foreign
flag vessels and persons not citizens of the United States only to the
extent consistent with recognized principles of international law
including treaties and international agreements to which the United
States is signatory.

Section 3. Emergency Regulati ons. Where essential to prevent immediate,
serious and irreversible damage to the ecosystem of the area, activities
other than those listed in Section 1 may be regulated within the limits
of the Act on an emergency basis for an interim period not to exceed
120 days, during which an appropriate amendment of this article would
be proposed in accordance with the procedures specified in Article 6.

Article 5. Relation to Other Regulatory Programs

Section 1. FishliU... The regulation of fishing is not authorized under
Article 4. However, fishing vessels may be regulated with respect to
discharges in accordance with Article 4, Section 1, paragraph (b) and
aircraft conducting kelp bed surveys below 1000 feet can be regulated
in accordance with Article 4, Section 1, paragraph (e). All regulatory
programs pertaining to fishing, including particularly regulations
promulgated under the California Fish and Game Code and Fishery
Management Plans promulgated under the Fishery Conservation and
Management Act of 1976, 16 U.S.C. 1801 et seq., shall remain in

effect. All permits,-licenses and other authorizations issued pursuant
thereto shall be valid within the Sanctuary unless inconsistent with
any regulation implementing Article 4. Fishing as used in this articl.e
and in Article 4 includes kelp harvesting.

Section 2. Defense Activities. The regulation of those activities
listed in Article 4 shall not prohibit any activity conducted by the
Department of Defense that is essential for'national defense or because
of emergency.

Section 3. Other Programs. All applicable regulatory programs shall
remain in effect a d all permits, licenses and other authorizations
issued pursuant thereto shall be valid within the Sanctuary unless
authorizing any activity prohibited by any regulation implementing
Article 4. The Sanctuary regulations shall set forth any necessary
certification procedures.

Article 6. Alterations to this Designation,

This Designation can be altered only in accordance with the same
procedures by which it has been made, including public hearings,
consultation with interested Federal and State agencies and the Pacific
Regional Fishery Management Council, and approval bythe President of
the United States.

Prcposed Final Pegulations

PART 935 -THE CHANNEL.ISLANDS MARINE SANCTUARY REG=IONS

935-1. Authority.

935-2. Purpose.

935-3. Boundaries.

935.4. Definitions.

935-5. Allowed Activities.

935-6. Hydrocarbon Operations.

935-7. Prohibited Activities.

935-8. Penalties for Commission of Prohibited Acts.

935-9. Permit Procedures and Criteria.

935-10. Certification of Other Permits.

935-11. Appeals of Administrative Action.

935-12. Amendments.

935.1. Authori

The Sanctuary has been designated by the Secretary of Commerce

pursuant to theauthority of Section 302(a) of Title III of the

Marine Protection, Research and Sanctuaries Act of 1972,, 16 U.S.C.

1431-1434 (the Act). The following regulations are issued pursuant

to the authorities of Sections 302(f), 302(g) and 303 of the Act.

935.2. Purpose..

The purpose of designating the Sanctuary is to protect and

preserve the extraordinary ecosystem including marine birds and

mammals and othet natural resources of the waters surrounding the

northern Channel Islands and Santa Barbara Island and ensure the

,continued availability of the area as a research and.recreational

resource. This area supports a particularly rich and diverse marine

biota,.partially because it is located in a transition-zone between

northern,and southern waters and partially because it is one of very
few areas off the Southern California coast'that has been relatively"

unaltered by.human use.

935.3. Boundaries.

The Sanctuary consists of an area of the waters off the coast of
California,of approximately 1252.5 square nautical miles (nm12) adjacent

.to the following islands and offshore rocks: San Miguel Island, Santa

Cruz Island, Santa Rosa Island, Anacapa Island, Santa Barbara Island,

Richardson rbcky and Castle Rock extending seaward to a distance

of 6 nautical miles (nmi). The coordinates are shown.in Appendix 1A.

935.*4. Definitions.

(a) "Administrator" means the Administrator of the National Oceahic

and Atmospheric Administration.

(b) "Assistant Administrator" means the Assistant Administrator

for Coastal Zone Management, National Oceanic and Atmospheric Administration.

or other entity; or any officer, employee, agentp departmentp agency

or instrumentality of the Federal governmento, or any state or local

unit of government.

(d) "Islands" means San Miguel Island,, Santa Cruz Island, Santa

Posa Island,, Anacapa Island, Santa Barbara Island, Richardson Rock,

and Castle Rock.

'935.5. Allowed Activities:

All@activities except those specifically prohibited by-Sections

935.6 and 935.7 may be carried on in the Sanctuary subject to all

prohibitions, restrictions and conditions imposed by any other authority-

Recreational use of the area is encouraged.

935.6. Hydrocarbon Ope@ations.
(a) Hydrocarbon exploration, development and production pursuant

to any lease executed prior to the effective date of these regulations

and the laying of any pipeline is allowed subject to paragraph 935.6(b)

and all prohibitions, restrictions and conditions imposed by applicable

regulations, permits, licenses or other authorizations and consistency

reviews including those issued by the Department of the Interior, the

Coast Guard, the Corps of Engineers, the Environmental Protection A gency

and the California Coastal Management Program and its implementing

regulations.

(b) No person may engage in any hydrocarbon operation

unless the following oil spill contingency equipment is available. at

the site of such operation:

(1) 1500 feet of open ocean containment boom on a
boat capable of deploying the boom;

(2) one oil skimming device capable of open ocean
use; and

(3) fifteen bales of oil sorbent material.

pursuant to leases executed on or after the effective date of these

regulations are prohibited.

935-7. Prohib-ited Activities.-

(a) Except as may be-necessary for the na,ti'onal defense, in

accordance with.Art icle 5, Section Zof the Designation, or as may be

necessary to respond to an emergency threatening life-, property, or the

environrm.nt, the following activities are prohibited within the Sanctuary

unless permitted by the Assistant Administrator in.accordance with

Sections 935.9 or 935.10. All prohibitions shall be applied

,tonsistently with international law.

(1) Discharge of substances.

No person shall deposit or discharge any materials-or substances

of any kind except:

(A) indigenous fish or parts and chumming materials (bait)-

(8) effluents from marine sanitation'devices

(D) effluents incidental to hydrocarbon exploration and

exploitation activities as allowed by Section 935.6.

(2) Alteration of, or construction on, the seabed.

-Except in connection with the laying of any pipeline as allowed

by Section 935.6, withi n 2 nautical miles of any Island, no person

shall:

(A) construct any structure other than a navigation aid, or

(8) drill through the seabed, or

(3) Commercial vessels operations.

Except to transport persons or supplies to or from an Island, no

person shall operate within one nautical mile of an Island any vessel
engaged in the trade of carrying cargo, including but*not limited to

tankers and other bulk carriers and barges, or any vessel engaged in

the trade of servicing offshore installations. In no event shall this

section be construed to limit access for fishing'(including kelp

harvesting), recreational, or research vessels.

(4) Disturbing marine mammals and birds.

No person shall disturb seabirds or marine mammals by flying

motorized aircraft at less than 1000 feet over the waters within

one nautical mile of any Island.except:

(A) for enforcement purposes;

(B) to engage in kelp bed surveys; or

(C). to transport persons or supplies to or from an 1sland.

(5) Removing or damaging historical or cultural resources.

No person shall remove or damage any historical or cultural

resource.

(b) All activities currently carried out by the Department of

Defense within the Sanctuary are essential for the national defense

and, therefore, not subject to these prohibitions. The exemption of

additional activities having significant impacts shall be determined

in consultation between the Assistant Administrator and the Department

of Defense.

of territoriality and will be applied to foreign persons and vessels

only in accordance with recognized principles of international law,

including treaties, conventions and other international agreements to

which the United States is signatory.

935.8. Penalties for Commission of Prohibited Acts.

(a) Section 303 of the Act authorizes the assessment of-a civil

penalty of,not more-than $50,000 against any person subject to the

jurisdiction of the United States for each violation of any regulation

Jssued pursuant to the Act, and further authorizes a proceeding in rem

against any vessel used in violation of any-such regulation. Procedures

are set out.in Subpart D of Part-922 (15 CFR Part 922) of this chapter.

Subpart 0 is applicable to any instance of a violation of these

regulations.

935.9 Permit Procedures and Criteria.

(a) Any person in possession of a valid permit issued by the

Assistant Administrator in accordance with this section may conduct

any activity in the Sanctuary including any activity specifically

prohibited under Section 935.7 if such activity is either (1) research

related to the resources of the Sanctuary, (2) to further the educational

value of the Sanctuary, or (3) for salvage or recovery operations.

(b) Permit applications shall be addressed to the Assistant

Administrator for Coastal Zone Management, Attn: Office of Sanctuary
Programs, bivision of Operations and Enforcement, National. Oceanic and
Atmospheric Administration, 3300 Whitehaven Street, N.W., Washingto'n,

D.C. 20235. An application shall provide sufficient information to

enable the Assistant Administrator to make the determination called

for in paragraph (c) below and shall include a description of all

activities proposed, the equipment, methods and personnel (particularly
describing relevant experience) involved, and,a timetable for completion

of the proposed activity. Copies of all other required licenses or

permits shall be attached.
(c)' In considering whether to grant a permit the Assistant

Administrator shall evaluate such matters as (1) the -general professional

and financial responsibil.ity of the applicant; (2) the appropriateness

of the methods envisioned to the purpose(s) of the activity; (3) the

extent to which the conduct'of any permitted activity may,diminish or

enhance the value of the Sanctuary as a source -of recreation, or as a

source of educational or scientific information; (4) the end value of

the activity and (5) such other matters as may be deemed appropriate.

(d) In considering any application submitted pursuant to this

section, the Assistant Administrator may seek and consider the views of

any person or entity, within or outside of the Federal Government, and

may hold a public hearing, as deemed appropriate.

(e) The Assistant Administrator may, at his or her discretion,.

grant a permit which has been applied for pursuant to this section, in

whole or in pa rt, and subject to such condition(s) as deemed appropriate.

The Assistant Administrator or a designated representative may observe

any permitted activity and/or require the submission of one or more

reports of the status or progress of such activity. Any information

obtained shall be available to the public.

M The permit granted under paragraph (e) may not be transferred.

(g) The Assistant Administrator may amend, suspend or revoke a

permit granted pursuant to this section, in whole or in part, temporarily

or indefi.nitely, if the permit holder (the Holder) has acted in violation

of the terms of the permit or of the applicable regulations. Any such

action 'shall be set forth in writing to the Holder, and shall set forth

the reason(s) for the action taken. The Holder may appeal the action

as provided for in Section 935-11.

935.10. Certification of Other Permits.

a) All permits, licenses and other authorizations issued.pursuant

to any other authority are hereby certified and shall remain valid if
they do not authorize any activity prohibited by Sections 935.6 or

935.7. Any interested person may,request that the Assistant Administrator

offer an opinion on whether an activity is prohibited by these regulations.

.935.11. Appeals of Administrative Action.

(a) Anrinterested person (the Appellant) may appeal the granting,

denial, or conditioning of any permit under Section 935.9, to the

Administrator of NOAA. In order to be considered by the Administrator,

such appeal shall be in writing, shall state the action(s) appealed

and the reason(s) therefor, and shall be submitted within 30 days of

the action(s) by the Assistant Administrator. The Appellant may request

an informal hearing on the appeal.

(b) Upon receipt of an appeal authorized by this section, the

Administrator will notify the permit applicant, if other than the

Appellant, and will request such additional information and in such

form as will allow action upon the appeal. Upon receipt of sufficient

information, the Administrator will decide the appeal in accordance

with the criteria set out in Section 935.9(c) as appropriate, based upon

information relative to the application on file at OCZM and any additional

information ,the summary record kept-of any hearing and the'Hearing
Officer's.recommended decision', if any, as provided in paragraph (c),

and such other considerati ons as deemed appropriate. The Administrator

will notify all interested persons of the decision, andthe reason(s)
therefor, in writing,.normally within 30 days of the receipt of suffidient

information, unless additional time is needed for a hearing..-

,(c) If a hearing is requested or if the Administrator determines

.that one is appropriate, the Administrator may grant an informal

hearing before a Hearing Officer designated for that purpose after

first giving notice of the time, place, and subject matter of the
hearing in the Federal Register. Such hearing shall normally be held

no later than 30 days following publication of the notice in the Federal

RegIster unless the Hearing Officer extends the time for reasons
-deemed equitable. The Appellant, the Applicant (if different),and, at

the discretion of the Hearing Officer, other interested persons, may

appear personally or by counsel at the hearing and submit such material

and present such arguments as determined appropriate by the Hearing

Officer. Within 30 days of the last day of the hearing, the Hearing

Officer shall recommend in'writing a decision to the Administrator.

(d) The Administrator may adopt the Hearing Officer's recommended,

decision, in whole or in part, or may reject or modify it. In any

event, the Administrator will notify interested persons of the decision,

and the reason(s) therefor in writing within 30 days of receipt of the

recommended decision of the Hearing Officer. The Administrator's action

shall constitute final action for the Agency for the purposes of the

Administrative Procedures Act.

(e) Any time limit prescribed in this section may be extended

for a period not to exceed 30 days by the Administrator for good

cause, either up'on his or her own motion or upon written request

from the Appellant or Applicant.stating the reason(s) therefor.

935.12 Amendments.

(a) Any amendment to these regulations which significantly

alters the extent of the prohibitions described in Sections 935.6

and 935.7 will directly affect California's coastal zone and shall

be consistent with the California Coastal Management Program to

the maxi.mum extent -practicable.

(b) If the California Coastal Management Program is amended

to authorize in State waters an activity prohibited by Section.

935.6 or 935.7, upon the requst of the Governor of California

the Assistant Administrator shall propose a'conforming amendment

to these regulations, unless he/she* determines in writing that the

activity would be clearly inconsistent with the purposes of the

Sanctuary or otherwise would be prohibited by law.

APPENDIX l.A: Coordinates of the Channel Islands Marine Sanctuary

LATITUDE N LONGITUDE W
0 / // 0 / //

01 33 056'28. 959" 119016'23.800"
02 33058'03.919" 119014'56.964"
03 34001 '33.846" 119014'07.7401,
04 34004'24.203" 119015'21.308"
05 34006'06.653" 119017 '27. 0021,
06 34006'54.809" 119019'46.046"
07 34 006'5 7. 988" 119023'24. 9051,
08 34006'51. 627" 119024'04.198"
09 34007'01. 640" 119025'40.8191,
10 34006'59. 904" 119026'50. 959"
11 34008'02.002" 119028'47. 501 11
12 34008'l 7. 693" 119 02 9'2 7. 698"
13 34008'52.234" 119030'39.5621,
14 34009'16. 780" 119 03 5'22. 667"
15 34009'05.106" 119 036'41. 69411
16 34008'02. 782" 119 03 9'33. 421 "
17 34008'46.870" 119 041 '4 8. 621 "
18 34009'35. 563" 119045'57. 284"
19 34009'32.627" 119046'37.335"
20 34009'33.396" 119047'32. 285"
21 34009'43.668" 119048'09.018"
22 34010'10. 616" 119 05 0'0 7. 659"
23 34 010 '21. 586" 119 051 '0 5.146 11
24 34010'33.161" 119053'17.044"
25 34010'36.545" 119055'57.37311
26 34010'21.283" 119 05 7'2 6. 4 03 "
27 34008'07.255" 120001 '07.2331,
28 34008'13.144" 120002'27.930"
29 34007 '47. 772" 120005'05.44911
30 34007'29. 314" 120006'36. 262"
31 34007'30.691" 120009'35.2381,
32 34006'36.285" 120012'39.335"
33 34006'40.634" 120013'33. 9401,
34 34008'10.759" 120015'07.017"
35 34009'12.290" 120 017 '0 7. 046 11
35A 34009'50. 706 120017'31.649"
36 34010'56. 346" 120018'40.5201,
36B 34011'28.249" 120019'29.213"
37 34012'08.078" 120021 '00.8351,
3 7C 34012'25.468" 120025'01 . 261 "
38 34012'18.754" 120025'39.37311
38D 34011'33.184 120027'33. 921 "
39 34012'19.470" 120 030'22. 620"
3 9E 34012'17.540" 120032'l 9. 959"
40 34010'54.592" 12003557.88711
40F 34006'07.491" 12 003 8'2 7. 883 11
41 34004'53.454" 120038'16.602"

LATITUDE N LONGITUDE W
0 / // 0 / //

41G 34003'30.539" 120037'39.442"
42 34001'09.860" 120035'04.808"
42H 34000'48.573" 12003425.106"
43 33059'13.122" 120033'53.385"
44 33057'01.427" 120031 '54. 590"
45 33055'36. 973" 120027 '37. 1881,
46 33055'30.037" 120025'14. 587"
47 33054'50. 522" 120022'29.53611
48 33055'01.640" 120019'26-722"
49 33054'34.409" 120018'27.3441,
50 33053'23-129" 120017 '39. 927"
51 33050'39. 990" 120015'13. 8741,
52 33049'53.260" 120013'41.904"
53 33049'03. 437" 1 20012'06.750"
54 33048'36. 087" 120011 'l 0. 821 "
55 33047'39.280" 120007'59.707"
56 33 04 P3 7. 617 " 120006'04. 002"
57 33047'59.351" 120004'08.370"
58 33048'38.700" 120002'33.188"
59 33048'52.167" 120001 '50.244"
60 33050'28.486" 11905 P50. 820"
61 33 050 '5 5. 128" 11 9055'l 9. 934"
62 33052'13.338" 119052'53.439"
63 3 3 0 52 '04. 900 " 119 0 52 '10. 719 "
64 33051'39.919" 119 04 7 '21 .15 2 "
65 33 051 '48. 592" 119 046'13. 213 "
66 33051 '35. 798" 119 044'3 4. 589"
67 33051'44.374" 119 041 'l 2. 738"
68 33052'23.857" 119 03 9'14. 708"
69 33053'09.365" 119037'30.784"
70 33053'l 2. 754" 119 03 5'3 5. 793"
71 33053'17.114" 119034'54.567"
72 33053'38. 865" 119 03 2'51. 578"
73 33054'02.277" 119031'06.274"
74 33054'56-444" 119 02 8'54. 052 "
75 33 054 '3 9. 349" 119 027 '3 7. 512 "
76 33054'l 5. 236" 119025'23.779"
77 33054'07. 847" 119 024'22. 849"
78 33054'04. 682" 119022'58.006"
79 33054'l 4. 311 " 119 021 '44. 5 73 "
80 33054'22-824" 119021 '09. 003"
81 33054'46.904" 119019'54.677"

LATITUDE N LONGITUDE W
0 0

82 33055'05.834" 119019'16. 027"
83 3 3 02 8'5 6. 904 " 119010'04.092"
84 33026'32. 364" 119010'01 . 328"
85 33024'19.904" 119008'52.2361,
86 33023'26. 019" 119007'54. 826"
87 33022'04.836" 119005'16.7161,
88 33021'49.387" 119004'01 . 551
89 33 021 '44. 594" 119002'49.8871,
90 33021'49.556" 119001'37.839"
91 33 022'0 7. 538" 118059'49.3571,
92 33022'27.774" 118058'51.623"
93 33022'47-957" 118058'07. 633"
94 33023'20-805" 11805 Pl 4. 375"
95 33024'18.458" 118056'08.450"
96 3302624.130" 118054'51. 352"
97 33029'02.820" 118054'22.276"
98 33 031 '2 7. 917 " 118054'50. 367"
99 33032'17.935" 118055'l 8.396"
100 33035'10. 090" 118059'40. 0910"
101 33035 '24. 575" 119 001 '22.1081 "
102 33 03 5'0 6. 497 " 119 00 3' 5 9. 4632 "
103 33034'48.322" 119005'03.3743"

-TI.
LA
ARRAR

SON ANNEL

SANTA CRUZ
ISLAND
SANTA
-ROSA
'SLAND

E:. F_
@.AIT
'7A
MAID

119* 0'
33*5o, 10, 119*CKY
Y-617,760 33*50'

93
ca IN. w
Q Y-601,920' 0
601,920'

586,080'

570,240' 570,240'

40, 554,400' -4 1- 40'
654,400

538,560' 538,560"

101
103 102 100

522,720, 522.720'

506,880' 104 99 506,880'

3(Y
30'@ 4191,.' 491,040"
a3 SANTA 97
BARBARA
ISLAND
475,200' @4 / 1 1 475,200'
96

459,360' 95 459,360'

94
93
92
91
443,520' 88 9.0 443,520'

33*20'

33*20,
Y-427,680, '-@27,680'

90 J, P 'N
co 0) w
0
DO
1 Y-411,840'1 D. 1
119020' 10,
118,50,
uj

9 /r,
94
9'3
9@92

PREFERRED MARINE
@%% OF SANCTUARY eOUNOARY
DIGITIZED POINTS-O,,

APPENDIX 2. Fish and shellfish species of commercial and recreational
interest in the waters around the northern Channel Islands
and Santa Barbara Island (Califlornia Department of Fish
and Game, in process).

Fishery Resources Listed on Atlas by Island

SAN MIGUEL

1. Mollusks in Rocky Areas:

Red Abalone Black Abalone White Abalone Rock Scallop

2. Kelp Bed & Rocky Bottom Fish:

Cabezon Monkeyface Eel Kelp Greenling Lingood
Black Rockfish Black & Yellow Rockfish Blue Rockfish Copper Rockfish
Kelp Rockfish Gopher Rockfish Grass Rockfish Olive Rockfish
Vermillion Rockfish Yellowtail Rockfish Blue'Shark Leopard Shark
.Barred Surfperch Black Surfperch Pile Surfperch Pile Surfperch
Rubberlip Surfperch Striped Surfperch Tomsmelt Surfperch
3. Fish Over Shallow Sand Bottom.; O-18m (0-60 ft.):

N. Anchovy Pacific Butterfish Jacksmelt Queenfish
White Seabass Barred Surfperch Pile Surfperch Spinner Surfperch
Spotfish Surfperch Rainbow Surfperch Walley Surf- White Surfperch
perch
Tom smel t C-0 Turbot Horny Head Surfperch

4. Fish Over Moderate Deep Sand Bottom; 18-465m (60-150 ft.):

Spiny DDgfish Pacific Sanddab Calico Rockfish Halfbanded Rockfit
Stripetail Rockfish English Sole Sand Sole Pink Surfperch
Shiner Curlfin Turbot Hornyhead Turbot

5. Pelagic Fish Off This Coast:

Albacore NDrthern Anchovy Pacific Bonito Pacific Hake
Jack Mackerel King Salmon Pacific Sardine Pacific Saury
Blue Shark Mako Shark Thresher Shark White Shark
Swo rdfi sh

SANTA ROSA ISLAND

1. Mollusks in Rocky Areas:

Red Abalone White Abalone California Sea- Black Abalone
mussel

Rock Scallop Piddocks

2. Kel p Bed & Rocky Bottom Fish:

Cabezon MDnkeyface Eel Lingood Black Rockfish
Black & Yellow Rockfish Blue Rockfish Copper Rockfish China Rockfish
Gopher Rockfish Kelp Rockfish Olive Rockfish Yellowtail Rockfi!
Blue Shark Leopard Shark Califbrnia Black Surfperch
Sheephead
Pile Surfperch Rubberlip Surfperch Striped Surf- Tomsmelt
perch

3. Fish Over Shallow Sand Bottom; O-18m (0-60 ft.):

Anchovy Leopard Shark Rainbow Surf- C-0 Turbot
perch
Pacific Butterfish White Seabass Walleye Surf- Hornyhead Turbot
perch

ANACAPA ISLAND

1. Mollusks in Rocky Areas:

Black Abalone Pink Abalone Rock Scallop Red Abalone
White Abalone '.Califbrnia Mussel

2. Kelp Bed & Rocky Bottom Fish:

Kelp Bass Black Rockfish Yellowtail Giah.t Sea Bass
RDckfish
Black & Yellow Rockfish Blue Shark Blacksmith Brown Rockfish
Leopard Shark Monkeyfaced Eel Blue Rockfish Califbrnia Sheep-
head
Garibaldi Copper Rockfish Black Surfperch Halfmoon
Gopher Rockfish Pile Surfperch Opaleye Olive Rockfish
Rubberlip Surfperch Kelp Rockfish Striped Surf- Tree Rockfish
perch
Tomsmel t

3. Fish Over Shallow Sand Bottom; 0-18m (0-60 ft.):

Northern Anchovy Pile Surfperch White Surf- Pacific.Butterfis
perch
Rainbow Surfperch Tomsmelt Jacksmelt Shiner Surfperch
C-0 Turbot Queenfish Spotfin Surf- White Seabass
perch
Walleye Surf.perch

4. Fish Over Moderate Deep Sand Bottom; 18-46m (60-150 ft.):

Spiny Dogfish Stripetail Rockfish Shiner Surf- Pacific Sanddab
perch
English Sole Curlfin Turbot Calico Rockfish Sand Sole
Hornyhead Turbot Halfbanded Rockfish Pink Surfperch

S. Pelagic Fish Off This Coast:

Albacore@ Pacific Bonito Pacific Saury Mako, Shark
No rthern Anchovy Jack Mackerel Blue Saury Thresher Shark
Pacific Hake Pacific Sardine Blue Shark White Shark
Swordfish

SANTA BARBARA ISLAND

1. Mollusks in Rocky Areas:

Black Abalone White Abalone Mussels Red Abalone
Rock Scallop Piddocks

2. Kelp Bed & Rocky Bottom Fish:

Cabezon Gopher Rockfish Black Surfperch Bat Rays.
Monkeyfaced Eel Calico Rockfish Olive Rockfish. Pile Surfperch
White Seabass Kelp Greenling Squarespot Yellowtail Rockfi
Rockfish
Rubberlip Surfperch Giant Sea Bass Lingood Blue Shark
Striped Surfperch Ocean Whitefish Black Rockfish Horn Shark.
Sculpin Black & Yellow Rockfish Swell Rockfish Tomsmelt
Blue Rockfish Leopard Shark Mal famo n Copper Rockfish
Califbrnia Sheephead Opaleye

3. Fish Over Shallow Sand Bottom; O-18m (0-60 ft.):

Northern Anchovy Barred Surfperch Spotfin Surf- Topsmelt
perch
Facific Butterfish Pile Surfperch Walleye Surf- Jacksmelt
perch
Rainbow Surfperch White Surfperch C-0 Turbot Queenfish
Shiner Surfperch White Seabass

4. Fish Over Moderate Deep Sand Bottom; 18-46m (60-150 ft.):

Spiny DDgfish Halfbanded Rockfish Sand Sole Curlfin Turbot
Pacific Sanddab Stripetail Rockfish Pink Surfperch Hornyhead Turbot
Calico Rockfish English Sole Shiner Surf-
perch

5. Pelagic Fish Off This Coast:

Albacore Jack Mackerel Mako Shark Yellowtail

Northern Anchovy Pacific Sardine Thresher Shark [bgfi sh
Pacific Bonito Pacific Saury White Shark Soupfin Shark
Pacific Hake Blue Shark Swordfish
Jacksmelt Pile Surfperch White Surfperch Queenfish
Shiner Surfperch Tomsmelt Speckled Sand- White Croaker
dab.
Island Surfperch

4. Fish Over Moderate Deep Sandy Bottom; 18-46m (60-150 ft.):

Spiny DDgfish Halfbanded Rockfish Sand Sole Curlfin Turbot
Pacific Sanddab Stripetail Rockfish Pink Surfperch Hornyhead Turbot
Calico Rockfish English Sole Shiner Surf- Soupfin Shark
perch
Califbrnia Halibut

5. Pelagic Fish Off This Island:

Albacore Pacific Kake Blue Shark Swordfish
Northern Anchovy Pacific Mackerel Mako Shark Mola
Pacific Bonito Pacific Sardine Thresher Shark Jack Mackerel
Pacific Saury White Shark
(Commercial fishing close in fbr Abalone,'Lobster, Squid)

SANTA CRUZ ISLAND

1. Mollusks in Rocky Areas:

Red Abalone White Abalone Rock Scallop Black Abalone
Bay Mussel Califbrnia Sea Mussel

2. Kelp Bed & Rocky Bottom Fish:

Cab ezo n Copper Rockfish Cal i fb rni a Monkeyfaced Eel
Sheephead
China Rockfish Black Surfperch Blacksmith Kelp Rockfish
Kelp Rockfish Kelp Greenling Olive Rockfish Pile Surfperch
Lingood Gopher Rockfish Rubberlip Surf- Black Rockfish
perch
Yellowtail Rockfish Striped Surfperch Black & Yellow Blue Shark
Rockfish
Tom smel t Blue Rockfish Leopard Shark Garib al di
Grass Rockfish Opaleye Kelp Bass

3. Fish Over Sh.Allow Sand Bottom; O-18m (0-60 ft.):

Northern Anchovy. Barred Surfperch Rainbow Surf- Pacific Butterfis
perch
Calico Surfperch Walleye Surfperch Jacksmelt Pile Surfperch

White Surfperch Queenfish Shiner Surf- Tomsmelt
perch
White Seabass Island Surfperch C-0 Turbot Grunion
Spotfin Surfperch @Iornyhead Surfperch Speckled Sanddab
4. Fish Over Moderate Deep Sandy Bottom; 18-46m (60-150 ft.):

Spiny Dogfish Stripetail Rockfish Shiner Surf- Pacific Sanddab
perch
English Sole Curlfin Turbot Calico Rockfish Sand Sole
Hornyhead Turbot Halfbanded Rockfish Pink Surfperch

5. Pelagic Fish Off This Island:
Albacore Pacific Mackerel Thresher Shark Northern Anchovy
Pacific Sardine White Shark Pacific Boni'to Pacific Saury
Swordfish Pacific Hake Blue Shark Mola
Jack Mackerel Mako Shark Opah

APPENDIX 3: Brief Review of the Outer Continental Shelf (OCS)
Oil and Gat Development Process

In virtually all instances, the pattern of OCS oil and gas devel-
opment follows the same basic steps: 1) pre- explo ration, 2)
leasing, 3) exploratory drilling, 4) development drilling, 5)
production, and 6) completion. During pre-exploration activity,
oil companies send research vessels to conduct sei 'smic surveys of
an area to- determine' the geologic structure and location of
potential petroleum bearing strata. Since OCS lands are federally
owned, oil companies must first secure the right to drill and
exploit the natural resources before any drillings can be con-
ducted. Drilling rights on the OCS are obtained by leasing areas
(called blocks or tracts) from the responsible federal agent --
the Bureau of Land Mangement (BLM). The oil companies nominate
for lease -sale those.tracts which they view as promising and bid
on those tracts in a competitive bid lease sale. BLM reviews the
highest bids and may accept or reject them., If the high bids are
deemed commensurate with the resource potential, the company is
granted a lease to drill and develop the block.

Upon award of a.lease, exploratory drilling from a drilling "rig"
may be conducted to determine the precise location, extent, and
quantity of oil and gas resources. This involves drilling an
average of about four exploratory wells per tract from a movable, -
temporary rig. If an exploratory well indicates the presence of
petroleum hydrocarbons, additional wells are drilled to determine
.the areal extent of the reservoir(s) and to aid in locating the
optimal site for production platforms. After exploration is
complete, but before commercial production can begin, a develop-
ment plan must be prepared by the developer and submitted for
approval to the U. S. Geological Survey (USGS). The USGS reviews
this plan to insure that safety and environmental standards are
met.

After approval of the development plan, production "platforms" are
installed on the tract and development wells are drilled. A tract
with a high resource potential might include two platforms and
approximately 40 wells. Production "platforms" are more permanent
structures than drilling "rigs" since they must serve throughout
the production life of the field (which may be 15 to 40 years) and
withstand 'the rigors of even the most severe ocean storms. In
addition to platforms, production facilities normally include
transportation systems to shore and onshore processing and storage
plants.

After all recoverable oil and gas resources have been exploited,
the well is closed below. the sea floor and the platform and
pipelines are removed.

APPENDIX.4: BLM Special Stipulations for OCS, Sale #48 (U. S. Bureau
of Land Management, 1979).

Stioulation No. 1.. Department ofDefense restriction

Requires lessee and/or operator to coordinate boat and aircraft
traffic with appropriate military commander; provides for tempo-
rary suspensions of OCS operations, and requires control of
electromagnetic emissions.

Stipulation No. 2. Department of Defense restriction

Indemnifies and saves harmless the United States against claim for
injury or damage from space and missile testing.

Stipulation No. 3. Cul tural Resources

Requires surveys to identify resources of historical or arch-aeo.-
logical significance, and subsequent protection.

Stipulation No. 4. Trawl grounds

Requires that protrusions above the sea floor, and irregular pipe
surfaces, be protected by shrouds which will prevent damage to the
structures, or fishing gear.

Stipulation No. 5. Area.s of special biological interest

Requires prevention, to the maximum extent possible, of detri-
mental impact upon.areas of special biological.interest.

Stipulation No. 6.. Transport of oil and gas

This stipulation establishes regional and state working groups,
consisting of federal, state, and local government, and industry
representation, to formulate regional transportation management
plan recommendations.

Stipulation No. 7. Tanner-Cortes Banks

To mitigate the impacts of physical disruption and sedimentation
on significant biological communities of Tanner-Cortes Banks.

APPENDIX 5: Summary of USGS Pacific OCS Orders and Notices to Lessees
(U.S. Bureau of Land Management, 1979).

Pacific Area OCS Order No. 1

This Order requires all platforms, drilling rigs, drilling ships,
and wells to have standard signs identifying the 'operator, the
specific lease block of operation, and well number.

Pacific Area OCS Order No. 2

Order No. 2 concerns procedures for drilling of wells. It re-
quires the operators to file an application for drilling which
includes information on the drilling platforms or vessel, casing
-program, blowout prevention equipment, well control training and
safety training of operators' personnel, and a list or description
of critical drilling operations.

Pacific Area OCS Order No.3.

This Order is established to provide regulation of plugging and
abandonment of wells which have been drilled for oil and gas. For
permanent abandonment of wells, cement plugs must be placed so as
to extend 30m (100 feet) above the top and 30m (100 feet) below
the bottom of fresh water.' oil, and gas zones to prevent those
fluids from escaping into other strata. Portions of a well in
which abnormal pressures are encountered are also required to be
isolated with cement plugs. Plugs are required at the bottom of
the deepest casing below which an open hole exists. Pl ugs or
cement retainers are required to be placed 30m (100 feet) above
the top and 30m (100 feet) below any perforation interval of the
well hole used for production of oil and gas.

Pacific Area OCS Order No. 4.

An OCS lease provides for its extension beyond its primary term
for as long as oil or gas may be produced in paying quantities
provided the operator has met the requirements for diligent
development. If these circumstances should occur, the lease can
be extended beyond its initial term, pursuant to Section 8(b)(2)
of the OCS Lands Act and Title 30 CFR 250.11 and 250.12(d)(1). In
addition, an OCS lease may be maintained beyond the primary term,
in the absence of actual production, when a suspension of produc-
tion has been approved by the Supervisor. Order No. 4 defines the
conditions and requirements for such suspensions.

Pacific Area OCS Order No. 5.

This Order sets regulations for the installation, design, testing,
operation, and removal of subsurface'safety devices.

Pacific Area OCS Order No. 6.

This Order pertains to procedures for completion of oil and gas
wells. Wellhead equipment such as casing-heads, wellhead fit-
tings, valves, and connections are specified and rating require-
ments are noted here. Testing procedures for wells and subsurface
safety devices are also specified in the Order along with methods
for multiple or tubingless completions.

Pacific Area OCS Order No. 7.

Order No. 7 concerns the control or pollution to the marine
environment and provides regulations for the disposal of waste
materials generated as a result of offshore operations.

Pacific Area OCS Order No. 8.

This Order requires that platforms, fixed structures, and artifi-
ci al islands be designed with consideration for geological ,
geographical , environmental and operational conditions. Prior to
structural approval by the Supervisor, detailed design and stress
load data must be submitted to the USGS. Certification of struc-
tural adequacy by a registered professional engineer is required
by the Order.

Pacific Area OCS Order No. 9.

OCS Order No. 9 provides approval procedures for oil and gas
pipelines on the OCS. All pipelines and related equipment must be
designed and maintained with high-low pressure sensors, automatic
shut-in valves, checkflow valves (to control backflow), and
metering systems to detect input/output variances (leakage). The
Order also requires adequate provisions for cathodic corrosion
protection, trawling compatibility, hydrostatic testing, storm
scour and other environmental stress in OCS pipelines. Procedures
and schedules for regular inspection of pipelines along with
recording of such inspections are stipulated.

Pacific Area OCS Order No. 10.

OCS Order No. 10 provides for drilling twin core holes located
adjacent to core holes drilled on the OCS under earlier California
State authorization. Such holes were drilled prior to the esta-
blishment of Federal authority beyond the 3-mile limit.

Pacific Area OCS order No. 11.

This Order provides for prevention of waste, conservation of oil
and gas resources, and protection of correlative rights by defin-
ing and setting standards for rates of production, production
.testing procedures, and joint production requirements.

Pacific Area OCS Order No. 12.

The purpose of this Order is to make the records of the Department
of the Interior available to the public to the greatest extent
possible.

Notice to Lessees No. 77-1. "Applications for exploratory opera-
tions"

This NTL summarizes the requirements and instructions relative to
the approval of applications for a permit to dri'll exploratory
wells.

Notice to Lessees No, 77-2. "Minimum requirements for shallow
drilling hazard surveys"

Minimum requirements of geologic hazard surveys, which must be
conducted pursuant to 30 CFR 250.34(a), are described.

Notice to Lessees No. 77-3. "Minimum cultural survey require-
ments"

-Describes necessary measures to be taken to identify and preserve
all Federally-owned sites, structures, and objects of historic,
architectural , or archeological significance as directed by
Executive Order No. 11593.

Notice to Lessees No. 77-4. "Minimum requirements for biological
surveys"

Requires a plan of survey to identify significant biological
communities.

APPENDIX 6.

ANALYSIS,OF THE ECONOMIC IMPACTS OF THE
PROPOSED CHANNEL ISLANDS SANCTUARY REGULATIONS

Prepared for
Sanctuary Programs Office
National Oceanic and Atmospheric Administration
U.S. Department of Commerce

Prepared by
Sterling Hobe Corporation
Suite 350
1747 Pennsylvania Avenue, N.W.
Washington, D.C. 20006

April 1980

TABLE OF CONTENTS

Executive Summary ........................................ ES-1
Introduction ............................................. 1
Background ............................................... 5
Expected Hydrocarbon Reserves ............................ 9
Socioeconomic Impact of Proposed Sanctuary Resulting
from Curtailment of Hydrocarbon Exploration and
Production .............................................. 27

value of Hvdrocarbon Resources ........................... 28

Production Rates Over Time ............................... 29

Initial Production Years ................. 0 ............... 34
Substitute Opportunities ................................. 35
Types of Socioeconomic Imapcts ............................ 36
Socioeconomic IMpacts of Proposed Sanctuary Assuming
Worst Case Direct Impact ................................. 39
Impact on the Economy and Consumers ...................... 39
Impact on Oil and Gas Industry ........................... 39
Impact on Region ......................................... 43
Commercial and Rec'reational Fishing and Tourism
Activities Within or In the Vicinity of Proposed
Sanctuary ................................................ 48
Impacts on Prices and Costs of Goods and Services ........ 49
Impacts on Productivity and Employment ................... 19
Impact on Consumers ..................................... 50@
indirect Impacts .......................... ........ 51
Total (Direct and Indirect) Costs Assuming Worst Case .... 62
Socioeconomic Impact of the Proposed Sanctuary Assuming
Normative Case Total Impacts ............................. 62

Appendix A: Individuals Interviewed in the Course of
the Study
Appendix B: Indirect Impact Calculations

LIST OF TABLES

Table No. Page

1 Milestones in Santa Barbara Channe 1 and the
Channel'Islands Area.0il and Gas
Development....... .................................... 10
2 Cognizant Information on Lea'se 'Sales ................... 12
3 Number of Wells Drilled on Exist 'ing Leas'es, All or
Partially within 6 nmi (11.lkm) of the Northern
Channel Islands and Santa Barbara Island (also
see Figure E-22). (Adams, 1979, personal communica-
tion; U.S. Bureau of Land Management,.1979 (Visual
No. 1); U.S. Bureau of Land Management, 1978a) ..... 23
4 Platforms in the Santa Ba Irbara Channel'Area (U.S.
Bureau Of Land Management, 1979 (Visual No. 1);
U.S. Geological Survey, 1975 (Map 1-974);
Resources 1978; Adams, 1979,-personnal communica-
tion; and California office of Planning and
Research, 1977); ...25
5 Assumed Crude Oil Prices, 30
.............

6 Assumed Natural Gas Prices, 1982-2000 ....... * ........ 31
7 Most Probable Values for Oil and Gas Production
and Producing Wells .................................. 32
8 Annual Rates of Oil and Gas Production for Lease
Sale #48 ........................................... 33
9 Direct Loss to Economy from Foregone Hydrocarbon
Production for 24 Tracts Withdrawn from Proposed
Sanctuary Assuming Worse Case, 1982-2000 ........... 40
10 Direct Loss to Economy from Foregone Hydrocarbon
Production for Remaining Tracts Within Boundaries
of Proposed Sanctuary Assuming Worst Case, 1988-
2006 ............................................... 41
11 Total Impact on the Economy Resulting from Hydro-
carbon Production in the 24 Tracts Withdrawn from
Lease Sale #48 and from Hydrocarbon Production in
the Remaining Tracts of the Proposed Sanctuary,
1982-2006 .......................................... 42
12 Profit as Percent.of Sales-for the Oil and Gas
Industry,__:k@75-1978 ................................... 44
13 __ Forego'_n_e__Net Incom-e as the Resuit of-Pr4ohibition
of Hydrocarbon Exploitation in the Proposed
Sanctuary Boundaries, 1982-2006 .......... 0 ......... 45
14 Sectors of Economy and Associated Total Coefficients
With Total (Direct and Indirect). Requirements at
Lease of $0.01 Per $1.00 Output in Crude Petroleum
and Natural Gas-Production .......................... *54
15 Producers Wholesale Price Deflators for Crude Oil
and Gas, 1972 and.1980 ............................. 56
16 Value of Potential Annual Loss of Crude Oil and
Natural Gas in Constant 1972 Dollars, Resulting
from Prohibition of Hydrocarbon Exploitation in.
the 24 Tracts Withdrawn from Proposed Sanctuary,
1982-2000 ....................... 0 ......... 0..* ...... 57

Table No. Page

17 Value of Potential Annual Loss of Crude Oil and
Natural Gas in Constant 1972 Dollars, Resulting,
From Prohibition of Hydrocarbon Exploitation
in the 24 Tracts withdrawn from Proposed
Sanctuary, 1988-2006 ................................ 58
i8 Component of,Implicit GNP Price Deflectors Used and
and Other Deflectors Used .......................... 59
19 Indirect Annual Costs Resulting from Prohibition of
Hydrocarbon Exploration and Exploitation in the
24 Tracts withheld from Lease Sale #48, 1982-2000.. 60
20 Indirect Annual Costs.Resulting from Prohibition of
Hydrocarbon Exploration and Exploitation in the
Remaining Tracts of Proposed Sanctuary, 1988-2006.. 61
21 Direct and Indirect Annual Costs Resulting from
Prohibition of Hydrocarbon Exploration and .
Exploitation in the Proposed Sancutary, 1982-2006.. 63
22 Direct and Indirect Annual Costs Resulting from
Prohibition of Hydrocarbon Exploration and
Exploitation in the Proposed Sanctuary, Assuming
Normative Case ........ .............................. 66

LIST OF FIGURES

Figure No. Page

1 Location of the Southern California Bight ............. 6
2 Boundaries of Proposed Sanctuary (Northern
Channel Islands) .................................... 7
3 Boundaries of Proposed Sanctuary (Santa
Barbara Island) ..................................... 8
4 Location of Carpiteria Field, Santa Barbara
Channel and Lease Sales #35 and #48.
(Expired Tracts Not Included.) ...................... 13
5 Tract Location, Proposed Sale #48 ..................... 14
6 Tracts Leased in Lease Sale #48 in the
Vicinity of Proposed Sanctuary ...................... 15
7 Tracts Leased in'Lease Sale #48 in the
Vicinity of Proposed Sanctuary ...................... 16
8 Tracts Deleted from Lease Sale #48 .................... 18
9 Tracts Deleted from Lease Sale #48 .................... 19
10 Indu'stry.Interest in Lease Sale #68 ................... 20
11 Indication of Industry Interest in Tracts
Included in Call for Nominations for Lease
Sale #68 ............................................ 21

EXECUTIVE SUMMARY

The Office of Coastal Zone Management (OCZM), which is

responsible for the marine sanctuary program within the Na-

tional oceanic and Atmospheric Administration (NOAA), proposes

the designation as a marine sanctuary of the waters surrounding

the northern Channel Islands and Santa Barbara Island, extend-

ing from the mean high tide water line on the four northern

Channel Islands (San Miguel Island and adjacent rocks, Santa

Cruz Island, Santa Rosa Island, and Anacapa Island) and Santa

Barbara Island seaward 6 nautical miles (nmi). (11. 1 km) pur-

suant to Title III the Marine Protection, Research, and Sanctu-

aries Act of 1972.

If the sanctuary is designated,activities within the sanc-

tuary will be subject to necessary and reasonable regulations.

OCZM has proposed regulations for public review and comment

which would become effective if a sanctuary is designated.

The regulations would restrict, as necessary to protect the

sanctuary resources, oil and gas operations, discharges, alter-

ation and construction on the seabed, certain vessel operations

and overflights, and activities harming cultural and historical
resourcesY This report undertakes an analysis of the economic

impacts of the proposed Channel Islands Marine Sanctuaries

regulations.

l/ U.S. Department of Commerce National Oceanic and Atmospheric
Tdministration, Office of Coastal Zone Management, Draft Environ-
mental Impact Statement On the Proposed Channel Islands Marine
Sanctuary, 1979, Summary, pp. C-6 - C-9.

The National Oceanic and Atmospheric Administration Dir-
ectives Manual!-/requires that a formal regulatory analysis of

proposed regulations be undertaken if the proposed regulations

have certain negative or positive economic effects on the

economy industry, the public, employment, a region, etc.
b. A regulatory analysis shall be prepared for any
other significant regulation if that regulation, or in
the, case of an amendment to an existing non-significant
regulation, if the change resulting from that amendment--

(1) During any one year of its existence, can be
expected to result in an effect (direct or indirect) on
the economy exceeding $50 million;

(2) During any one year of its existence,, can be
expected to result in an effect (direct or indirect) on
either consumersl industries, levels of government, or
a geographic region exceeding $25 million;

(3) During any one year of its existencer can be
expected to result in an increase in costs or prices of
5% or more in the economic activities or sector(s) af-
fected by the'proposed regulation;

(4) Can *be expected to reduce labor productivity by
1 percent or more in the economic activities or sector(s)
affected by the proposed regulation;Z/

.(5) Can be expected to reduce employment by 5% or
more in the econom.ic activities or sector(s) affected by
the proposed rule orregulation;

(6) For, the particular market(s) affected, can be
expected to result directly oi indirectly in a 1% or more
decline in supply of materials, products or services, or
a 1% or more increase in consumption of those materials,
products or services; or

For the particular market(s) affected, can be
expected to result in a distinct decline in competition
as a result of the proposed rule or regulation. Factors
to be considered include limitation of market entryp
restraint of market information, or other restrictive
factors that impede the functioning 'of the market system.

l/ National Oceanic and Atmospheric Administration, Procedures
'for Development of Regulations 21-24, June 1, 1979, p. 5-6.
27 -Since changesin the resource base have very limited impact on
labor productivity this issue is not discussed in this' report.

This study evaluates the magnitude of the impacts resulting

from the proposed marine sanctuary regulations within the con-

text of the criteria for a Regulatory Analysis. The study

will increase the understanding of the economic impact of
the regulations and may also be useful in determining

whether a full formal Regulatory Analysis is required.

The only proposed regulations which can be expected to

have any significant economic impact are those affecting explora-

tion, development and production of hydrocarbon resources within

the proposed Sanctuary. The other proposed regulations deal

with activities which currently are minimal within the area

of the proposed sanctuary.(constructi6n or alteration of the

seabed) or apply in the limited nearshore zones (operations of com-

mercial vessels and overflights) in a manner which will have

no more than negligible economic effects. Therefore, this study

is limited to reviewing the impacts of the proposed regulations

restricting activities for exploration, development and produc-

tion, of hydrocarbons.
OCZM proposes to prohibit any activity for the exploration

or exploitation of hydrocarbons anywhere in the Sanctuary pur-

suant to leases executed on or after the effective date of the

regulations. This regulation may restrict access to certain

hydrocarbon reserves underlying the proposed Sanctuary. The
impact o'f thus restricting production is tihe focus of this study. l/

The proposed regulations have -no impact on-pre-exi'sting
leases except to require on-site location of certain oil 'spill
equipment. U.S. Department of Commerce National Ocenic and
Atmospheric Administration, Office of Coastal Zone Management,
Draft Environmental Impact-Statement on the Proposed Channel
Islands Marine q;4nctuary,__l5_7-9,p. C-7.

Methodology

Two scenarios have been developed to estimate socioeconomic

impact:

(1) The "normative case" which assumes that certain portions

of the hydrocarbon resources (approximately 40 percent)

associated with the proposed Sanctuary can be exploited

by directional drilling from tracts immediately outside

the proposed Sanctuary boundary; and

(2) The "worst case" which assumes that none of the

hydrocarbon resources associated with the proposed

Sanctuary can be exploited.

The normative case represents the most likley circumstance.

Directional drilling technology iscurrently well developed

and commonly utilized. Should any economically recoverable

reserves exist within the proposed Sanctuary, a substantial

portion could be recovered from activities outside the boundary.

The worst case analysis is presented to review the economic

impacts of the regulations under unrealistically restricted access.

There is no implication that the impact of the regulations is

expected to be any greater than that discussed in the normative

case,

A resource reserve estimate of. hydrocarbons underlying the

proposed Sanctuary was established by doubling existing official

United States Geological Survey estimates for 24 tracts-within

the Sanctuary. The estimates of hydrocarbon reserves on the

24 tracts are 5.7 million barrels of oil and 8.9 billion cubic

of gas. With.the exception of the estimate for the 24 tracts

discussed above, there are no official United States Geological

Survey estimates of hydrocarbon resources in the area of the

proposed Sanctuary for the currently unleased tracts which

would be affected by the proposed regulation. Limited explora-

tory activity by the oil and gas companies has taken place

within the boundaries of the proposed Sanctuary. No useful data

concerning resource estimates is available from these operations.

Thus, empirical nonproprietary information regarding oil and

gas resources for unleased tracts in the proposed Sanctuary

area is virtually non-existent.

Based on the only reserve estimate available and the

combination of the other factors listed above, economically

recoverable hydrocarbon reserves within the proposed Sanctuary

are extremely doubtful beyond 5.7 million barrels of oil and

8..9 billion cubic feet of gas. The expected economic impact of

the proposed regulations might arguably be limited to impacts

based on this only available official estimate. However, in

order to be extremely conservative in estimating the economic

impact of the proposed regulations we determined to double the

level of hypothetical reserves within the proposed Sanctuary, i.e.,

11.4 million barrels of oil and 17.8 billion cubic feet of gas, and

to comnlete the economic analysis on this inflated resource base.

The study relies in large part on the detailed data pre-

sented by the Department of the Interior (DOI) in its Final

Environmental Impact Statement and Secretarial Issue Document

on Lease Sale #48 and extrapolates, draws inferences and per-

forms analyses based on this information. For instance, expected

regional impact was established by computing the proportion that

estimated reserves within the proposed Sanctuary bear to the

estimated reserves for Lease Sale #48 and taking a like pro-

portion of DOI's regional impact figure.

Similarly, 'Production curves for Lease Sale #48 are utilized

to establish the likely production schedule of estimated re-

serves within the proposed Sanctuary. The difficulties in

such an approach are related to the fact that this methodology

essentially assumes exploration and distribution activities of

hydrocarbon resources within the. proposed Sanctuary to be

identical to those in the entire Lease Sale #48. There is no

compelling evidence that this indeed is the case.

Conversely? the absence of specific information pertain-

ing to the hydrocarbon resources within the Sanctuary requires

significant reliance on the data available for Lease Sale #48.

Direct impact on the economy was established by estimating

foregone market value of hydrocarbon products that could be

produced within boundaries of the proposed Sanctuary over time,

as well as by estimating the loss of net income to the oil and

gas industry, reduced employment and related factors all result-

ing from not exploiting estimated hydrocarbon resources within

the proposed Sanctuary.

IndIrect impact on the @eEmo_nomy was established by estimating

the foregone value over time of goods and services supplied by

other sectors of economy required by the oil and gas industry

if exploitation of hydrocarbon resources within the boundaries

of the'proposed Sanctuary would take place. The methodology

used was that of inter-industry model.

Conclusions

The results of the study concerning the normative case

are summarized here according to the criteria established in

the NOAA Directive.

(1) During any one year of its existence, can the regula-

tion be expected to result in an effect (direct or indirect)

on the, economy exceeding $50 million?

The total resulting from the annual direct loss of oil

and gas to the economy under normative case assumptions in the

first year of production is only 1.2 million. This loss in-

creases as the cumulative number of oil and gas wells are in-

creased and in the peak production year of 1992 the total.loss is

almost $30 million.- From thereon the annual losses decline as

the oil and as reserves are gradually depleted. (Table ES-1.)

(2) During any one year of its existence, can the

regulation be expected to result in an effect (direct or indirect)
on either consumers, industries, levels of government 1/,or a

geographic region exceeding $25 million?

United States Department of Interior originally estimated

that the entire Lease Sale #48 would add to the Gross Regional

Product of Southern California $519 million during the peak
year of hydrocarbon exploitation, i.e., 1986.@/

Impacts on the Federal Government cannot be estimated at
this time. Impacts on State and local governments are subsumed
in regional impacts.

2/ United States Department of Interior, Final Environmental
9tatement OCS Sale #48, Washington, D.C., 1972, Vol. 2, p. 1307

TABLE ES-1

DIRECT AND INDIRECT ANNUAL COSTS RESULTING FROM
PROHIBITION OF HYDROCARBON EXPLORATION AND
EXPLOITATION IN THE PROPOSED SANCTUARY,
ASSUMING NORMATIVE CASE

(in millions of dollars)

Year Total Costs

1982 1.17
1983 5.49
1984 11.00
1985 17 41
1986 20:40
1987 17.63
198.8 18.11
3,989 19.18

1990 24.51
1991 29.16
1992 29.96
1993 26.22
1994 25.21
1995 23.92
1996 20.25
1997 16.63
1998 14.08
1999 12.69

2000 10.82
2001 6.)9
2002 6.14
2003 5.71
2004 5.26
2005 5,00
2006 4:58

This impact was based on hydrocarbon r6source estimates

for Lease Sale #48 of 715 million barrels of oil and 860 billion

cubic feet of gas. Subsequently, Unitdd States Geological

Survey drastically reduced these resource estimates to only

104 million barrels of oil (a reduction of 86 percent) and

498 billion cubic feet of gas (a reduction of 42 percent).

Assuming proportional reduction in the increment to the Gross

Regional Product during the peak year of production this is

estimated to be only about $72 million.

Under normative case assumptions,hydrocarbon resources

located within the boundaries of the proposed Sanctuary that

will not be exploited by the oil and gas industry are com-

prised of 6.8 million barrels of oil and 10.7 billion cubic

feet of gas (60 percent of 11.4 million barrels of oil and

17.8 billion cubic feet of gas).

Thus, unexploitable oil resources in the proposed Sanctuary

represent only 6.5 percent of total revised oil resources in

the entire Lease Sale #48; in the case of gas resources, those

located within the boundaries of the proposed Sanctuary comprise

only 2.1 percent of total gas resource estimates in Lease Sale #48.

Assuming that the magnitude of regional impact is in

direct proportion to the resource estimates, such impact result-

ing from foregoing exploitation of hydrocarbon resources within

proposed Sanctuary under normative case assumptions during the

peak year of production should not exceed $4.7 million.

With regard to the socioeconomic impact on the consumers

the market for the oil and gas produced from the Lease Sale

#48 and therefore from tracts within the proposed Sanctuary
is that of entire United States*.!/ The for6gone quantity of

oil and gas from the proposed Sanctuary is infinitesimal when

compared to the magnitude of annual (1978) demand for oil and

gas products estimated to be over 7000 million barrels and there-

fore would have no effect on supply or cost to consumers, either

yearly or over the life of the field.

With regard to the impact on the oil and gas industry, the

recent data indicate industry net income to average about 5 per-

cent of total revenues. For the peak year of production, i.e.,

1992, since the foregone total oil production revenues are
estimated to be almost $30 millionY the impact of the proposed

regulations on the industry is therefore $1.5 million.

(3) During any one year of its existence, can the regula-

tion be expected to result in an increase in costs or prices

of 5 percent or more in the economic activities or sector(s)

affected by the proposed regulation?
As already indicated the magnitude of total foregone oil

and gas production within the boundaries of the proposed
Sanctuary over the entire life of these resources of 6.8 million

barrels of oil and 10.7 billion cubic feet of gas is miniscule

when compared to the annual (1978) domestic hydrocarbon produc-

tion of about 3200 million barrels of oil.

Thus, the impact of foregone oil and gas production within

the boundaries of the prposed Sanctuary on the costs orprices

in the economic activities related to oil and gas industry is

nil *
l/ United States Department of Interior, Final Environmental
"gtatement OCS Sale #48, Washington, D.C., 1972, Vol. 2, p. 1293.

2/ Note that the foregone total revenues of $30 million represents
loss to the economy and not to the oil and gas industry.

(4) Can the regulation be expected to reduce employment by

5 percent or more in the economic activities or sector(s) affected

by the proposed rule or regulation?

Department of Interior estimated additional employment

resulting from entire Lease Sale #48 during the peak year of
production at 14,629 persons.Y This estimate was based on

unrevi.sed hydrocarbon resource estimate for Lease Sale #48.

The revised employment estimate based on the more recent

hydrocarbon resource estimates for the peak year of production

would place additional employment needs generated by activities

associated with Lease Sale #48 at about only 2.000,persons.
The foregone oil and gas resources resulting from the pro-
posed Sanctuary regulations represent 6.5 percent of the total oil
.resources in Lease Sale #48 and only 2.1 percent of gas resources

in Lease Sale #48 and only 2.1 percent of gas resources

under the normative case assumptions. Some employment decrease

resulting from these foregone hydrocarbon resources can be

expected, however, because of the insensitivity of labor demand

to marginal changes in output this decrease will be small, and will

certainly not reduce total affected employment by 5 percent.

(5) For the particular market(s) affected, can the regulation

be expected to result directly or indirectly in a one percent or

more decline in supply of materials, products or services, or a 1

percent or more increase in consumption of those materials, pro-

ducts or services?

l/ United States"Department of Interior, Final Environmental State-
ment OCS Sale #48, Washington, D.C., 1972, Vol. 2, p. 1293.

.The magnitude of the foregone value oi@l and gas resources

within the proposed Sanctuary is too small in the relationship

to the domestic oil and gas industry to have any impacts.

(6) For the particular rnarket(s) affected, can the

regulation be expected to result in a distinct decline in

competition as a result of the proposed rule or regulation.

Factors to be considered include limitation of market entry,

restraint of market information, or other restrictive factors

that impede the functioning of the market system.

As in the previous case, because of the very small mag-

nitude and value of the foregone hydrocarbon resources within

the boundaries of the proposed Sanctuary these will have no

impact on competition in the oil and gas industry.

In summary, under the normative case assumptions the socio-

economic impacts both direct and indirect, on the economy, con-

sumers, industry and employment, resulting from foregone exploita-

tion of certain proportion of estimated hydrocarbon resources

within the proposed Sanctuary, are essentially insignifi(.;ant.

Further, the proposed regulations have no impact on costs,

prices or supply of materials, products and services.

As already indicated, the worst case scenario assumes un-

realistically restricted access to the hydrocarbon resources

within the proposed Sanctuary and stipulates that none of the

estimated 11.4 million barrels of oil and 17.8 billion cubic

feet of gas resources within the boundaries of the proposed

Sanctuary can be recovered.

As in the normative case the results concerning the worst

case are summarized here according to the criteria established

in the NOAA Directive.

(1) During any one year of its existence, can the regula-

tion be'expected to result in an effect (direct or indirect) on

the economy exceeding $50 million? .

Tables ES-2 presents annual summation from 1982 to the

year 2006 period of direct and indirect costs resulting if it is

assumed that the regulations would completely prohibit exploita-.

tion of the estimated hydrocarbon resources within the boundaries

of the proposed Sancutary.

As the data show, in the initial production year the total

costs of not exploiting these resources is less than $2 million.

These costs are estimated to be $49.94 million at the peak year

in 1992 only to decrease to $43.70-million in the following year

1993 and continue to decrease as the hydrocarbon resources are

depleted.

(2) During any one year of its existence, can the regulation

be expected to result in an effect (direct or indirect) on either

consumers, industries, levels of government, or a geographic

region exceeding $25 million:

The revised increment to Gross Regional Product for Southern

California resulting from Lease Sale 448 during the peak year of

production is estimated to be about -$72 million.

Under worst case assumptions, hydrocarbon resources located

within the boundaries of the proposed Sanctuary that will not be

exploited by the oil and gas industry are comprised of 11.4

million barrels-of oil and 17.8 billion cubic feet of gas.

TABLE ES-2

DIRECT AND INDIRECT ANNUAL COSTS RESULTING FROM PROHIBITION OF
HYDROCARBON EXPLORATION AND EXPLOITATION IN THE
PROPOSED SANCTUARY, 1982-2006

(in millions of dollars)

Direct Costs Indirect Costs
Remaining Remaining Total
Year .24 Tracts Sanctuary Total 24 tracts Sanctuary Total Costs

1982 1.85 - 1.85 0.1 - 0.1 1.95
1983 8.46 - 8.46 0.6 - 0.6 9.06
1984 17.18 - 17.18 1.1 - 1.1 18.28
1985 27.22 - 27.22 1.8 - 1.8 29.02
1986 31.72 - 31.72 2.2 - 2.2 33.92
1987 27.48 - 27-48 1.9 - 1.9 29.38
1988 26.43 1.85 28:28 1.8 0.1 1.9 30.18
1989 21.40 8.46 29.86 1.5 0.6 2.1 31.96

1990 19.48 18.87 38.35 1.2 1.3 2.5 40.85
1991 15.10 29.90 45.60 1.0 2.0 3.0 48.60
1992 12.20 34.84 47.04 0.7 2.2 2.9- 49.94
1993 10.75 30.25 41.00 0.7 2.0 2.7 43.70
1994 9.58 2�.83 39.41 0.6 2.0 2.6 42.01
1995 10.10 27.27 37.37 0.7 1.8 2.5 39.87
1996 9.09 22.56 31.65 0;,6 1.5 2.1 33.75
1997 8.41 17.51 25.92 0.6 1.2 1.8 27.72
1998 7.47 14.13 21.87 0.5 1.0 1.6 23.47
1999 7.40 12'.45 @19.85 o.5 0.8 1.3 21.15

2000 6.73 10.10 16.83 0.5 0.7 1.2 18.03
2001 10.71 10.71 - o.6 0.6 11.31
2002 - 9.63 9.63 - 0.6 0.6 10.23
2003 - 8.93 8.93 - 0.6 0.6 9.53
2004 - 8.21 3.21 - 0.5 0.5 8.71
2005 - 7.85 7.85. - 0.5 0.5 8.35
2006 - 7.14 7.14 - 0.5 0.5 7.64

Estimated oil resources in. the proposed Sanctuary rep-

resent only 11.0 percent of total revised oil resources in

the entire Lease Sale #48 and only 3.6 percent of total gas

resource estimates in the Lease Sale #48.

Assuming that the magnitude of regional impact is in

direct proportion to the resource estimates, such impact result-
ing from foregoing exploitation of hydrocarbon resources within

proposed Sanctuary under worst case assumptions during the peak

year of production should not exceed 7.9 million.

With regard to the socioeconomic impact on the consumers

the market for the oil and gas produced from tracts within

the proposed.Sanctuary is that of'entire United States. The

foregone quantity of oil and gas produced from the proposed Sanc-

tuary is infinitesimal when compared to the magnitude of annual

(1978) demand for oil and gas products estimated to be over

7000 million barrels, and therefore would have no effect on supply

or cost to consumers, either yearly-or over the life of the field.

The impact of the total loss from foregoing production of

oil and gas resources within the boundaries of the proposed

Sanctuary on the oil and gas industry can be readily estimated

by calculating the lost net income to the industry resulting

from not exploiting the hydrocarbon resources within the pro-

posed Sanctuary boundaries.

Recent financial data on the oil and gas industry indicates

net income as percent of total revenues for this industry

averages about 5 percent. Applying this statistic to the value

of lost production yields a measure of the impact of proposed

Sanctuary regulations on the oil and gas industry (Table ES-3).

TABLE ES-3

FOREGONE NET INCOME TO THE OIL AND GAS INDUSTRY AS THE RESULT
OF PROHIBITION OF HYDROCARBON EXPLOITATION IN THE
PROPOSED SANCTUARY BOUNDARIES, 1982-2006

Foregone Profits
Year (in thousands of $)

1982 $92.5
1983 423.0
1984 859.0
1985 1,361.0
1986 1,586.0
1987 1,374.0
1988 1,414.0
1999 11490.5

1990 1,917.5
1991 2,250.0
1992 2,352.0
1993 2,050.0
1994 11970.5
1995 1,868.5
1996 1,582.5
1197 1,093.5
1998 992.5
1999 960.9

2000 841.5
2001 535.5
2002 481.5
2003 446.5
2004 410.5
2005 392.5
2006 257.0

As the data indicate, the loss of profits to the oil and

gas industry is not significant. In the pak year of produc-

tion, i.e., 1992, this loss is estimated to be only $2.3 million.

(3) During any one year of its existence, can the regula-

tion be.expected to result in an increase in costs or prices of

5 percent or more in the economic activities or sector@s)

affected by the proposed regulation?

The magnitude of total foregone oil and gas production

within the boundaries of the proposed Sanctuary assuming worst

case scenario over the entire life of these resources of 11.4

million barrels of oil and 17.8 billion cubic feet of gas re-

mains miniscule even in worst case scenario when compared to the

annual (1978) domestic hydrocarbon production of about 3200

million barrels of oil.

Thus, the impact of foregone exploitation of all oil and

gas resource estimates within the boundaries of the proposed

Sanctuary on the costs or prices in the economic activities

related to oil and gas industry is insignificant if any at all.

(4) Can the regulation be expected to reduce employment

by 5 percent or more in the economic activities or sector(s)

affected by the proposed rule or regulation?

The revised employment estimate based on the more recent

hydrocarbon resource estimates for the peak year of production of

Lease Sale #48 would place additional employment needs generated

by activities associated with Lease Sale #48 at about 2000 persons.

The foregone oil and gas resources estimated within the

boundarieg of the proposed Sanctuary represent 11 percent

of total oil resources in Lease Sale #48 and only 3.6 percent.

of gas resources under the worst case assumptions. Some employ-

ment decrease resulting from these foregone hydrocarbon resources

can be.expected, however, this decrease will be marginal and

will certainly not reduce total affected employment by 5 percent.

The principal factor accounting for this negligible impact on

employment is the fact that marginal changes in production (such

as these resulting from prohibition of all hydrocarbon resource

exploitation in the proposed Sanctuary) of offshore oil and gas

have n.0 direct impact on labor demand because of the insensitivity

of labor demand to marginal changes in output.

(5) For theparticuILAr market(s) affected, can the regulation

be expected to result directly or indirectly in a 1 percent or more
decline in supply :of materials, products or services, or a 1 per-

cent or more increase in consumption of those materials, products

or services?

The magnitude of the foregone value oil and gas resources

within thO- proposed Sanctuary even under the worst case assmptions

is too small in the relationship to the domestic oil and gas

industry to have any impacts.

(6) For the particular market(s) affected, can the regulation

be expected to result in a distinct decline in competition as a

.result of the proposed rule or regulation. Factors to be con-

sidered include limitation of market entry, restraint of market

informationp or other restrictive factors that impede the func-

tioning of the market system?

The very small magnitude and value of the foregone hydro-

carbon resources assuming worst case scenario will have no impact

on competition or market system in the domestic oil and gas

industry.

In summary, even under worst case assumtpions, the socio-

economic impacts both direct and indirect, on the economy, con-

sumers, industry and employment, resulting from foregone exploita-

tion of all estimated hydrocarbon resources within the proposed

Sanctuary, are not significant.

The proposed regulations have no impact on costs, prices or

supply of materials, products and services.

"The Proposed regulation prohibits any activity
introduction for the exploration or exploitation of hydrocarbons
(oil and gas) anywhere In the sa nctuary pursuant
The Marine Protection, Research and sanctuaries Act Of 1972 to leases executed on or after the effective date
(16-U.S.C. 1431-1434) authorizes the Secretary of commerce, after of these regulations. Exploration and development
pursuant to leases predating the effective date
of the regulations and the construction of pipe-
consultation with appropriate Federal agencies, concurrence of lines are allowed subject to all proposed sanctuary
the affected State, and Presidential approval, to designate ocean regulations and all regulations and conditions in-
posed by the following entities: the Department of
the Interior, the U.S. Coast Guard, the Corps of
areas having distinctive conservation, recreational,.ecological, Engineers, the Environmental Protection Agency, the
or aesthetic values as marine sanctuaries. In 1977, the National State of California under the Federal consistency
provisions of the Coastal Zone Management Act, and
any other State or Federal authority. This activity
Oceanic and Atmospheric Administration (NoAA) of the.Department is permitted subject further to the requirement that
certain oil spill contingency equipment is present
of commerce sent a letter nationwide asking for recommendations for such operations (See Section F.2.b.1). This
regulation is designed to reduce the risk of con-
for sites appropriate for consideration as marine sanctuaries.- tamination of the nearshore resources by spilled
oil, and to protect the island shores from visual
The response included several different recommendations for the and acoustic disturbances." I/
waters around the northern Channel islands and Santa Barbara Proposed designation of the Channel Islands as a
island. marine sanctuary accompanied by those and other regulations
The Office of Coastal Zone Management, which is responsible may result in Increased protection of the resources necessary
for the marine Sanctuary program within NOAA, proposes the desig- to the continuing v .itaility of certain sectors of the economy.
nation as a marine sanctuary of the waterssurrounding the notably commercial fishing and tourism. The local economy may
northern Channel islands and Santa Barbara island, extending thus benefit from increased production, increased regional
from the mean high tide water line on the four northern Channel income, increased employment and increased wages and salaries.
Islands (San Miguel island and adjacent rocks, Santa Cruz Islande
Conversely, the proposed regulations may have certain
Santa Rosa island, and Anacapa island) and Santa Barbara island nega -tive economic impacts on the oil and gas industry operating
sea-ward 6 nautical miles (nmi) 111.1 km) . in this area. The National Oceanic and Atmospheric Admin-
If the designation is adopted, certain activities will 2/
Istration Directives Manual requires that a formal regulatory
be subject to necessary and reasonable regul .ations. The most
I/ U.S. Department of Commerce National oceanic and Atmospheric
economically significant of these is hydrocarbon operations# Kdministration, office of Coastal Zone Management, Draft'Environ-
mental Impact Statement On the PrO22sed Channel Islian-di'll-ar-In-e-
i.e., exploration, development and production of oil and gas. Sanctuary, 1979, p. C-7._
2/ National oceanic and Atmospheric Administration, Procedures
To be quite specificp the office of coastal zone Management 'For Development of Regulations 21-24,
June 1. 1979,
proposes the following regulations with respect to the hydro-
carbon operations: 2'

analysis of the proposed action be undertaken if the proposed
The objective of this study is to determine the magnitude
action has certain negative or positive economic effects on an of the impacts resulting from the proposed marine sanctuary
industry, the public, employment, a regicni etc. T@ be specific
regulations of hydrocarbon exploration and exploitation within
the following are the criteria requiring regulatory analyses:
the context of the seven point criteria for Regulatory Analysis.

The study will increase the understanding of the economic
b. A regulatory analysis shall be prepared for any
other significant regulation if that regulation, or in impact of the regulations and may also be useful in determining
the case of an amendment to an existing non-significant
regulation, if the change resulting from that amendment-- whether a full formal Regulatory Analysis is required.
(1) - During any one year of its existence, can be The data sources used in this report are principally
expected to result in an effect (direct or indirect) on those of
the economy exceeding $50 million; the Office of Coastal Zone Management, United States
(2) During any one year of it's existence, can be Geological Survey and other official Federal government offices.
expected to result in an effect (direct or indirect) on
either consumers, industries, levels of government, or However, other data sources are used and identified.
a geographic region exceeding $25 million;
This report was prepared by Sterling Hobe Corporation.
(3) During any one year of its existence, can be
expected to result in an increase in costs or.prices of Ivars Gutmanis and Lucinda B. Blakeslee were the principal
5% or more in the economic activities or sector(s) af-
fected by the proposed regulation; authors.

(4) Can be expected to reduce labor productivity by
I percent or more in the economic activities or sector(s)
affected by the proposed regulation;!/

Or Can be expected to reduce employment by 5% or
more in the economic activities or sector(sl affected by
the proposed rule orregulationi
(6)* For the particular market(s) affected, can be
expected to result directly oi indirectly in a 1% or more
decline in supply of materials, products or services, or
a 1% or more increase in consumption of those materials,
products or services; or
(7- the particular market(s) affected, can be
expecied to result in a distinct decline in competition
as a result of the proposed rule or regulation. '@ Factors
to be considered include limitation of market entry,
restraint of market information, or other restrictive
factors that impede the functioning of the market system..

I/ Sincd-chang-e-sin th-e- resource base has very limited impact on
labor productivity this issue is not discussed in this report..

Background

The proposed Channel. Islands Marine Sanctuary lies within

referred to as the'Southern California Bight (see Figure I).
the northern portion of a regional coastal ocean area commonly

HAUTCAL IULFS

0
The Office of the Coastal Zone Management proposes the creation
of the Channel Islands Sanctuary in the waters around the San Francisco

northern Channel islands and Santa Barbara Island extending
6 nmi (11.lkm) seaward from the mean high tide line (Figures 2
CALIFORNIA
and 3).

According to the Office of Coastal Zone Management:-
Point Conception
"This area was selected in large part because
Southern California Bi
of the extraordinary concentratlon of the follow 9@h
ing resources: (1) marine mammals; (2) seabirds; __-Los Angeles
(3) fish, shellfish, and kelp resources; (4) inter- '5
tidal organisms; and, to a lesser extent, (5) arch- San Miguel Is.
aeologic/historic resources." Santa Rosa Is. Diegg
San
However, the general area where-the proposed Sanctuary is located
Santa.Cruz IS. R,
I@'% " '- MEXICO
is also a potential tource of hydrocarbon resources and has Anacapa Is.
experienced considerable oil and gas exploration and exploitation
San Nicolas Is.
activities, although this activity-has been minimal in the site Santa Barbara Is. \1
actually proposed for Sanctuary designation.

Development of the Federal OCS lands in this area began in Santa Catalina Is.

San Clemente IS.
1966 with a lease sale to allow development of a known field

(Carpinteria) in Federal waters. In 1968, the first Federal

lease sale was held in the Channel. Federal development in the

Channel continued with OCS Lease Sale #35 in 1975 and Lease
Sale 448,in June 1979. BLM plans to hold two additional sales

l/ U.S. Department of Commerce National Oceanic and Atmospheric FIGURE I
Administration, Office of Coastal Zone Management, Draft Environ-
mental Impact Statement on the Proposed Channel IslaRds Marine LOCATION OF THE SOUTHERN CALIFORNIA BIGHT
Sanctuary, 1979, p. C-1.

33.4-. za

601.920

MAW

0
S3a.SW

w C3
Z
0
Z 11
rq 0

0 r)
-3 1 r+
>

"IS20,

33-2V

--MGM

.1 -1 FIGURE 3.
BOUNDARIES OF PROPOSED SANCTUARY'
(SANTA BARBARA ISLAND)

in the Southern California Bight (which includes the Santa %0 %a %0 ko %D
00 CO %0
_J 0% 0% 0%
Barbara Channel) in the next three years: Sale f68 in 1982 and Li %Q C10(A %D

sale #73 (which may be statewide) in 1983. Sianificant milestones

in the history of oil and gas development in the Santa Barbara
Channel and in the vicinity of the northern Channel Islands M, En
are summarized in Table 1. M
R
M,
Expected Hydrocarbon Reserves
There is, unfortunately a paucity of information as to Z .0.

the oil and gas-reserves in this area in general and within
CA
the proposed Sanctuary in particular. Establishing the level &r
o
C4 rr
of expected reserves is a principle component in this econ- 1A
omic analysis. The estimate of reserves will include only
0
W C;
co M
those tracts beyond the 3 nmi territorial sea. The State of

co so
California prohibits the leasing of its tidal and submerged

0
lands around the Northern Channel Islandsand Santa Barbara

PJ
Islands through state legislation establishing oil and gas

s;anctuaries and through the implementation of its Coastal

Act. The impact of the proposed Sanctuary regulations must

therefore be gauged by the additional restrictions on hydro-

carbon exploitation on the Outer Continental Shelf beyond state

jurisdiction. All discussions of estimated reserves thus apply

to the area from the territorial sea to the 6 nmi boundary.

The only available information regarding oil and gas reserves

was developed by the United States Geological Survey in connec-
tion with Federal lease sales for oil and gas exploration and

exploitation.

10
9

%D 10 ko %0 M
he data in Table 2 indicate, the Geological Survey @4 0%
As t Ln CO 0%
established oil and gas reserves for the first Federal Lease (n n
W Do
0
Sale in 1966 at 610 million barrels of Oil and 580 billion Cr
to rt
cubic feet of gas; for Lease Sale #35 held in 1975: of 719 0 (D
CO
million barrels of oil and 997 billion cubic feet of gas; and M
for Lease Sale #48 held in 1979 of 104 million barrels of oil
0 M
91
and 498 billion cubic feet of gas (see Figure 4 for location of V
those tracts leased in these Lease Sales. However, the area M
to which each estimate of reserves applied was much larger.
r)
For instance, the area to which the estimate of reserves in 0
z
Lease Sale #48 applied is represented by Figure 5.)
>
z
Lease Sale #48 is of particular interest to us because
the area borders the proposed Sanctuary (Figures 6 and 7) and Ln
U) M 0
because estimates of reserves developed by the United States
W rt
Geological Survey, during the pre-Lease Sale evaluation,
0
z
indicate that the reserves in the Southern California Bight, 0
z
the Santa Barbara Channel, and the proposed Sanctuary are t@
>
much more limited than had been projected by earlier estimates, in
H. 0

W
The United States Geological Survey's final estimate of %0 >
0 P. 0 t--
:3 M
the hydrocarbon reserves for the entire Lease Sale #48 was 0 LO
104 million barrels of oil and 498 billion cubic feet of gas. '00
M
0
In addition, an estimate of reserves within the proposed Sanc-
tuary was developed due to the following circumstances. MM
0
Based on environmental concerns, a total of 24 tracts within <
(D
the proposed Sanctuary were removed from Lease Sale #48. The Lq (p 0 tn

Ir
e, M I
%
0 :-.N 4-1
3s.
mom
0 81 20
Par
3 Ide
-R'@�r
028029

40 0

05 057

08 co@
9 426 T6
17. Coll 0 00910 08 221,220 21 el
078
12 21 097
Wfta Q5
% Kh
C"tb I* Itcn
n
SAN MKAXL ANACAPA
ISLAND 49@
PAM CPA
X&AND
Iv!P&WM 111011A
%
.. ARAND,,t -

w 61F

4-
19 WON

Figure 4. Location of Carpiteria Field, Santa
Barbara Channel and Lease Sales #35 and
#48. (Expired tracts not included.)
IM Carpiteria Field (1966) M
RR Santa Barbara Channel (1968
Lease Sale #35 (1975)
Lease Sale #48 (1979)

TRACT LOCATION OEPA UNIT
RTME
PROP03ED IWAS NO. 40 BUREAU OF
PACIFIC OUTER

SOUTHERN CAL

T.
A\
Ism . . .

IN It* F111111,
4166152 Its t
V/W, Raft 4A r is tI-ft
fed"m b@
.14
/NUMERIC
TIFICATION

/17,
. . . . . . . . ..

A . . . . . . . .

------ - ----

Figure 5. Tract Location Proposed Sale t48

"low ARBAR

skvrfx HF.7,

Ww 24W
ANTA CRUZ ISLA&D
F-J V, -129 8AMrA ROSA IstA)VI,
Inc

3w
3ww

Figure 6. Tracts Leased in Lease Sale #48 in the
. Vicinity of Proposed Sanctuary,

33, 20' 10,

.,-617,760

0 -D
16017920
601.920'

586,080' 586,080

570.240' 570,240

4CY 554,400' 4- .40,
654,400

S38.SW 538,560'

102 100

5=720! 522,720'

104

506.880. 1

30'
Cw. 30'
491.040' F +-91.
sAi@rA
BARBARA
475,200' ISLAND 475.200'
96

459,360' 459,360

22
443,520' 90 "3,520'

33'2(Y
+ 33*2C'
.427,680 427,680'

N Pj

119*20,
10, 119.0cr 118-50
24

Figure 7. Tracts Leased in Lease
Sale #48 in the Vicinity
PREFERRED MARINE
of Proposed Sanctuary SANCTUARY BOUNDARY
01C=r= M14.13-0.

office of Coastal Zone Management had requested this deletion

because these tracts were located within the boundaries of

the proposed Sanctuary (Figures 8 and 9). Several other re-

quests for the deletions were received from various sources.

The United States Geological Survey estimates hydrocarbon re-

serves on these 24 tracts to be 5.7 million barrels of oil and
8.9 billion cubic feet of gas.i/

As stated previously, the proposed Sanctuary reglations pro-

hibit future hydrocarbon exploration and exploitation activi-

ties in the proposed Sanctuary except on leases which exist

prior to the effective date of the Sanctuary regulations.

However, with the exception of the estimate for the 24 tracts

discussed above, there are no official United States Geological

Survey estimates of hydrocarbon resources in the area of the

proposed Sanctuary.for currently unleased tracts. Limited

exploratory activity by the oil and gas companies has taken

place within the boundaries of the proposed Sanctuary (Table 3).

No useful data concerning resource estimates is available from
these operations.Z/ Thus, empirical nonproprietary information

regarding oil and gas resources for unleased tracts in the

proposed Sanctuary area is virtually non-existent.

l/ Keith Meekins, Geologist, Lease Sales Activities Section,
USGS, March 3, 1980.

2/ For instancel, of the seven tracts within the proposed Sanc-
:Euary, upon which leases were terminated or expired and upon
which exploratory drilling occurred, one well was tested and de-
clared a discovery by USGS, others had no indications or slight
indications. Tom Dunaway, Chief of Operation, Inspection and
Lease Management, USGS, Pacific OCS Region (conversation,
4/30/80).

317 w IV

.SAW
AR"AR
IMIW iqr.I,

:;Zz?

SAWA
CRUZ
CO SAWA #OSA "MAND
@4-

Figure 8. Tracts Deleted from Lease Sale'448.
NN-1
@8AWA,,,,,
EE-4

119*
33-49* 10? 119,07
-617,760*

ab po w

W 1.920'

W.080, 586,083
1570.240' 570.240*

400
SS4.400' 4(Y

538.56a S3&560'

102 too
522.720' 163

506.8W-1
30' 491.040r d^ + 317
SANTA
BARBARA
475=* ISLAND 475.200'1

459,3W' ss 459,360'

23
92
443.SM'

33*2a

33*2C,

-427,680 427.680-

ab b)
119*20, 411.840
1(y 1191W 118-W -- -

Figure 9. Tracts Deleted from Lease
Sale #48 PREFERRED MARINE
SANCTUARY BOUNDARY
DIMTT= MMM-0. lot
9

qi;@ Berm

2 j.- 4
"R,
2

5%jew P rre
2 2 2 1
.r 1,211
2
U6 175 1 1A -.I J
A 4-1 -, 4
P"Asw 2 4J.: -.. - t.- 7-.
2 .170 go 92 93 94
P2 05 go 21,
169 -goo Oft"
Ise too OF 105
3 go -99 toz "20 6% 901 300 10
3 3 11L 167 103
N*v Ole_
3 3 '"QUOL &-ft
14 N.

3 SAWA
3 CRUZ
)@ . -.. , ISLAIV13 - A
1,,3 SAIr4 "A
3 3 %3 :3 OAhv
3.
f 3 N. M11e5 3
04
of:z
.*ee. 3 3
3 13 3
Sneer
2 2 1-+2 3
3 2 2 2 3
an
3 -3 2 2 2

2 2
3 3 _2 2 L ------ JL-

Tracts:l-ease'd prior to lease Sale #40R
High Industry
-X% Tracts leased in lease sale 48 2
Moderate Industx
[]'Tracts.deleted fran lease Sale 68 3
Low Inddstry in
C>
FIGURE 10 - Industry Ifiteriest in Leabe sale
#.6 8

3. 2 2 _3 3

2 -3
2 2
@3
There are, howeverr several circumstantial indicators
601,920
3 3 3 3' 3 which suggest that oil and gas resources within the boundary
MAO of the proposed Sanctuary are limited.
3 3 1 -3 3 3 The first of these pertain to the significant reduction
S702.0
-S70.m, in oil and gas resource estimates for the entire Lease Sale
3 3' 3 3 3 3,
#48 by the United States Geological Survey. originally, the
-SUAW, United States Geological survey estimated oil resources for
3 3, 3.
Lease Sale #48 at a total of 715 million barrels of oil; the
revised estimate is only*104 million barrels, a reduction of
2 '3 5U.720 86 percent. Similarly, whereas the original estimate for gas
SM7W 0
resources within Lease Sale #48 was 860 billion cubic feet, the
.2 revised estimate is 42 percent lower--only 498 billion cubic
@ @@BWWO

feet.

Further, the United States Geological Survey hydrocarbon
MUND
resource estimates for the 24 tracts removed from the proposed
Sanctuary boundaries are modest when compared to resource
estimates for other tracts--only 5.7 million barrels of oil
and 8.9 billion cubic feet of gas, indicating very limited
31" hydrocarbon resources in this general area.
Additional support for this hypothesis is lent by the fact
3,11-W 332V
that a total of 19 tracts which were leased in earlier sales

and which are Iodated within the proposed Sanctuary have

expired without any development or production activities by the

oil and gas industry. Exploratory drilling had occurred an

at least 7 of these tracts (Table 3).
Tracts leased prior t6 Lease Sale 48 1 High Industry Interest
Tracts leased in lease Sale 6 48 Ybderate Industry Interest
4M

Tracts deleted from Lease Sale 68 .,3 low Industry Interest

FIGUM 11. Indication of industry Interest in Tracts ImIuded in Call
for Ncminations for Lwse Sale 68 21

Finally, the historical dat

tion platforms (Table 4) shows a
Table 3. Number of wells drilled on existing leacs;, ?.)I or hydrocarbon resources some dista
partially within 6 nmi (II.Ikm) of the northern
Channel Islands and Santa Barbara Island (also see proposed Sanctuary. While one c
Figure E-22). (Adams, 1979, personal camunication;
U.S. Bureau of Land Management, 1979 (Visual No. 1); reason for this is the historica
U.S. Bureau of Land Management, 1978a).
the vicinity of the proposed San

the distances between the sites
boundaries of the proposed Sanct
Tnm ZZ .7M Cwtm su@
167 M Ki-1 I TC.td number of leases sold prior to L
M 5- M71 0 T.IiMtd
169 S- Ki-1 I W 1-tAd the proposed Sanctuary suggest t
170 SM Kig.1 I ENPired " Te-imted
172 3- Kiq"I 0 bp1red w Terftmted
1'4 "n Mwl bpLrd Tvq@tw has, at least historically, pref
11S S- ni7ml 0 !Vlred Teqmimted
176 U. ftq-@l 2 b@pi-d or [email protected]
177 9-419-1 CVired or Ternimted
1.
'g "M Mique or T--,,J--td those in the vicinity and/or wit
179 S- Kiqua I bpimd M Toqmi-ud
leaEb in part because of limited
243 s6m& P 0 ?
244 MAU 0 ch ?
245 --W' M P- cv* ? ability within these boundaries.
246 saw ft 0 ?
247 ? Based on the only reserve e

200 S-t. cr 0
201 9-A tra CVi:ed M Tem. i@ted combination of the other factors
2" unt. crMs 0 bpizd W Tt-dmtd
21, Wt. t--.t Ch0q= ? recoverable hydrocarbon reserves
21, S.M. OqM bpi-d = T@-,Aimud
712 Wt. I &;,i---d = Tez-dmqW
21) 0 CVL-d w Urmimud are extremely doubtful beyond 5q.
198 Aq-Pa 0 b9ired m Termimted 8.9 billion cubic feet of gas.
qM A-@P% 2 b9ired w Termimted
20Z A--p. D-elap@m
20) A'.C.P4 4 urz(A E*lcrnmy Drilhq proposed regulations might argua
204 k.-P. 1. chq@ EVIo-wry DriUkq
205 A-Cq" 2 ch@q@ DqAq@wry Drillirg
208 A-pa 1. Chq@ EvIcrawry Drinim based on this only available off
2D9 Aq-@Pa 1. chvvq@ bq@q@Itxy Drilliq
us EVI-Y
order to be extremely conservati
209 Unta bubq@ I ftbil I
29' S-t. hmtra 0 Wbil 7
2% S-ts gub@a 0 Pbbil ? impact of the proposed regulatqio
ch-"q@ X P1- fm -Pl-t-ry --1-16 P-0204-1. P-020e-2. F-0.09-2 the level of hypothetical reserv
ard q"22.1,2 q@z r--*,aly MMq@ed by VMS. Im p1m q@ cert-@fied
[email protected] with qW-Ifari"' q@Ul PlAn by the Cftlif=niA Cq@tftl
C-q@I. . D.q. 12. 1978. tuary and to complete the econorn
7 As
resource base.

23
24

Doubling the resource estimate is extremely generous.

All indications discussed above suggest that the resources in

this general area are extremely limited. The 24 tracts orig-

inally considered and later deleted from Lease Sale #48 en-

compass most of the unleased area in the proposed Sanctuary

where the oil and gas industry has high interest. The subsequent

Call for Nominations for Lease Sale #68 has evoked limited res-

ponse. Industry indicated no interest in 54 tracts, or por-

tions of tracts, within the proposed Sanctuary; low interest

in 26 tracts or portions therof; moderate interest in 10 tracts or portions; and high interest in 20 tracts or portions (Fig-

ures 10 and 11).___Only the last two categories will be fur-

ther evaluated for possible leasing in Sale #68. Since the

number of tracts in which industry has indicated moderate or

high interest roughly equals the number of tracts deleted

from Lease Sale #48, we determined to double the resource esti-

mates from the 24 tracts deleted from Lease Sale #48. This

assumes the reserve estimate for the remaining unleased Federal

portions of the Sanctuary equals that in the 24 tracts.

The Channel side of the Islands represented by the 24 del-

eted tracts has much higher industry interest and reserve po-

tential than the rest of the proposed Sanctuary. (Figures 10 and

11). As note above, industry expressed no or low interest ing

73 percent of the tracts or portions thereof within the proposed

Sanctuary included in the Call for Nominations for Lease Sale #68.

1/ Memorandum from Manager, BLM Pacific OCS Office and Acting

Conservation Manager, USGS Pacific OCS Region to Assistant Dir-

ector, BLM Mineral and Energy Resources and Chief, USGS Conserva-

tion Division; Subject: Tract Selection Recommendation for Sale

68, Southern California, April 7, l980. There was no interest

indicated in any tracts within the proposed Sanctuary boundary

surrounding Santa Barbara Island.

Therefore, doubling the united States Geolo4ical Survey hydro-
(1) The "worst case- which assumes that none of the hydro-
carbon resource estimates for the 24 tracts withdrawn from
Leas e.Sale #48 by the Secretary of the Department of Interior carbon resources associated with the proposed Sanc-
tuary can be-exploited; and
appe.ars.mome than generous and results in a hypothetical re- (2) The'"normative case" which assumes that certain por-
source reserve estimate of 11.4 million barrels of oil and .. 17.81 tions of the hydrocarbon resources associated with the

billion cubic feet of gas. proposed Sanctuary can be exploited by directional
This estimating procedure establishes an outside parameter drilling from tracts immediately .outside the proposed
for possible reserves and will allow us to provide measurest Sanctuary boundary.
admittedly approximate and inflated, of the socio-econo-ic
The normative case represents the most likely circumstances.
impacts which might result from curtailment of hydrocarbon ex-
Directional drilling technology is currently well-developed and
plor loitation within the boundaries of the pro-
aticn, and exp commonly utilized. Should economically recoverable reserves
posed Sanctuary. exist within the proposed Sanctuary, a substantial portion could
be recovered from activities outside the boundary. The worst
Socioeconomic LWpa n from case reviews the economic impacts of the regulations under
Curtailment.ot Hdctocoa@bpo@nopEoxspeLr:!It-lcltnu:711 ;erZu1-t!Hn
ar unrealistically restricted access. There is no implication that
As we have already indicated, for purposes of this analysis,
esti- the impact of the regulation is expected to be any greater than
hydrocarbon reserves in the proposed Slanctuary area are
that discussed in the normative case. A number of issues related
mated at about 11.4million barrels of.oil and 11.8 billion cubic
to the socioeconomic impact analysis must be clarified before
feet of gas. While this estimate is highly putative and generous,
we undertake analyses-of the two cases.
there is no informationt'other than proprietory towhich there
is no iLccess, which would reduce possible errors a. ssociated with Value of Hydrocarbon Resources
these estimates. The first of these issues is related to the valuation of
Creation of the proposed Sanctuary would partially,or com- oil and gas resources. In the case of oil, all of the oil
pletely preclude exploitation of these hydrocarbon resources& reserves in the vicinity of the proposed Sanctuary represent
..which in turn would result in certain socioeconomic impacts. new oil" with the current (May 1980) price of $14.00/barrel.
This chapter analyzes the pertinent socioeconomic impacts by However, this price is being phased out at a rate of 3 percent
type of effected party. It is important to note that we pre- per month and it is reasonable to assume that at the t.ime
sent this.im rent asstimpt' production from these reserves could begin, i.e., 1982, the
.pact analysis under two diffe ions:.

27 28

complete decontrol of prices will have occurred and the price
TABLE 5
of domestic oil will be permitted to equal world prices. There
ASSUMED CRUDE OIL PRICES 1982-2006
are no valid projections of world oil prices and our discussion (per barrel of crude oil)

with several industry experts suggest that such projections

should not be based on historical time series data. Several of Year Price
these industry experts have suggested that the 1982 price of
1982 $37
oil, $37 per barrel, is a reasonable estimate and that further 1983 37
1984 37
increas&s to $40 per barrel by 1985 can be expected. 1985 .37
1986 :37
We propose to use these estimates and are assum- 1987 @37
1988 .37'
ing further price increases in crude oil to $45 per barrel 1989 37
by the year'1995 and to $47 per barrel after the year 2000. 1990 40
1991 40
(See Table 5). Projections of future gas prices is an even 1992 40
1993 40
more difficult undertaking. The available information on 1994 40
1995 45
future gas contracts suggests that a price of $6 per 1,000 1996 45
1997 45
cubic feet of gas by 1982 is reasonable estimate. Table 6 1998 45
1999 45
provides information on our assumptions regarding gas prices
2000 45
in the 1982 to 2000 period, 2001 47
2002 47
2003 47
Production Rates Over Time 2004 47
2005 47
We have estimated annual production rates for oil and 2006 47

gas located within the boundaries of the proposed Sanctuary

from data presented in Table 7., which shows Bureau of Land

Management annual projections of oil and gas production for
the entire Lease Sale #48.i/

I/ Note-that these production projections are based on the
Friginal,unrevised oil and gas resource estimates for Lease
Sale #48. However, since we require here the annual rate
of production, i.e., percentage-of oil and gas withdrawn
annually from the estimated resources based on technological
and related factors, changes in the absolute values of these
resources'is of margiii@l importance.
30

29-

TABLE -7
TABLE 6
MOST PROBABLE VALUES FOR OIL AND GAS PRODUCTION AND PRODUCING WELLS
ASSUMED NATURAL GAS PRICES, 1982-2006 Cumulative
(per 1000 cubic feet) Annual Production Da y Produ on Number of
oil (MB)a 1' ct! Producing Wells
YEAR Gas (MKCF) Oil (B) G. (HCF)

1979 0. 0 0 0 0
Year Price 1980 0 0 0 0 0
@1981 0 0 0 0 0
1982 $6 1982 5,000 6 '000 13.700 16,400 19
1983 6 1983 21,100 25,400 .57,700 69,600 84
1984 6 1984 52,200 118,900 143,000 205
1983 6 68,500 .82.400 187,700 225.800 367
1986 6 1986 80,200 96,500 219,700 264,400 512
1987 6
1988 6 1987 78,800 94,800 216,000 259,700 617
-1989 5 1988 67,500 .91,200 185,000 222,500 673
1989 53,700 64.600 147.000 177,000 695
11990 7 1990 42,100 50,600 115,400 138,600 701
1991 7 1991 33,700 40,500 92,400 111,000 701
1992 7 1992 28,300 34,000 77,600 93,200 701
1993 7 1993 24,700 29,700 67,800 81,400 701
1994 7 1994 22,000 26,500 60,300 72,600 701
1995 9 1995 19.800 23,800 54o3OO 65,200 701
1996 9 1996 18,100 il'BOO 49.,500 59,700 701
1997 9
1998 9 1997 16,600 20,000 45,500 54,800 701
1999 9 1998 15,300 18,400 42,000 50,400 701
2000 9 1999 14,300 l7j2Od 39,300 47.160 701
2001 10 2000 13,300 16,000 36,500 43'0800 701
2002 10 TOTAL 666,400b 801,600b
2003 10
2004 10
2005 10 Source: USDI, .1977.
2006 10 V
IM equals 1000.
11nis cumulative total is for 18 years of production only; production may continue for several years at
a declining rate.

We show our projections of the rates of oil and gas
TABLE 8
ANNUAL RATESI/OF OIL AND GAS PRODUCTION annual production for the 1982 to 2000 period from the proposed
FOR LEASE SALE #48 Sanctuary, i.e., percentage of oil and gas withdrawn from

the estimated resources in Table 8. This procedure, of course,
Year Annual Rate
results in the assumption that the exploitation rate of oil
1979
1980 and gas within the boundaries of the proposed Sanctuary is
-1981 identical to the entire Lease Sale #48.
1982 0.7
1983 3.2 initial Production Years
1984 6.5
1985 10.3 We also need to establish hypothetical initial produc-
1986 12.0
1987 11.8 tion years for both the 24 tracts withdrawn from Lease Sale
1988 10.0
1989 8.1 #48 and for the remainder of the area within the proposed
1990 6.3
1991 5.2 Sanctuary. In the case of the 24 tracts withdrawn from
1992 4.2 Lease Sale #48 the init .ial production year is 1982 the same
1993 3.7
1994 3.3
1995 3.0 as for the remainder of the Lease Sale #48.
1996 2.7 In the case of the remainder of the area within the
1997 2.5
1998 2.3 proposed Sanctuary, it is extremely difficult to predict initial
1999 2.2
2000 . . . 2.0 years.of production. For instance, the Call fo .r Nominations for

Lease Sale #68 incltided the entire area of the proposed Sanc-

tuary except for an area north of the Islands. (Figures 10 and

11.) within the area of the Call included in the proposed

Sanctuary, industry interest was so limited that BLM/USGS

recommended further evaluation of only 30 tracts for possible
leasing.!/These 30 tracts may hereafter be included in the tenta-

tive tract selection, subjected to analysis in the DEIS on the

I/ Memorandum from Manager, BLm Pacific OCS office and Acting
@@onservation Manager, USGS Pacific OCS Region to Assistant
Director,,BLM Mineral and Energy Resources and Chief, USGS
33 Conservation Division; Subject: Tract Selection Recommendatio
for Sale 68, Southern California, April 7, 198b.'

sale, and ultimately could be offered and leased. Although it emphasize that such impacts may not occur at all, may occur to
is extremely unlikely that all these tracts would be offered much more limited extent, or may not occur in the 1982 to 2006
and leased in 1982,.we assume this scenario. time frame covered in this report because of the substitutability
We assume that after this sale of leases, 6 years would of production opportunities. There are in the Southern California
be required by a successful bidder an these tracts within the Bight numerous other tracts that may offer equal or better hydro-
bo.undaries of the proposed Sanctuary prior to any production carbon exploration and exploitation opportunities than those
of hydrocarbons. Our assumption is based on the fact that located within boundaries of the proposed Sanctuary. Assuming
unlike the general area of Lease Sale #48, where some explora- that the oil.and gas industry will not commence oil and gas ex-
tion for hydr ocarbon resources has occurred in the past, in ploration and production on all available tracts within the
the proposed Sanctuary, pa rticularly on the south side of the Southern California Bight at one time-surely a realistic assump-
Isl ands, such activities have been extremely limited as we tion in light of limited capital, manpower, time and other re-
have already noted. Thus, the earliest year in which hydro- quirements--the prohibition of such activities within the bound-
carbon production could begin on.any tracts in Lease Sale #68 aries of the proposed Sanctuary will have the effect of redir-
is assumed to be 1�88. -ecting such activities to other available tracts.
For the sake of this analysis,.it is assumed that all Thus, the regulations which Prohibit hydrocarbon explora-
remaining tracts within the proposed Sanctuary on which any tion and exploitation in the proposed Sanctuary may have no
industry interest has been expressed would be leased in 1983 socioeconomic impacts on the economy or such impacts may be
in Lease Sale #73. It appears unlikely that these tracts-in, marginal. Clearly, the socioeconomic impacts estimated in this
which industry interest is extremely low will be leased at any report represent the worst posgiblle assumptions.
time. The earliest year in which hydrocarbon production could
Types of socioeconomic Impacts
begin on these remaining'26 tracts is assumed to be 1988, based
onthe same factors discussed above. Both these production There are two principal causes for socioeconomic impacts
resulting from either complete or partial prohibition of oil
schedules probably overestimate the speed with which production and gas exploitation within boundaries of the proposed Sanctuary:
will proceed.

Substitute opportunities
Priotto presenting the analyses of the socioeconomic impacts
d resulting from prohibition of hydrocarbon exploration and ex- 41
ploitation within the proposed Sanctuary it is cardinal to
36
35

(1) loss of lease income to the United States because
Thus, our analyses will emphasize socioeconomic impacts
tracts within the proposed Sanctuary .are not leased resulting from the latter cause. Two different kinds of socio-
to oil and gas industry; and economic impacts can be readily distinguished. The first of
(2) foregone value of oil and gas not pro .duced by the these is the direct impact on oi .I and gas industry's sales,
oil and gas industry within the boundaries of the
income, Profits and associated employment (as well as,wages
proposed Sanctuary. and salaries) resulting from complete or partial curtailment
With regard to the former case, i.e., socioeconomic of oil and gas production within the boundaries of the pro-
impacts resulting from the loss of lease income, the required posed Sanctuary.
information for such an analysis is essentially not available. The second kind of impact is so called indirect which
In this regard it is useful to quote the following from the results from reduced demand for goods and services (because of
Draft Environmental Impact Statement on the Proposed Channel
curtailed oil and gas production) from other sectors of economy
Islands Marine Sanctuary-i/
which supply the oil and gas industry.
"The proposed prohibition could reduce U.S. income
.from offshore .leasing. It is unlikely that the industry Both direct and indirect socioeconomic impacts resulting
will bid on affected tracts located completely within from h drocarbon exploration and ex loitation re
the sanctuary if those tracts are offered in future y P gulations with
lease sales. Tracts located partially within the sanc- in the boundaries of the proposed sanctuary will be analyzed.
tuary would also be less attractive to industry given
a prohibition on drilling in the sanctuary and would Finally the socioeconomic impacts may be classified and
draw lower bids or none. this change in bidding could
represent a reduction of revenue to the U.S. Treasury appropriate analyses undertaken according to the recipient of
if these leases might otherwise have been sold. The
total amount of lost revenues-cannot be estimated at the impact and/or affected sectors. We propose.to distinguish
this time. The prices of leases are based on data much
of which is proprietary. Furthermore, the future prices the following'specific recipients in our impact analyses:
of leases in the Channel will depend heavily on the results
of exploratory activity from Sale 48. Prices for tracts (1) economy as a whole,
leased in earlier sales do not follow any clear geo-
graphic pattern. The Department of the Interior estimated (2) consumers;
the social value of the 24 tracts deleted from Sale 48
to be $1 million (U.S. Department of the Interior, 1979c) (3) oil and gas industry;
The social value is the savings gained by producing oil
.domestically rather than importing it.. The Federal govern- (4) regio.n where the activities resulting in impacts
ment obtains most of these savings through leases, royalties, take place;
and taxes."

(5) prices and costs of goods and services;
U.S. Department of Commerce, NOAA, office of Coastal Zone (6) employment.
Management, Draft Environmental Impact Statement on the Proposed
Channel Islai@d-s marine Sanctuary, 1979, pp. F-98-99. We can now turn to the socioeconomic impact analyses as out-
lined above..

37 38

Q 10 M 0% 04@- W tIj H 0 %D M -4 M 0 a, W W

C6:j D 0
Socioe wHt@ tjwt,)w a@ w cn m w w t- (t z M op.
Mconomic i1mPacts of Proposed? Sanctuary Ij w Ln -J CD 1-1 W %D OD 0% -4 1 03 00 j W W Or rt 0 @- P) 0
CM I- H Co 0 W 0% to W 4- -4 0 hi W W :r F@ 0 In @3
Impact "o"Z 0 @d 0
M C Id :1
(b to 0 " (D
As already described, socioeconomic i *-,I tto
M-PaCts Under the worst
case assumes no exploitation of an estimated 12 million barrels
of oil and 18 billion cubic feet of gas reserves within the .0. J. .0. A@ W W W La W W 'Lij, h Id 0)
U$ vi tn ui Ln %n c> o Q 4o o J -J @4 14 @J -4 14 -4
boundaries of the proposed Sanctuary.
FA
I!Mact on the EconoM
0
0 :1 M
0 Ln O@ M -4-4 00 %D M c :3
The direct loss-tO the economy is therefore foregone value @4 Z. I. @n co L. c, 0 H - - - - - 00
from the production of the oil and gas located within the ch

0
boundaries of the proposed Sanctuary. Tables 9 and 10 present
the pertinent impact calculations. AS the data in Table-11 c
@h on Ct r. H C@ M
Q bi ON H -j 00 2 0 0 Vt tu 1- 0 M P
indicate, the total resulting annual direct loss to the economy &' W '4 W ko W KJ 0 0 0 a Go .7% 03 4@ " :I, W 0 @-4
- - - - - - n z '00
C;@ C@ 0 c' 0 C@ 0 0 0 C> 0 H M ):0 0
under worst case assumptions in the first year of production a Cn. CD Q 0 0 0 Q 0 W
t-h 0
(1962) is only $1.85 million. Tbis.loss increases-rapidly as a
the cumulative number of oil and gas wells are increased and in 0 0
z
4A. Ct a -0 01
the peak production year of 1992 the total is $47.04 10 -J -3 -J -3
(n
million. After 1992 the annual losses decline equally rapidly
as the oil and gas reserves are gradually depleted. 10
0
0 3: 0 z :I
M Pi rt Co
tj
Impact on Oil and Gaa-IPAUstry
The impact of the total loss from foregoing production of

@-I-W 0 >
oil and gas resources within the boundaries of the proposed bi t) W W 1-1 W--:3 0 M :3 @3
?D @O n 0
L' _j tj CD
Sanctuary can be readily estimated using several measur6s. one QX6t"%DQC0U1C>oW OW00"W WC%Cn
of these is to calculate the lost net income to the oil and

40
39

TABLE 11

TOTAL IMPACT ON THE ECONOMY RESULTING FROM HYDROCARBON
PRODUCTION IN THE 24.TRACTS WITHDRAWN FROM
LEASE SALE #48 AND FROM HYDROCARBON PRODUCTION
IN THE REMAINING TRACTS OF THE PROPOSED
SANCTUARY, 1982-2006
(in millions of dollars)

Value of Hydrocarbon
Year Productbon

1982 $ 1.85
1983 8.46
1984 17.18
1985 27.22
1986 31.72
1987 27.48
1988 28.28
1989 29.8i

1990 38.35
1991 45.00
1992 47.04
1993 41.00
1994 39.41
1995 37.37
1996 31.65
1997 25.92
1998 21.87
1999 19.85

2000 16.83
2001 10.71
2002 9.63
2003 8.93
2004 8.21
2005 7.85
2006 7.14

TABLE 10

DIRECT LOSS TO ECONOMY FROM FOREGONE HYDROCARBON PRODUCTION
,FOR REMAINING TRACTS WITHIN BOUNDARIES OF PROPOSED SANCTUARY ASSUMING WORST CASE, 1988-2006

Foregone :'m Foregone Potential Total
Annual.Pro- Potential; Annual Pro-
duction Of Annual duction of Annual Annual
Oil Loss Gas Value Loss Loss (Oil
(in thous- Value in Mil- (in thous- Per in Mil- and Gas)
and barrels) Per, lions ands of cubic Cubic lions in Mil-
Year Barrels of $ feet) Ft. Of $ lion $

1988 39.9 $37 1.48 62,300 $6 $0.37 $ 1.85
1989 182.4 37 6.75 284,800 6 1.71 8.41

1990 370.5 40 14.82 578,500 7 4.05. 18.87
1991 587.1 40 23.48 916,700 7 6.42 29.90
1992 684.0 40 27.36 1,068,000 7 7.48 34.84
1993 572.5 40 22.90 1,050,200 7 7.35 30.25
1994 570.0 40 22.80 890,000 7 6.23 29.83
1995 461.7 45 20.78 720,900 9 6.49 27.27
1996 389.1 45 17.51 560,700 9 5.05 22.56
1997 296.4 45 13.34 462,800, 9 4.17 17.51
1998 239.4 45 10.77 373,800 9 3.36 14.13
1999 210.9 45 9.49 .329,300 9 2.96 12.45

2000 188.1 45 8.46 293,700 9 2.64 10.10
2001 171.0 47 8.04 267,000 10 2.67 10.71
2002 153.9 47 7.23 240,300 10 2.40 9.63
2003 142.5 47 6.70 222,500 10 2.23 8.93
2004 131.1 47 6.16 204,700 10 2.05 8.21
2005 125.4 47 5.89 195,800 10 1.96 7.85
2006 114.0 47 5.36 178,000 10 1.78 7.14

gas industry resulting from not exploiting the hydrocarbon,

resources within the proposed_Sanctuary boundaries.
Recent financial data on the oil and gas industry indicates TABLE 12
PROFIT AS PERCENT OF SALES FOR THE OIL
net income as percent of total revenues for this industry to AND GAS INDUSTRY, 1968-1976
average about 5 percent (Table 12). Applying this statistic (millions of dollars)
to the value of lost production presented in Table 12 yields a

measure of the impact of proposed Sanctuary regulations on the
Net Income as Percent
oil and gas i -ndustry (Table 13). Year Total Revenue Net Income of the Total Revenue
As the data in Table 13 indicate the loss of profits to 1968 $61,178 $5,805 9.5%
the oil and gas industry is not significant. In the peak 1969 67,479 5,636 8.4
year of production-, i.e., 1992, this loss is estimated to be 1970 73,499 5,797 7.9
1971 81,297 5,847 7.2
1972 88,582 5,784 6.5
only $2.3 million. 1973 110,348 9,468 8.6
1974 194,356 13,149 6.8
1975 202,115 9,901 4.9
.Impact on Region 1976 225,540 11,641 5.2
1977 250,402 12,090 4.8
The direct and indirect impact of the regulations on the 1978 273,604 13,266 4.8
southern California region can be estimated utilizing the
Source: API Key Financial Date of Leed!ng
projected impact of the activities expected to result from u1s, ssion Paper #017, Septembe 6,Ui;jqOre Companies,
cu

the entire Lease Sale #48 on the Gross Regional Product..

Inferences from these estimates support the conclusion that

prohibiting exploitation of hydrocarbon resources within the

boundaries of the proposed Sanctuary will have a negligible

impact.

The impact of the entire Lease Sale #48 on the region's

economy is estimated to be less than-1 percent in the Final

Environmental Impact Statement with regard.to the Lease Sale 448.

"The impact of proposed OCS Sale No. 48, direct
and indirect activity, during the peak of 1986 on
Southern California Gross Regional Product (GRP) is
d

44
43

TABLE 13
FOREGONE NET IkOME AS THE RESULT OF PROHIBITION O@ projected at $519 Million. That is less than a I per-
HYDROCARBON E@PLOITATION IN THE PROPOSED cent increase over the projected GRP for the area in
SANCTUARY BOUNDARIES, 1982-2006 1986. During none of the these years is the Southern
California GRP increased by I percent. The impact
of proposed Sale No. 48, direct and indirect activity,
on the economy of Southern California is positive, but
minor.
Foregone Profits
Year (in thousands of However, and most important, the above estimates of the socio-
economic impacts resulting from the entire Lease Sale #4B are
1982 $92.5
1983 423.0 based'on the original United States Geological Survey hydro-
1984 859.0
1985 1,361.0 carbon resource estimates of 715 million barrels of oil and
1986 1,586.0
1987 1,374.0 860 billion cubic feet of gas.
1988 1,414.0
1999 1,490.5 The revised resource estimates are considerably smaller,.
1990 1,917.5 onlyl04million barrels of oil and 498 billion cubic feet of
1991 2,250.0 gas.
1992 2,352.0
1993 21050.0
1994 1,970.5 This very significant reduction in hydrocarbon resources
1995 1,868.5 for Lease Sale #48 will also result in proportional reduction
1996 1,582.5
1197 1,093.5 in the increment resulting from Lease Sale #48 activities to the
1998 992.5
1999 960.9 Gross Regional Product.
2000 841.5 This revised increment to Gross Regional Product for Southern
2001 535.5
2002 481.5 California r .esulting -from Lease Sale #48 during the peak year
2003 446.5
2004 410.5
of production is estimated to be about $72-million.
2005 392.5
2006 257.0 Under worst case assumptions hydrocarbon resources located

within the boundaries of the proposed Sanctuary that will not

be exploited by the oil and gas industry are comprised of

11.4 million barrels of oil and 17.8 billion cubic feet of gas.

1/ United States Department of Interior, Final Environmental
@@tatement OCS Sael #48, Washington, D.C., 1972, Vol. 2, p. 1307.

Estimated oil resources in the proposed Sanctuary rep- Commercial and Recreational Fishing and TouiiSm Activities
resent only 11.0 percent of total revised oil resources i Within or In the Vicinity of Proposed Sanctuary
in
the entire Lease Sale #48 and only 3.6 percent of total gas The proposed Sanctuary may also add to the Region's
income by preserving commercial fishing operations and tourism.
resource estimates in the Lease Sale #48.
Assuming that the magnitude of regional impact is in Both of these activities represent major sources of income in
direct proportion to the resource estimates, suc .h impact result- this region and therefore require brief discussion.
The proposed Sanctuary would result in enhanced preserva-
ing from foregoing exploitation of hydrocarbon resources within
proposed Sanctuary under worst case assumvtions during the peak tion of ecological, recreational and esthetic resources, parti-
year of production should not exceed 7.9 million. cularly endangered species, marine mammals and birds, and the
With regard to the personal income the Department of habitats of these populations. Fishing and recreation activi-
Interioxi/reports: ties, two major sources of income for the region, also depend
"Personal income changes due to Proposed OCS on the continued,health of the marine resources of the area.
Sale No. 48, direct and indirect activity, in Southern
California is projected to increase by $241 million In 1975 commercial fishermen landed 12,248,000 lbs of fish and
during the oeak year of 1986. That is less than a I shellfish from the'waters around the northern Channel Islands
percent increase over the projected level of personal
income for that.year." I/ and Santa..Barbara Island.l/ The California Department of Fish
Again, these personal income estimates are based on the and Game reported that 187,500 ang Iler days occurred in the Channel
original hydrocarbon resource estimates. Additional personal
(from partyboats) in 1970 with a catch of 517,.558 fish and esti-
income resulting from Lease Sale #48 during the peak year based
mated and related expenditures of $2,294,000. The natural
an the revised hydrocarbon estimates is only,$39 million. resources of the island waters are also a factor in attracting
Assuming that personal income increases (or decreases) vary
tourists and recreational fishermen to the Santa Barbara area,
roughly proportionally to the hydrocarbon resources, the loss in
but that factor cannot be easily quantified. The Santa Barbara
personal income resulting from worst case assump .tions during Chamber of Commerce estimated the total tourist expenditures in
the peak year of production represents 11 percent of $39 mil- the County at $60,534,520 in 1973. Most of these expenditures
lion or only $4.3 million.
occur on the mainland, rather than island, coast and waters.

The proposed Sanctuary in these waters would help assure

I/ United States Department of'Interior, Final Environmental
"9tatement OCS Sale #48, Washington, D.C., r972, Vol. 2, p. 1307. 1/ U.S. Department of Commerce National Oceanic and Atmosoheric
Administration, office of Coastal Zone Management, Draf Eny on-
t
mental Impact Statement on the Proposed Channel Islands Mar. it
Sanctuaty, 1979, pp. E-70, E-73 and E-74-76.

47
48

protection for the natural resources upon which these economic Sanctuary represent 11 percent of total oil resources in
activities partially depend. Lease Sale 448 and only 3.6 percent of gas resources under
impacts on Prices and Costs of Goods and Services the worst case assumptions. Some employment decrease result-
ing from these foregone hydrocarbon resources can be expected,
Since the total loss of oil and gas production of 11.4
million barrels and 17.8 billion cubic feet respectively, result- however, this decrease will be marginal and will certainly
ing from the proposed Sanctuary is relatively.small when compared not reduce total affected employment by 5 percent. The principal
to the total projected production from the entire Lease Sale #48 factors accounting for this negligible impact on employment is the
(104 million barrels) or to the total -annual domestic production fact that marginal changes in production (such as these resulting
of 3,200 million barrels per year in-1979, it is not likely that from prohibition of all hydrocarbon resource exploitation in
this loss will have any effect on prices of oil and gas or costs the proposed Sanctuary) of offshore oil and gas have no direct
in the national market which exists.for oil and gas. impacton labor demand because of the insensitivity of la bor
demand to marginal changes in outputJ/
impacts on Productivity and Employment
Since ch-anges in the resource base have very limited impact Impact on Consumers
With regard to the socioeconomic impact on the consumers,
on labor productivity, the proposed regulation which affects only
the resource base has negligible impact on labor productivity. the market for the oil and gas produced from the Lease Sale
#48 and therefore from tracts within the proposed Sanctuary
With regard to.the impact on employment, the proposed prohibition
of hydrocarbon exploitation within the boundaries of the proposed is that of entire United States'. 2/ The foregone production of
oil and gas from the proposed Sanctuary during the peak year
Sanctuary my reduce somewhat the total construction.and non-
of production, i.e.,'1991,.of 296 thousand barrels is infinitesi-
construction employment demand.
mal when compared.to the magnitude of domestic annual (1978)
The revised employment estimate based on the'more recent
hydrocarbon resource estimates for the peak year of production production of oil estimated to be 3200 million barrels.---'In
light of these differences between the foregone oil production
of Lease Sale #48 would place additional employment needs

generated by activities associated with Lease Sale #48 at
I/ Ivars Gutmanis and Everard Munsey, "Impacts of National
about 2000 persons. Environment and Energy Jolicies on the Demand for scientists
and Engineers," Projection Highlights, volume 3, Number 8,
g a._
The foregone oil and gas resources resulting from the pro- National Plannin .c., tion, Washington, D.C., August, 1974.
ID
posed Santuary estimated within the boundaries of the proposed 2/ United States Department of interior, Fianl Environmental
Statement OCS Sale #@L8, Washington, D.C., 1972, Volume 2, p.
T293.

from the proposed Sanctuary during the peak year and the boundaries of the proposed Sanctuary from the Lease Sale #48
annual demand for oil in the United States@it is not likely at only $1.6 millionY
that regulations which impact on oil and gas production in The methodology we propose to utilize to estimate the
the proposed Sanctuary will have any effect on the supply indirect impact associated with prohibition of the hydrocarbon
or cost to consumers. exploration and exploitation is that of inter-industry modelY
The first step in determining the indirect impacts
Indirect Impacts from total or partial prohibition of the hydrocarbon resource
our discussion and our impact analysis has so far dealt exploration and exploitation within the boundaries of the
with direct impac-ts resulting from regulations that would pro- Proposed Sanctuary is to select industry sectors which are
hibit hydrocarbon exploration and exploitation within the impacted by this regulation.
boundaries of the proposed Sanctuary.
Our criteria for this selection is as follows: if the
in this section we will discuss the indirect impacts of indirect impact on sector of economy is at least $0.01 or
the regulations. Our principal emphasis will be on the indirect more per $1.00 ofoil and gas production this sector will be
impacts Iresulting-from loss of oil and gas production located included in our analyses--all other sectors will be excluded.
within the proposed Sanctuary. Table 14 presents the results of this selection process
While there are other indirect impacts associated with as well as the associated total (direct and indirect impact)
such issues as reducti6n in oil and gas industry profits, coefficients and modifiedYtotal coefficients. Note that a
reduced employment opportunities and others, these obviously total of eight sectors of economy meet the criteria estab-
are very insignificant in light of our findings presented in lished above.
the Previous section. The most important of these is Maintenance and Repair
Additional proof for this contention can be found in the Construction Sector. Production of oil and gas valued at
fact that the United States Department of Interior has esti-
mated total social value of deleting the 2 4 tracts within the U.S. Department of Interior' Secretarial Issue Document
Southern California OCS Sale #4;, February 28, 1979, p. 4-6-.
2/ See-: @ii.@e InPut-Nutput. Structure of the'U.S. Economy, 1972-
iness
ffeaartment-of Commerce, Survey of Current Busine April, 1979,
51 Voi. 59, No. 4.

$1.00 results in demand for goods and services from this TABLE 14
sector valued at 5.5 cents and conversely curtailment of SECTORS OF ECONOMY AND ASSOCIATED TOTAL COEFFICIENTS WITH
TOTAL (DIRECT AND INDIRECT) REOUIREMENTS AT LEAST OF $.01
oil and gas production by $1.00 results in 5.5 cent loss of PER $1.00 OUTPUT IN CRUDE PETROLEUM AND NATURAL GAS PRODUCTION

output in the Maintenance and Repair Construction Sector.
The second largest'sector where the curtailment of gas Total
Total Requirements
and oil production will have relatively significant impacts Commodity Requirements Coefficient
Number Sector Title Coefficient Modified
is that of Business Services. In this sector curtailment
of oil and gas prod uction valued at $1.00 will result in Maintenance and Repair
12 Construction .05729 .05502
reduced output of goods and services Valued at 3.5 cents. Chemicals and Selected
The other sectors of economy where the total impact of reduc- 27 Chemical Products .01191 .01144
Primary iron and
tion of oil and gas production will be relatively significantly 38 Steel Manufacturang .01716 .01648
noticed are "Primary Iron and Steel Manufacturing"; "Trans- Transportation and
65 warehousing .01600 .01536
portation and Warehousing"; "Wholesale and Retail Trade" and
Electric, Gas, Water,
"Finance and Insur@ince." 68 and Sanctuary Services .02451 .02354
Since the Department of Commerce input-output table used Wholesale and Retail
69 Trade - .01661 .01595
(and for that matter all other Federal government input-output 70 Finance and Insurance .01623 .01559
tables) are presented in constant 1972 dollars, we need to
73 Business Services .03649 .03504
deflate the projected value of potential oil and gas production
from the 24 tracts deleted from the Lease Sale #48 and the Source: "The Input-Output Structure of the U.S. Economy, 102,"
Surv Department of Commerce, April
�797yVo
.I.Cu
grent Business,
estimated oil and gas production in the remaining area of the #4, Table p. 62.

proposed Sanctuary to 1972 dollars.

_I/ Modification is required because the total coefficients
presented in the Department of Commerce's table are those
for final demand. We require total coefficient at producers
level, hence all final demand coefficients have been divided
by 1.04132, i.e., total coefficient for "crude petroleum and
natural gas" sector,.

53 54

TABLE 15
Table 15 -presents the pertinent calculations for deriving PRODUCERS WHOLESALE PRICE DEFLATORS
the appropriate producers wholesale price deflators for oil and FOR CRUDE OIL AND GAS, 1972 and 1980

gas.

Table 16 and 17 presents the data on potential annual loss Crude Oil Natural Gas
of crude-oil and gas for-the 1982 to 2000 period in constant BLS Price. Modified BLS Price Modified,
eflator-* 15@'ftatbr V D6fl tor
Year s4d a Deflator Used
1972 dollars, resulting from deflation of the pertinent data..
The product of the "Total'Requirements Coefficient Modified" 1972 113.2 100.0 117.6 100.0
(Table.14) and "Value of Potential Annual Loss in Constant 1972 1980 522.8 461.8 777.3 661.0
Dollars" (Tables 16 and i7) will yield value of the indirect

impacts to the eight selected sectors of economy in constant

1972 dollars.

In order to express these in 1980 dollars several components

of Implicit Price Deflator for Gross National Product were used.

These are shown in Table 18. Tables 19 and 20 present the indirect

impact values resulting from prohibition of hydrocarbon exploration

and exploitation for the 24 tracts withdrawn from Lease Sale #48
and.for the remaining of the tracts within the proposed Sanctuary-.l/

As the data show, the annual indirect costs resulting from

regulations related to proposed Sanctuary are not significant.

The largest annual indirect cost is about $2.3 million and for

most years the indirect costs are below $1 million.

l/ Appendix B; Tables B-1 through B-39 present the data and-
Falculations used in deriving indirect costs.

55
56

TABLE 16 TABLE 17

VALUE OF POTENTIAL ANNUAL LOSS OF CRUDE OIL AND NATURAL GAS VALUE OF POTENTIAL ANNUAL LOSS OF CRUDE OIL AND NATURAL GAS
IN CONSTANT 1972 DOLLARSt RESULTING FROM PROHIBITION OF IN CONSTANT 1972 DOLLARS, RESULTING FROM PROHIBITION OF
HYDROCARBON EXPLOITATION IN THE 24 TRACTS WITHDRAWN FROM HYDROCARBON EXPLOITATION IN THE 24 TRACTS WITHDRAWN FROM
PROPOSED SANCTUARY, 1982-2000 PROPOSED SANCTUARY, 1998-2006
(in millions.of 1972 dollars) (in millions of 1972 dollars)

Year Potential Annual Potential Annual P6tentia .I.Annual Potential Annual
Loss of Crude Oil Loss of Gas Total Year Loss of Crude oil Loss of Gas Total

1982 $0.32 $0.06 $0.38 1988 $0.32 $0.06 $0.38
103 1.46 0.26 1.72 1989 1.46 0.26 1.72
1984 2.96 0.53 3.49
1985 4.70 0.83 5.53 1990 3.21 0.61 3.82
1986 5.48 b.97 6.45 1991 5.08 0.97 6.05
1987 4.59 0.95 5.54 1992 5.92 1.13 7.05
1988 4.57 0.81 5.38 1993 4.96 1.11 6.07
1989 3.70 0.65 4.35 1994 4.94 0.94 5.88
1995 4.50 0.98 5.48
1996 3.79 0.76 4.55
1990 3.37 0.59 3.96 1997 2.99 0.63 3.62
1991 2.57 0.49 3.06 1998 2.33
1992 0.50 2.83
2.07 0.40 2.47 1999 2.06 0.44 2.50
1993 1.83 0.35 2.18
1994 1.63 0.31 1.94 2000
1.67 0.36 2.03 2001 1.74 0.40 2.14
1995 1.83 0.40 2.23
1996 1.50 0.33 1.83 2002 1.57 0.36 1.93
1997 1.39 0.30 1.69 2003 1.45 0.34 1.78
1998 1.28 0.27 1.55 2004 1.33 0.31 1.64
1999 1.22 0.26 1.48 2005 1.28 0.30 1.58
2006 1.16 0.27 1.43
2000 1.11 0/24 1.35

57 -
58

TABLE 18 TABLE 19
COMPONENT OF IMPLICIT GNP PRICE DEFLECIORS INDIRECT ANNUAL COSTS RESULTING FROM PROHIBITION OF
USED AND OTHER DEFLECTORS USED HYDROCARBON EXPLORATION AND EXPLOITATION IN THE
2,4 TRACTS WITHHELD FROM LEASE SALE 948, 1982-2000
Sector Component Used (in millions of dollars)

Maintenance and Repair Construction Producers Durable Indirect Costs for 24 Tracts
Equipment Year withheld from Lease Sale #48
Chemical and Selected Chemical Products BLS Chemical Industry
1982 0.1
Primary Iron and Steel manufacturing GNP 1983 0.6
1984 1.1
Transportation and Warehousing GNP 1985 1.8
1986 2.2
Electicity, Gas, Water, and Sanitary 1967 1.9
Services GNP 1988 1.8
1989 1.5
Wholesale and Retail Trade GNP

1990 1.2
Finance and insurance GNP 1991 1.0
Business Services GNP 1992 0.7
1993 0.7
1994 0.6
1995 0.7
1996 0;6
19'97 0.6
1998 0.5
1999 0.5

2000 0.5

TABLE 20
INDIRECT ANNUAL COSTS RESULTING FROM PROHIBITION OF Total (Direct and Indirect) Costs A
HYDROCARB014 EXPLORATION AND EXPLOITATION IN THE
REMAINING TRACTS OF PROPOSED SANCTUARY, 1988- 2006 Table 21 presents annual summa
(in millions of dollars) 2006 period of direct and indirect
tions which would completely prohib
Year Indirect Costs for Remaining Tracts
mated hydrocarbon resources within
88 0.1 Sanctuary.
989 0.6
As the data show in the initia
1990 1.3
1991 2.0 costs of not exploiting these resou
1992 2.21
1993 2.0 These costs rapidly increase the pe
1994 2.0
1995 i's total costs are estimated to be $49
1996 1.5
19'97 1.2 to $43.70 million in the following
1998 1.0
Y99 0.8 decrease as the hydrocarbon resourc
2000 0.7 case scenario is highly unrealistic
2001 0.6 is based on improbably high resourc
2002 0.6
2003 0.6 does not take into account the tech
2004 0.5
2005 0.5 exploiting at least some of the hy
2006 0.5
the boundaries of the proposed Sanc

techniques from tracts just outside

boundary. This more realistic scen

on inflated resources estimates, re

in this report, is discussed in the

Socioecono c 1 Ract st
uming gt 0 th
--I TFImpac

Under the worst case assumptic

tion of the hydrocarbon resources s

proposed Sanctuary was outright prc

TABLE 21
DIRECT AND INDIRECT ANNUAL COSTS RESULTING FROM PROHIBITION OF were lost to the industry. These
HYDROCARBON EXPLORATION AND EXPLOITATION IN THE
PROPOSED SANCTUARY, 1982-2006 too stringent and do not represent
(in millions of dollars) the industry because they preclude
Direct Costs Indirect Costs drilling. Directional drilling is
Remaining Remaining Total and is used with increasing freque
Year 24 Tracts Sanctuary Total 24 tracts Sanctuary Total Costs
readily applied in the case of the
1982 1.85 - i.85 0.1 - 0.1 1.95 critical issue is what proportion
191 8.46 - 9.46 0.6 - 0.6 9.06
1984 17.18 - 17.18 1.1 - 1.1 18.28 oil and 18 billion cubic feet of g
1985 27.22 - 27.22 1.8 - 1.8 29.02
1986 31.72 - 31.72 2.2 - 2.2 33.92 the proposed Sanctuary boundaries
1987 27.48 - 27.48 1.9 - 1.9 29.38
98 26.43 1.85 2.9.28 1.8 0.1 1.9 30.18 directional drilling technology.
99 21.40 -8.46 29.86 1.5 0.6 2.1 .31.96
cannot be provided. However, on t
1990 19.48 18.87 38.35 1.2 1.3 2.5 40.85
1991 15.10 29.90 45.60 1.0 2.0 3.0 48.60 we estimate that at least 40 perce
1992 12.20 34.94 47.04 0.7 2.2 2.9 49.94
1993 10.75 30.25 41-00 0.7 2.0 2.7 43.70 within the boundaries of the propo
199 9.59 20.83 39.41 0.6 2.0 2.6 42.01
1995 10.10 27.27 37.37 0.7 1.8 2.5 39.87
199 9.09 22.56 31.65 O6 1.5 2.1 33.75
1997 8.41 17.51 25.92 0.6 1.2 1.8 27.72
1998 7.47 14.13 21.87 0.5 1.0 1.6 23.47 1/ According to the author of eig
1999 7.40 12.45 19.85 3.5 0.8 1.3 21.15 irilling. . . "most offshore developr
drilled." See: Keith millheim "Op
2000 6.73 10.10 16.83 0.5 0.7 1.2 18.03 about directional drilling," The 0
2001 - 10.71 10.71 - 0.6 0.6 11.31 20, 1978, p. 63. see also,
2002 - 9.63 9.63 - 0.6 0.6 10.23
2003 - 8.93 8.93 - 0.6 0.6 9.53 J. G. Jackson, "Planning a Mul
2004 - 8.21 3.21 - 0.5 0.5 8.71 ing Program for offshore Locations,
2005 - 7.85 7.85 - 0.5 0.5 8.35 No. 2325, Class 6, Petroleum Technc
2006 - 7.14 7.14 0.5 0.5 7.64 W. B. Bradley, Factors Affect
Angle in Straight and Directional P
Presented October 6-9, 1974, Housto
2/ See for example: F. A. Maretich
Weduces Drilling Time on Ghario by
and Gas Journal, 12/22/52; or R. H.
World Oil, V.
Drillin Technique,"

64
63

TABLE 22

DIRECT AND INDIRECT ANNUAL COSTS RESULTING FROM
using directional drilling technology. The total loss to the PROHIBITION OF HYDROCARBON EXPLORATION AND
EXPLOITATION IN THE PROPOSED SANCTUARY,
economy is therefore foregone revenues from the sale Of the ASSUMING NORMATIVE CASE, 1982-2006
resources that cannot be exploited. (in millions of dollars)
Table 22 presents the pertinent calculations. AS the Year Total Costs
data in Table 22 indicate, the total resulting from loss of
1982 1.17
oil and gas annual direct loss to the economy under normative. 1983 5.49
1984 11.00
case assumptions in the first year of production is only 1.2 1985 17.41
1986 20 40
million. This loss increases as the cumulative number of oil 1987 17:63
1988 18.11
and gas well is increased and in the peak production year*of 1989 19.18
1992 the total loss is almost $30 million. From thereon the 1990 24.51
1991 29.'16
annual losses decline as the oil and gas reserves are gradually 1992 29 .96
1993 26.22
depleted. 1994 25.21
1995 23.92
All other impacts associated with the normative case pro- 1996 20.25
1997 16 63
hibition of hydrocarbon exploitation within the boundaries of 1998 14:08
1999 12.69
the proposed Sa nctuary are on the order of about one-half of 2000 10.82
the impacts discussed under worst case assumptions. This 2001 6.79
2002 6.14
can be readily seen from the impact estimates on the Gross 2OD3 5.71
2004 5 26
Regional Product of Southern California. 2005 5:00
2006 4.58
United States Department of Interior originally estimated
that the entire Lease Sale f48 would add to the Gross Regional
Product of Southern California $519 million during the peak-
year of hydrocarbon exploitation, i.e., 1986.1/

I/ United States Department of Interior,, Final: Environinental
9tatement OCS Sale 948L Washington, D.C., r972, Vol. 2, p. 1307

65 66

This impact was based on hydrocarbon rdsource estimates With regard to the impact on the oil and gas industry
for Lease Sale #48 of 715 million barrels of oil and 860 billion the recent data indicate industry net income to average about
cubic feet of gas. Subsequently, Unitdd States Geological 5 percent of total revenues. For the peak year of production
Survey drastically reduced these resource estimates to only i.e., 1992, since the foregone total oil production revenues
104 million barrels of oil (a reduction of 86 percent) and are estimated to be almost $30 million, the impact of the
498 billion cubic feet of gas (a reduction of 42 percent). proposed regulations on the industry is therefore $1.5
Assuming proportional reduction in the increment to the Gross million. For the worst case this estimate was $2.3 million.
Regional Product during-the peak year of production this is The magnitude of total foregone oil and gas production
estimated to be only about $72 million. within the boundaries of the proposed Sanctuary over the entire
Under normative case assumptions hydrocarbon resources life of these resources under normative case scenario of 6.8
located within the boundaries of the proposed Sanctuary that million barrels of oil and 10.7 billion cubic feet of gas is
will not be exploited by the oil and gas industry are com- miniscule when compared to the annual (1978) domestic hydro-
prised of 6.8 million barrels of oil and 10.7 billion cubic carbon production of about 3200 million barrels of oil.
feet of gas (60 percent of 11.4 million barrels of oil and Thus, the impact of foregone oil and gas production within
17.8 billion cubic feet of gas). the boundaries of the proposed Sanctuary on the costs or prices
T.hese unexploitable oil resources in the proposed Sanctuary in the economic activities related to oil and gas industry is
under normative case assumptions represent only 6.5 percent of nil.
total revised oil resources in the entire Lease Sale #48; in the With regard tothe employment impacts, in the normative case,
the Department of Interior estimated additional employment
case of gas resources, those located within the boundaries of
the proposed Sanctuary comprise only 2.1 percent of total gas resulting from entire Lease Sale #48 during the Peak year of
resource istimates in the Lease Sale #48. Production at 14,629 persons.!/ This estimate was based on
Assuming that the magnitude of regional impact is in direct unrevised hydrocarbon resource estimate for Lease Sale #48.
proportion to the resource estimates, such impact resulting-from The revised employment estimate based on the more recent
-foregoing exploitation of hydrocarbon resources within proposed hydrocarbon resource estimates for the peak year of production
Sanctuary under normative case assumptions during the peak year
of-production should not exceed $4.7 million as compared to
I/ United States Department of interior, Final Environmental
$7.9 million for worst case. @@tatement OCS Sale #48, Washington, D.C., 1972, Vol. 2, p. 1293.

would place additional employment needs generated by activities

associated with Lease Sale #48 at about only 2000 persons.

The foregone oil and gas resources resulting from the

proposed Sanctuary estimated within the boundaries of the

proposed Sanctuary represent 6.5 percent of total oil resources

in Lease Sale #48 and only 2.1 percent of gas resources

under the normative case assumptions. Some employment decrease

resulting from these foregone hydiocarbon resources can be

-expected, however, because of the insensitivxty of labor demand

to marginal changes in output this decrease will be small, and
will certainly not reduce total affected employment by 5 percent.

Further, because of the very small magnitude and value

of the foregone hydrocarbon resources within the boundaries of

the proposed Sanctuary,these will have no impact on competition

in the oil and gas industry.

in summary, under the normative case assumptions the socio-

economicimpacts both direct and indirect, an the economy, con-

sumers, industry and employment, resulting from foregone exploita-

tion of a certain proportion of estimated hydrocarbon resources

within the proposed Sanctuary, are essentially insignificant.

Further, the proposed regulations have no impact on costs,

prices or supply of materials, products and services.

APPENDIX 7. Distribution List for the Channel Islands FEIS

U.S. Air Force
L.A. District - Corps of Engineers
U.S. Department of Energy
U.S. Department of the Interior
U.S. Department of the Interior - National Park Service - Channel Islands
National Monument
Department of State, Office of Oceans and Polar Affairs
Department of Transportation, FAA
Department of Transportation, Federal Highway Administration - Region Nine
Department of Transportation, Ilth Coast Guard District
U.S. Environmental Protection Agency, Surveillance and Analysis Division
U.S. Environmental Protection, Office of Environmental Review
Marine Mammal Commission

U.S. Representative Anthony C. Beilenson (CA)
State of California Coastal Commission
California Coastal Commission, Regional Office
The Resources Agency of California
California Department of Fish and Game
City of Del Mar, California
The City of Santa Barbara, California
Santa Barbara County Board of Supervisors
Board of Supervisors of Santa Barbara County
Hermosa Beach Planning Commission
County of Ventura-Fish and Game Commission
State Senator Omer L. Rains
State Assemblyman Gary K. Hart

The American Cetacean Society
American Petroleum Institute
Association of Santa Barbara Channel Yacht Clubs
Atlantic Richfield Company
California Marine Parks and Harbors Association
California Seafood Institute
Carpinteria Valley Association
Center for Law and Social Policy
Channel Islands Yacht Club
CHEVRON U.S.A.
Coast Alliance
Concerned Citizens of Silver Strand
Corinthian Yacht Club
Crowley Maritime Corporation-Steamship Association of Los Angeles Harbor
Environmental Defense Network
Defenders of Wildlife
Environmental Defense Center
Environmental Defense Network
EXXON Company U.S.A.
Fishermen and Allied Workers' Union
Friends of the Earth and Coast Watch
Friends of the River

Friends of the Santa Monica Maintains, Parks and Seashore
Friends of the Sea Otter
Hanna-Barbara's Marineland
League of Women Voters of Santa Barbara
League of Women Voters of Ventura County
Merck & Co., Incl
More Mesa Land Trust
National Association of Underwater Instructors
National Coalition for Marine Conservation Pacific Region
National Parks and Conservation AssociationNorcal Graphics
Natural Resources Defense Council
Pacific Coast Federation of Fishermen's Association, Incl
Pacific Merchant Shipping Association
Recreational Boating Counsel
Resources Partnership
Santa Barbara Audubon Society
Santa Barbara Commercial Fishermen
Santa Barbara Museum of Natural History
.Scenic Shoreline Preservation Conference
Sea Land Sport Fishing and Sport Fishing Association of California
Seaworld
Sierra Club
Sierra Club - Santa Monica Mountains Task Force
Southern California Cruiser Association
Sportsmen's Council of Central California
Southern California Gas
Southern California Petroleum Contingency Organization Atlantic Richfield
Company
Sportsmen's Council of Central California and California Wildli,fe
Federation
Stauffer Chemical Company
Texico, Incl
University of California - Irvine - School of Biological Sciences
University of California - Santa Cruz
Ventura College
Ventura College Well Control School and the International Association
of Drilling Contractors
Ventura Yacht Club
Western Oil and Gas Association
Whale Center

F.E. Bernstein
Atlee Clapp
Al Ebling
Ted Flesher
Clara Ann Folk
Peter Gross
Rick Hamner and Associates
Mr. and Mrs. John D. Harms
Myrna Lefferts
Philip R. Lever
Helen Matel son
Adam C. McOuat

John Morgan
Timothy M. Murp@y and 30 Friends
Scott T. Olson,
Christopher P. Onuf
William Rubin
Richard Spotts
Mrs. J.R. Stall-injs
Dyanne Tabin and Family
Gary Vesperman
Edward and Sarah Zawaski

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