Kristina Kekuewa
Pacific Islands Regional Director
NOAA Office of National Marine Sanctuaries
1845 Wasp Blvd.
Honolulu, Hawaii 96818
RE: Marianas 5 Year Review
Dear Regional Director Kekuewa,
The Friends of the Monument submitted a proposal for a Mariana Trench National Marine
Sanctuary and it was accepted onto the inventory of possible sanctuaries on March 13, 2017. This letter makes official our request to renew our nomination for an additional five years. In this letter we provide updates to the 11 sanctuary nomination process criteria, which we believe strengthens the nomination. Once the nomination is renewed, we ask the federal government to move forward with scoping for a designation immediately.
In our 2017 nomination we quoted CNMI Constitution, Article I, Section 9, “Each person has the right to a clean and healthful public environment in all areas, including the land, air, and water.” We start our renewal with this quote again, to remind our community that a healthy ocean is a guaranteed constitutional right that we all have to work towards achieving. We invite the NOAA Office of National Marine Sanctuaries in as partners in helping to deliver this constitutional right to our citizens.
Our surrounding waters were first identified as a possible national marine sanctuary in the
1990s and our name appears on the first ONMS site evaluation list. In 2008, the Friends of the Mariana Trench made our request for a sanctuary official in a letter our organization sent to then-President George W. Bush. We copied this letter into the Goals Description of our 2017 nomination and it includes six vision categories: Management and Enforcement; Culture and Tradition; Conservation; Education; Research and Exploration; and Economic Development.
Before considering the specifics of the 11 criteria updates, we offer three overarching
comments: First, we make no substantive changes to our nomination, but request to amend our proposed name. Our waters are home to the iconic Mariana Trench, the deepest trench in the world’s ocean. This is something to be proud of, and we want to include it and keep it in our nomination. But we would like to bring greater attention to the stewardship of the people who have called this place home for more than 4,000 years and ask that the name reflect our heritage. We offer the name Ma’tingan Le’metawh National Marine Sanctuary.
Second, we want to stress the importance of co-management for the proposed national marine sanctuary, and ask that during the designation process, the proper CNMI government agencies and/or Indigenous representatives are included in both management, decision making, and advisory roles.
And third, we want to be clear that we are not proposing any additional restrictions for small fishing vessels home ported in Guam, Saipan, Tinian, or Rota, nor do we think our proposal will affect any existing commercial offshore fisheries. We do, however, want to address foreign and illegal fishing with the sanctuary. We would prefer that the proposed borders of the sanctuary emerge with extensive community engagement during the process of designation, and we have provided significant scientific information detailing the geographic and biological riches of our surrounding Exclusive Economic Zone.
Sanctuary Nomination Process Criteria and Considerations
National Significance Criteria 1: Natural Resources and Ecological Qualities
The 2017 nomination brought attention to the geography and biology that exists in the full US Exclusive Economic Zone around the Mariana Islands, including areas within the Mariana Trench Marine National Monument and close to some of the inhabited islands (based on discussions we had with local leaders at the time).
The Mariana Islands and surrounding waters are a geological and biological hotspot called the Ring of Fire. Coral reefs ring our islands, while volcanoes and seamounts surround the iconic Mariana Trench, the least explored and deepest ecosystem in the ocean. We cited a 2016 peer reviewed survey of global ocean priorities for marine biodiversity which identified the Marianas as the top marine conservation priority within the United States (Jenkins and Van Houtan, 2016).
We highlighted the unworldly creatures that have been discovered in our waters in recent years, but what is even more intriguing is that which we have yet to discover. We highlighted the natural resources and ecological qualities of potential sanctuary areas in a sixty page report as an addendum to our 2017 proposal.
2022 Update
The Friends of the Mariana Trench partnered with young Indigneous scientists to commission an update to our report to document discoveries made in the last 5 years. The paper is submitted as appendix I to this comment letter and focuses on four areas: Marine mammals; coral reef ecosystems; fish and other wildlife; and Mariana Trench. The details within this document highlight how the last five years of discovery and research strengthen the case that our surrounding waters are of global and national significance.
National Significance Criteria 2: Maritime Heritage Resources
The 2017 nomination highlighted the seafaring tradition of the Chamorro and Refaluwasch
peoples and the cultural and historical connections between the heavily populated, large islands in the south and the sparsely populated, smaller islands in the north. It also drew attention to the history of European explorers visiting our islands during 500 years of colonization, as well as World War II era Japanese and American aircraft and naval vessels whose final resting places are in our waters.
2022 Update
The nascent movement to reinvigorate the voyaging and wayfinding traditions in the Mariana Islands is blossoming. The sanctuary program has an opportunity to play a role in this growing movement to reclaim our maritime heritage and culture. There is a new generation of navigators and voyagers who can combine their understanding of traditional ecological knowledge to inspire a new generation of ocean stewards in our islands.
We could also bring attention to the treasure hunters looking for gold from wrecked Spanish galleons such as the Nuestra Señora de la Concepción, whose treasures are currently stored NMI Museum of History and Culture.
The sanctuary could also play a larger role in our cultural and historical understanding of our connection to, stewardship and ownership of ocean resources. A study by Gruby et al, 2017 looked at how Palauans are applying traditional ocean management concepts to the EEZ for the very first time, and this is something that can also take place in the Marianas.
National Significance Criteria 3: Economic Uses
The 2017 nomination reported that there were no economic uses in the Mariana Trench Marine National Monument, but that there was some limited subsistence fishing.
2022 Update
There is hope for the development of cruise line tourism to the Northern Islands and/or
adventure eco-tourism, but it hasn’t taken off yet. Low impact, sustainable ecotourism would benefit our islands, especially as we emerge from the two year Covid pandemic.
In 2018, the CNMI government announced at an international fisheries meeting the intention to pursue subsidies to develop a commercial fishery, but this has not materialized. There has been no industrial fishing in the US waters around the Mariana Islands since 1983 when President Ronald Reagan declared the US Exclusive Economic Zone.
National Significance Criteria 4: Publicly Derived Benefits
The 2017 nomination focused on the existence value of the Islands Unit of the Mariana Trench Monument in relation to both Indigenous identity and biological conservation.
2022 Update
Maintaining our surrounding waters for culture and science would benefit future generations, and act as a window into the past so that we can better understand what our islands and ocean were like before the advent of military colonialism, industrial fishing, plastic pollution, and climate change. Our surrounding waters are large enough and healthy enough to support both the world’s best managed fisheries, and conservation and cultural goals, and we see this as a vision for our waters. We want to support the economy to meet the needs of today, while also ensuring that we are passing down our cultures and natural heritage to our children.
The pandemic has made it obvious how reliant our economy is on tourism, and we need to
improve our branding as a climate-friendly, sustainable destination surrounded by waters
teeming with life. The sanctuary can provide data and information at local tourism hubs and
design education programs for both visitors and locals.
The Friends of the Mariana Trench work closely with the Northern Marianas College and see opportunities for the sanctuary to engage in and support citizen science, the planned NSF research hub, and Indigenous and cultural preservation in our ocean science programs.
The goals of the proposed sanctuary are also in line with the CNMI Comprehensive sustainable development plan which shares the goals of the United Nations’ SDG14. Federal and local agencies engaged in fisheries management, coral reef conservation, and marine protected areas can coordinate to ensure a healthy, sustainable ocean as guaranteed by the CNMI Constitution to all of our citizens.
Management Consideration 1: Research in Marine Science
The 2017 nomination focuses on the biological and geological deep sea research since the
Marianas were first identified as a possible ONMS site in the 1990s.
2022 Update
As the last unfished wildernesses in the United States, the US EEZ around the Marianas
provides opportunity to study healthy fish populations, especially during this time of climate crisis.
The Friends of the Mariana Trench are currently developing several social science research
programs, and there could be a role for the sanctuary. For example, we are bringing together elders and youths to share Chamorro and Refaluwasch traditional knowledge, to explore how to use this in ocean conservation. We are also looking at communication gaps between generations and communities in our islands, cultural blending of new information, and reviewing the exchange of knowledge in traditional ways.
There are opportunities to expand deep sea marine exploration and research. There has been a steady increase in the number of dives to the trench in the last 10 years and an absolute explosion in the last three. Not all of the discoveries or exploration is being shared with our community, or the American public, and the sanctuary could mandate that it is shared.
We hope that there will be future study towards better understanding the effects of plastic and PCBs in our ocean, and how this affects our food security and sovereignty. Several studies in recent years have found pollutants in the trench, which is surprising, because it is the most difficult place in the world to get to. We need to understand how these pollutants are harming our people and our surrounding ecosystems.
Management Consideration 2: Opportunities for Education
The 2017 nomination highlighted the 500,000 annual visitors to the Marianas, and that
government agencies, education institutions, and business are interested in capitalizing on a NMS designation. In the years following the monument designation there had been an increase in the amount of research done in the region.
2022 Update
The Friends work with students from the Northern Marianas College as part of our programs, and connect students to a group of ocean elders, so that they can teach and learn from one another. We are also studying communication gaps in our community to better engage our citizens in ocean stewardship.
Education programs for tourists and locals alike will be a unique destination offering, and could play a role in our community and economy recovering from Covid. Our community is also underserved when compared to other American communities, and partnering with our local organizations and agencies provides an opportunity for the US government to support
Indigneous-led conservation initiatives.
Management Consideration 3: Current or Future Threats
The 2017 nomination identified climate change, deep sea mining, and illegal fishing as the
major threats to the proposed sanctuary.
2022 Update
Our ocean faces more threats than ever. In the Marianas our lands and waters are threatened by increased military activities. In the last five years there have been heightened tensions with China and military threats from North Korea. We are also increasingly concerned about selling US waters to foreign fishing, as the CNMI Marine Conservation Plan still includes a loophole that would allow WESPAC and the CNMI governor to lease our waters to foreign companies and governments, like China.
The Covid-19 pandemic has caused an unprecedented economic downturn in our community, with tourism arrivals dropping to nearly zero for two years. Now we face the threat of inflation, which is further exaggerated by our isolated location and the Jones Act, which restricts which vessels can deliver goods to our ports. We are also concerned about plastic pollution and food security.
Management Consideration 4: Unique Conservation and Management Value
The 2017 highlighted strong support for marine protected areas in the Northern Mariana Islands, but limited resources to implement them.
2022 Update
A study in 2017 explored public perceptions of ocean conservation, marine protected areas, and the Mariana Trench Monument on Saipan. The study by Danny Morris of the University of York found that the people in the CNMI support MPAs, and when asked how much of the Mariana Islands ocean space should be protected, the average answer was 57%. There were less positive responses when asked similar questions about the Mariana Trench Marine National Monument, but they were still overwhelmingly positive. Presentation on the research: https://youtu.be/J1HbZaMXdbI
Management Consideration 5: Supplementing or Complementing Existing Regulatory and
Management Authorities
The 2017 nomination described how the Marianas would benefit from increased capacity to conduct educational and research programs.
2022 Update
We envision a Marianas where we have the world’s best managed fisheries and the most
important protected areas. We would like to see increased coordination of existing fishing
activity, fishing regulations, coral reef sanctuary, and proposed sanctuary rules to enhance
management. We also repeat that we aren’t suggesting fishing regulations for the sanctuary.
Our people have a proud fishing tradition and we support the current regime which keeps
foreign vessels out of our waters. We urge the CNMI Governor, WESPAC, and NOAA Fisheries to remove the loophole from the CNMI Marine Conservation Plan which could allow future foreign fishing. We also applaud the CNMI Governor, WESPAC, and NOAA Fisheries for currently banning longlines close to shore (0-50 nautical miles) and purse seines in our full EEZ, and hope that these restrictions remain in place to support our local fishermen.
Due to the lack of fishing in our offshore waters, they may qualify as an Other Effective
Conservation Measure (OECM), as defined by the Convention on Biological Diversity and the International Union for Conservation of Nature. The sanctuary could play a pivotal role in keeping our healthy ocean durable, along with other ocean management regimes and laws in our region. We think our waters should count as an OECM towards the goals of President Biden’s America the Beautiful Initiative, as our waters are the last unfished wilderness in the United States.
Management Consideration 6: Partnership Opportunities
The 2017 nomination suggested partnerships with local government agencies and
environmental NGOs.
2022 Update
The Friends of the Mariana Trench have received technical and funding support towards
achieving 30×30 in our waters and designating the sanctuary, particularly from the National Ocean Protection Coalition members and the Packard Foundation. Also, parallel to the creation of the America the Beautiful Initiative, we have been in contact with other Indigenous-led sanctuary proposals in the Pacific and hope to create a partnership with them. Here are a list of ongoing partnerships that could engage with the proposed sanctuary:
- The Packard Foundation is supporting our intergenerational ocean conservation corps, several MPA and fisheries science projects, and 30×30 communications and outreach.
- We have started discussions with the Blue Nature Alliance about an opportunity to stand up policy to benefit all our people.
- We are partnering with the Micronesia Islands Nature Alliance to plan workshops to address how to finance the Micronesia Challenge for the CNMI, which has a goal to effectively manage 50% of our marine resources.
- 500 sails has sailing and swimming programs for local community members and are a signatory to our support letter.
- We have a partnership with the Northern Marianas College and their environmental club to improve environmental literacy and work on other conservation projects.
- We are partnering with the CNMI humanities council and a group of ocean elders to document, preserve, and pass down traditional ecological knowledge, stories, traditions, and culture to future generations.
- Project HOPE is an ANA funded campaign which brings elders and youths together to protect the ocean
Consideration 7: Community Support
The 2017 nomination describes the political and community support for a national marine
sanctuary from 2008 to 2016 and includes a list of letter writers and supporters.
2022 Update
The CNMI government renewed their commitment to the Micronesia Challenge and joins a
region-wide commitment to effectively manage 50% of our marine resources. All government resource agencies and many NGOs, businesses, and community members are engaged with achieving this goal.
The Friends of the Mariana Trench participated in the quarterly meeting of the Environmental Sustainability and Stewardship Stakeholders working group hosted by the CNMI House Committee on Natural Resources and presented to over 50 members of the House Committee, executive branch offices, local and national NGOs, federal agencies, local businesses, scientists, and concerned citizens about the five year review. We also hosted a watch party to participate in the virtual public listening session. Letters of concern and support are posted to the Federal Register.
While public surveys and scientific research have found overwhelming support for ocean
conservation in our community, the support is not unanimous. Vocal opposition has been raised by John Gourley, Vice Chair of the Western Pacific Regional Fisheries Management Council, who attended both of the meetings described above. Despite the Friends explaining in careful detail our vision for the proposed sanctuary, Mr. Gourley and his WESPAC colleagues made several accusations about fishing access and permitting, while also lamenting their disappointment regarding the pace of the implementation of the Mariana Trench Marine National Monument. We share many of the same concerns and have been surprised that we are being accused of supporting things we never did. We believe that the concerns raised by Mr. Gourley and WESPAC are addressed in our renewal documents, and believe that the best way to protect our ocean is to work together.
