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Submit Your Oral or Written Comment on Chumash Heritage National Marine Sanctuary

This is Your Last Chance to Comment on Chumash Heritage National Marine Sanctuary Proposal!

Surfrider Foundation’s national policy managers have drafted comments on the recent Chumash Heritage National Marine Sanctuary (CHNMS) proposed designation documents published by the National Oceanagraphic and Atmospheric Administration (NOAA).

Surfrider’s letter addresses the “boundary surprise” sprung on us when the NOAA documents omitted most of SLO County’s north coast creating a Protection Gap roughly between Point Buchon and Cambria. The consensus is that the federal Bureau of Energy Management (BOEM) raised concerns with NOAA that Sanctuary status could delay, or defeat proposed Offshore Wind (OSW) projects that are beyond the desired boundaries but would require sea floor power transmission cables.

As a constructive solution to the problem, Surfrider’s comment letter, a recent article in the New Times by Andrew Christie (Executive Director of the Sierra Club chapter in SLO), and the comment letter by the Environmental Defense Center, all advocate filling in the Protection Gap, but also address the BOEM concerns by advocating for pre-approval of OSW transmission cables. As Surfrider’s letter states:

This would allow for anticipated offshore wind project development and operations in the Morro Bay Wind Energy Area, while helping to protect the future integrity of national marine sanctuary protections.

As Andrew’s article states:

Once the routes are certified, the cables become a preexisting fait accompli, and the marine sanctuary could then include the Point Buchon to Cambria region

The EDC's CHNMS comment letter states: 

“. . . we’d like to see them include this area, but allow the installation of transmission cables under special use permits. This will allow wind energy projects to go forward but will provide permanent protection from threats such as future oil and gas drilling proposals, seabed mining, and other harmful activities.”

The Chapter Executive Committee believes this represents a reasonable compromise between competing interests. The key thing to recognize is that an OSW platform is nothing like an oil platform, which only harms the environment by producing fossil fuels that create global warming gases including CO2 and methane.

By contrast, the clean renewable energy produced by OSW avoids the need to use fossil fuels and helps us reach our clean energy goals. Meeting these goals is critical to reduce the risks of climate change impacts, which are catastrophic for the ocean. See Coastal and Marine Ecosystems & Global Climate Change - Potential Effects on U.S. Resources.

In short, both the Sanctuary and OSW protect the ocean; we need to support a way forward that allows for both. To do so, please send a written comment and/or a live public comment at the upcoming zoom comment opportunity on October 12.

Suggested talking points and submission details for both options are below.

Suggested Talking Points for Comments

As a Surfrider member and/ or coastal recreation user, I stronlgly urge NOAA to do the following in regard to the Chumash Heritage National Marine Sanctuary (CHNMS)

  1. Adopt strong regulations and a robust management plan to provide sufficient protections for the region’s sensitive habitats, cultural resources and sustainable human uses.
  2. Include the full geographic extent reflected in the Initial Boundary Alternative, as well as the Gaviota Coast Extension (5B).
  3. In the enabling regulations, include special permits for the transmission cables needed for anticipated offshore wind project development and operations in the Morro Bay Wind Energy Area.

Procedure for Oral Comment

Date and time: Thursday, Oct. 12, 2023; 1 PM PDT

Procedure for Written Comments

  1. Go to this link
  2. Press the “Comment Buttion” under “PROPOSED RULE Chumash Heritage National Marine Sanctuary proposed rule; Availability of draft environmental impact statement and draft management plan
  3. Type or copy and paste your comments into the first dialogue box. This is limited to 5,000 words.
  4. You may also upload documents into the second dialogue box with a limit of 20 files of no more than 10 MB each.
  5. Provide your email where requested.
  6. Select the appropriate identify box below “Tell us about yourself”.
  7. Provide the contact information requested. Note this information will not be made public. However, personally identifiable information provided in the Comment section will be available to the public.
  8. Finally, click the “I’m not a robot” box and the “Submit” button.