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Dear Mr. Michel,

We, the undersigned, strongly support the swift designation of the Chumash Heritage National Marine Sanctuary (CHNMS) to protect ocean biodiversity and to advance environmental justice through collaborative ocean management.

In response to the draft designation documents, we support the following actions per category:

• Sanctuary Boundary: The Initial Boundary Alternative with Gaviota Coast Extension Sanctuary

• Name: The name “Chumash Heritage National Marine Sanctuary”

• Tribal Collaborative Management: An inclusive approach to all Tribes in Collaborative Management & a NOAA Tribal Liaison.

• Outreach and Education: Outreach, education and research programs that elevate Traditional Ecological Knowledge (TEK) and access for local underserved communities

• Rodriguez Seamount: The protection of Rodriguez Seamount

• Offshore Wind: Thoughtful planning of adjacent Offshore Wind farms to protect ocean life

• Water Quality: A prohibition on new oil & gas development within sanctuary boundaries

Sanctuary Boundary. It is vital that the CHNMS cover the largest possible contiguous boundaries. We support designation of the Initial Boundary Alternative with the Gaviota Coast Extension (Sub-Alt 5b). Including the waters offshore Point Buchon, Morro Bay, Cayucos, and Cambria will close the California Central Coast’s biodiversity protection gap between Monterey Bay and Channel Islands National Marine Sanctuaries. This will protect the only eelgrass bed in a 300-mile stretch of coast; many historic Chumash sites, including Lisamu’ (Morro Rock); numerous protected marine mammals and shorebirds; the highest population of Southern sea otters on the California coast; several State Marine Conservation Areas; and the kelp forests and rocky intertidal habitats considered to be some of the most diverse and abundant in the world.

No other proposed sanctuary alternative is adequate. The Draft Environmental Impact Statement acknowledges that all other alternatives would reduce the significant beneficial effects on biological resources provided by the Initial Boundary Alternative. All other alternatives would increase the vulnerability of those resources to adverse impacts that the Initial Boundary Alternative would prohibit or mitigate.

Sanctuary Name. We specifically support the name “Chumash Heritage National Marine Sanctuary” to honor the cultural history and stewardship of California Tribal peoples. The name will recognize Peoples that have lived on the California coast since time immemorial and protect the heritage of the Chumash, an ocean-going band among the First People of the Pacific Coast. We want to honor the late Chief Fred Collin’s nomination and vision for the sanctuary and the 10 years of work that the Northern Chumash Tribal Council
did to campaign for the sanctuary.

Tribal Collaborative Management. The CHNMS is an opportunity to advance environmental justice efforts. We ask that you keep the sacred connection between our ocean and community at the heart of this effort. The Sanctuary should teach the benefits of protecting our ocean and planet and promote the spirit of stewardship that is exemplified by the culture and history of the original Chumash caretakers.

We support equitable inclusion/representation of all Central Coast Tribes in the collaborative management of the CHNMS. By being equitable and inclusive, all sanctuary stakeholders will benefit from broad Indigenous input and TEK informing management.

Equitable collaborative management must be open to all Tribal groups interested in participating. This can best be accomplished with a Tribal Sanctuary Advisory Council made up of interested Tribal Groups. NOAA’s Tribal collaboration should be facilitated by a qualified Tribal Liaison.

Outreach and Education. Sanctuary education and community outreach should partner with area schools to increase education and access to the ocean for local communities. New educational programs should focus on both ocean ecology and Tribal history and culture. Outreach should be multilingual and multicultural, and should prioritize underserved communities, such as the inland communities of Guadalupe and Santa Maria. We also urge development of research programs that address the impacts of climate change, encourage community science, and elevate the use of TEK to enhance ecosystem-based management.

Rodriguez Seamount. We support regulations to protect Rodriguez Seamount. The seamount provides critical habitat for extremely biodiverse marine life, which needs strong and permanent protection. Once damaged, fragile seamount ecosystems may not recover in our lifetime.

Offshore Wind. While a source of renewable energy, Offshore Wind (OSW) farms will have environmental impacts on habitat, wildlife, and water quality. California’s first OSW projects adjacent to the sanctuary should be planned and sited to avoid or mitigate impacts to sensitive marine areas and species and important cultural resources. The National Marine Sanctuary Program should work closely with state and federal partners, OSW companies, Tribes, and community members to ensure future OSW is developed in the most environmentally and culturally responsible manner.

Water Quality. The CHNMS should prohibit oil and gas exploration, development and production; phase out existing fossil fuel infrastructure and leases; reduce land and ocean-based pollution; and partner with the local communities to improve conservation of the Central Coast.

The CHNMS is an exceptional opportunity to advance the first Tribally-nominated national marine sanctuary designation in the United States, setting a precedent for elevating Indigenous perspectives, cultural values in ocean conservation, and collaborative management that includes all Central Coast Tribes. The designation of the Chumash Heritage National Marine Sanctuary will be an unprecedented accomplishment, honoring the history and culture of Native Americans, the Chumash people, and their ancestors who inhabited this region for more than 10,000 years.

Thank you for your consideration of these comments.