Below is a commentary prepared by eight NWHI Coral Ecosystem Reserve Advisory Council members that was sent to the Advertiser on July 8, 2024 in response to an op-ed piece they printed by Roy Morioka on June 21. A shorter version was printed in the Honolulu Advertiser on August 11, 2005.

Response Commentary from the NWHI Coral Reef Ecosystem Reserve Advisory Council

By Linda Paul, Isabella Abbott, William Aila, Bill Gilmartin, Rick Gaffney, Buzzy Agard, Kem Lowry, Gail Grabowsky, members of the Northwestern Hawaiian Islands Coral Reef Ecosystem Reserve Advisory Council.

The following commentary is in response to the inaccurate and misleading commentary by Roy Morioka, the chairman of the Western Pacific Regional Fishery Management Council (WESPAC), printed in the Honolulu Advertiser on Tuesday, June 21, 2005. As scientists, fishermen and Native Hawaiian kupuna serving on the Northwestern Hawaiian Islands Coral Reef Ecosystem Reserve Advisory Council, it's our job to provide advice and recommendations to the National Marine Sanctuaries Office on a course of action that will maintain the ecological integrity of the Northwestern Hawaiian Islands (NWHI), using the best available science and the precautionary approach.

Coral reefs, the "rainforests" of the ocean, are one of the world's primary reserves of biodiversity, and most are in a serious decline because of a combination of global warming, invasive species, coastal pollution, irresponsible tourism and destructive fishing practices. The NWHI ecosystems are healthy and nearly pristine due to a number of factors, but fisheries management by WESPAC is not one of them. Their very remoteness helps protect these islands and atolls. For six months out of the year it is too rough for most bottom fishermen to safely fish these waters. Currently 8-9 fishermen fish there. The distances are great, and the costs incurred -- fuel, ice, bait, gear, insurance, and time away from home -- only barely justify the rewards. The catch cannot command top dollar because it is 1-2 weeks old when it is brought back on ice to the main Hawaiian Islands (MHI).

Roy Morioka, WESPAC's chairman, claims that his agency has "contributed immensely" to maintaining ecosystem diversity in the Northwestern Hawaiian Islands. The record does not support that claim. Longline fishing is prohibited within 50 nm from the NWHI, thanks in part to the request of local fishermen asking WESPAC to close the area in the early 1990s because of concerns about the impact of longline fishing on regional pelagic fish stocks, and interference with monk seals. WESPAC subsequently invited a South Atlantic bottom longliner to fish for sharks in the shallow waters of the NWHI. The fishery quickly proved unsustainable. WESPAC's Coral Reef Ecosystem Fishery Management Plan for the NWHI was rejected by the National Marine Fisheries Service (NMFS).

In 2000 the National Marine Fishery Service (NMFS) closed the NWHI lobster fishery under threat of a lawsuit. The U.S. District Court denied a motion for a preliminary injunction because NMFS came into Court asserting they were closing the fishery anyway because of overfishing due to a modeling error, and the Court concluded injunctive relief therefore was unnecessary. But the court subsequently issued a permanent injunction closing the fishery indefinitely until NMFS issues a new biological opinion under the Endangered Species Act and a new EIS under the National Environmental Policy Act.

Studies of monk seal food habits show that monk seals do eat a wide variety of fish and invertebrate species - including lobster. Monk seals have been observed catching and eating lobsters in the NWHI, but based on a captive trial the seals appear to fully digest the lobster leaving no evidence in the feces that they consumed this prey. Examining feces is an invalid technique for assessment of monk seals' lobster consumption. That method only tests for indigestible, identifiable parts of the prey (e.g., teeth, scales, and bone that can be attributed to a particular species). A different method of assessing food habits giving a good representation of all prey species that monk seals eat has been ongoing by NMFS for years, but the results are not yet available. Even when these data will be available, the results will not truly represent monk seal prey preference for lobster because the study is being done during a time period when the lobster stock is depleted.

Cameras to observe foraging habits have been deployed on only a very few seals, for short periods of time (a few days), and at a location where the lobster stock is very low. The cameras don't work at night when monk seal foraging on lobsters most likely occur. This limited information cannot be used to suggest that lobsters are unimportant to monk seals. Based on the NMFS annual assessment data, the number of lobsters is now a small fraction of what it was when the fishery started. As a known endangered monk seal prey species and a very depleted stock (due to fisheries, environmental causes, or both), lobsters should never again be fished in the NWHI.

Morioka dismisses the suggestion that the NWHI serves as a fish replenishment area for the main Hawaiian Islands based on one ocean current study. However, scientists are only beginning to discover the degree of interconnectedness between the MHI and the NWHI. Transport up and down the chain is very species-specific, and depends on many things, including complex currents, life history, etc. For example, the subsurface counter current running along Necker Ridge from the southwest to the middle of the archipelago is a likely transport mechanism for bringing back developing lobster larvae. WESPAC's own data indicate that deep waters snappers such as opakapaka are genetically identical throughout the Hawaiian chain. Additional genetic evaluations are being undertaken now to determine whether other species are genetically identical, and tagging studies have shown that ulua swim the open-ocean channels between islands. Many coral reef fishes such as goatfish and parrotfish are continuously depleted in the MHI because of overfishing by destructive fishing methods such as lay gillnet fishing and night SCUBA spear fishing, not because there is or isn't some replenishment from the NWHI. No amount of replenishment is going to bring these stocks back until these destructive fishing practices are limited or eliminated.

Of the 20-25 percent of marine species that are unique to the Hawaiian archipelago, most can be found in the MHI, although not in large numbers. These unique species dominate the ecosystems of the NWHI. The NWHI contain possibly the last large predator-dominated coral reef ecosystems on the planet. Despite their high latitude location, more species of coral have been reported from the NWHI compared with the MHI. Several species of the reef-building genus Acropora are locally abundant in the NWHI, but are not found in the MHI.

Reefs in the MHI are in serious trouble under the stress of alien invasive algae, which have over-grown many coral reefs. This hasn't happened in the NWHI largely because boat traffic has been low. Eighty percent of all invasive aquatic species are spread by vessel hulls. There are over 350 invasive aquatic species established in the MHI and every vessel traveling from the MHI to the NWHI has the potential of spreading them to the area -- the more traffic, the greater the threat. Already 12 invasive marine invertebrate, fish, and algal species have been recorded in the NWHI.

In terms of the amount of coral reef in the NWHI compared to the rest of the nation, the area of actual coral reefs or coral ecosystems in U.S. waters is not yet known. NOAA has estimates of potential coral ecosystem area based on depth curves, but not the actual area of coral reefs by location. NOAA has not completed comprehensive, detailed coral ecosystem (including coral reefs) maps for any location. For example, NOAA has mapped about 2,297 sq. km of shallow-water coral ecosystem around Puerto Rico, but there are still 465 sq. km of coral ecosystem area inside the 10 fathom depth curve that have not been mapped. In the case of the NWHI, NOAA has mapped 2,363 sq. km of shallow-water coral ecosystems, but there are still 2,197 sq. km inside the 10 fathom depth curve that have not been mapped. In addition, the NWHI have extensive areas of deeper water corals, including precious corals and certain stony corals that grow deeper than 10 fathoms (60 feet).

It is also not yet known whether the NWHI bottomfishery is ecologically harmless. It is highly likely that taking many thousands of pounds of bottomfish out of these cold water, low productivity coral ecosystems year after year impacts them. Furthermore, NWHI bottomfish populations may indeed be stressed, particularly in the waters around Nihoa and Necker Islands where stocks have declined to a "borderline" condition according to WESPAC.

In conclusion, we wish to add that science is not about "fishing" for data that support your self-interest or beliefs. It is about looking at all the available relevant data and drawing the most empirically and logically consistent conclusion based on the total picture. Our job is to protect this rare natural resource, one of the last wild places on earth.

june 8, 2024

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