A fifteen mile boundary line has been carefully located to include the waters within the primary foraging radius of the California brown pelican, an endangered species, and other breeding seabirds on the islands, and to provide protection to the unique assemblages of bottom dwellers in the transition zone. This choice of boundaries in relation to the range of species and the location of habitats is in response to the legislative intent of the Marine Protection, Research and Sanctuaries Act, that a sanctuary's size should be that necessary to protect the values for which it was established. In addition, the size of the area responds to the functioning of the Channel region as a unit ecologically, hydrographically, and perceptually in the minds of those who exploit and enjoy its resources. Birds and mammals forage in several feeding grounds within the Channel and around the islands, although they nest and breed in a few specific places. Current circulate independently within the Channel, carrying nutrients and pollution with them throughout the Channel's waters. Actions in one location in the region can and do affect all other areas. The offshore island and basin topography of Southern California is unique in the North American continental shelf, and has created an uncommon diversity of habitats for the support of marine organisms. The west coast of cont intental United States is in one of the world's areas of upwellings, where the productivity of the oceans is concentrated due to the increase of nutrients available in the water. The Santa Barbara Channel is a particularly important portion of these waters because of its location as the focus of the California transition zone. There are a handful of places in the world's oceans where two major marine provinces meet and intermingle. New species evolve or older ones survive in these places, greatly increasing their biological aiversity. The combination of topography, upwellings, and transition zone dynamics have made the Santa Barbara 3. Also, along the same lines as above, impacts to the coastal communities, if such a sanctuary were to be established, should be discussed thoroughly. 4. We disagree with your viewpoint that the EIS process is "on the wane." Section 102 of N.E.P.A. is an important process that also allows the public to challenge the administrative decisions of government, and is being used as such throughout the nation. It should not be discounted too lightly. 5. Realizing that this document is preliminary, we would still like to comment that the implementation strategies are not well defined. 6. Finally, the cost of the management of the proposed sanctuary appears to be unrealistically low, especially for the "daily management." A more detailed analysis should be included. Thank you for allowing us the opportunity to review and Sincerely. Gorge Fuler GBORGS FOWLER Acting City Manager /et |