A Public Comment for the
Papahanaumokuakea Marine National Monument
Draft Management Plan

I have just (yesterday) left the Papahanaumokuakea Marine National Monument after a recreational visit. I am submitting these comments from the standpoint of private boats, primarily small sailboats, visiting the Monument on recreational permits.

The Midway Atoll is a spectacular place. As a national monument, it should be accessible by the public. Unfortunately, the permit system as currently established makes it very difficult for people to visit the monument, especially those on private boats.

1. In order to visit the monument in June, we were required to submit a complex application in January. Even so, we did not receive our approved application until June 10, two days before our departure for Midway. This is unacceptable.

A private boat should receive a permit in just a few days after application. The rules and limitations on visits by recreational boats should be determined and made public by Midway Atoll. There is no reason for a public comment period on such a recreational visit that does not request unusual activities.

A private boat should not be required to submit an application months in advance. A standard application for a recreational visit should be allowed two weeks before a visit, although the approval would be contingent on space available at Midway, and the applicant would be required to meet the inspection and other requirements.

2. The Monument is a public resource, and should be available to the public in general. I should not be required to justify "how my visit will help the Monument" or write how I will accomplish my activities "in complete sentences," as is currently required. The Monument should be open to everybody, and you should not be requried to pass an examination first. I have never heard of a U.S. National Monument with this kind of barrier to entry.

If a person visits the Monument for tourism and recreation, that should be enough information for the Monument. The following application questions are completely inappropriate.

  • "Is there a practicable alternative to conducting the activity within the Monument? If not, explain why your activities must be conducted in the Monument."
  • "How does the end value of the activity outweigh its adverse impacts on Monument cultural, natural and historic resources, qualities, and ecological integrity?"
  • "Explain how the duration of the activity is no longer than necessary to achieve its stated purpose."

Questions such as these indicate a mindset of keeping everybody out of the Monument, except as a last resort. Instead, the public should be automatically entitled to visit, within reasonable rules.

3. Private boats visiting the Monument are required to install Vessel Monitoring Systems. There is a system approved and available that costs $1,500. However, we were required to purchase a $3,000+ model which included a terminal we had no need for and never used. Furthermore, we were required to pay several hundred dollars to a company in Honolulu for installation, costing more than $4000. Only only company was authorized to do the installation, and I was not allowed to install the VMS, even though it is not a difficult installation. (It is generally a bad idea for the government to require people to do business with a specific company.)

An extra $4000 is cost prohibitive to the majority of people who desire to visit the Monument on private boats. VMS systems should be made available for a reasonable price. The Monument could loan or rent VMS systems to visitors, or at a minimum the lower-priced $1,500 model could be used and personal installations allowed.

4. Information on facilities available to private boats should be made public. A holding tank pumpout service should be available to allow more and especially smaller boats to enter the no-discharge zone. There is a requirement for a fuel boom, which costs several hundred dollars, when fueling recreational boats. This requirement is unnecessary and should be removed for boats with limited fuel capacity, maybe 500 gallons or less.

5. Non-commercial fishing from private boats for food to be consumed on the boat should be allowed throughout the monument, with the possible exception of Special Management Areas and within three miles of the islands.

6. (This is a minor point.) The name "Papahanaumokuakea" is too long and hard to remember. Some spaces would improve it (Papahana umoku akea), or possibly using "Northwest Hawaiian Islands" in conjunction with or as an alternative to Papahanaumokuakea.

Midway Atoll and the Papahanaumokuakea Marine National Monument are public resources, and should be treated as such. As it stands now, it is very difficult for ordinary people to visit the Monument, particularly on private boats. The perception that the Monument exists primarily for a select few government personnel should be avoided, and the barriers to entry for the public should be reduced to a level consistent with national parks and monuments around the country.

Robert Webster, Sunday, June 29, 2008