Mariana Trench Monument Scientist Sign-On Letter

This is a letter that a group of scientists wrote in collaboration with the Friends of the Mariana Trench to support the proper management of the Mariana Trench Marine National Monument.  It was submitted to the Federal Register on July 26, 2021.

We, the undersigned, are scientists concerned with the proper protection and management of the Mariana Trench and the marine resources of the Pacific Ocean, and submit these comments on the Draft Monument Management Plan and Environmental Assessment.

We submit these comments with the leadership and local expertise of the Friends of the Mariana Trench, a local NGO which represents the voice of the local community and consists of a cross-section of indigenous and resident people of the Commonwealth of the Northern Mariana Islands and other interested parties who are dedicated to the conservation, preservation and protection of flora, fauna and geological features of the oceans; and the proper management of the Marianas Trench Marine National Monument.

The Friends of the Mariana Trench will submit detailed comments by the deadline, but we join them in bringing attention to the following themes:

The scientific community supports the preferred government alternative, Alternative 3 -- Prioritized Implementation of Action Plans. There is strong scientific evidence that marine protected areas benefit people and nature when they receive adequate funding and staffing (Gill et al, 2017). We cannot stress enough how the management plan needs to be formalized this year, as it will allow priority actions to be implemented sooner rather than later, and not allow another decade to pass without active management, and community engagement

The Management Plan should be fully accessible to all CNMI communities with summaries and fact sheets translated into Chamorro and Carolinian. We would like to see more prominence of the Chamorro and Carolinian cultures and people, the Indigenous residents and long-time stewards of the Mariana Trench, in the management plan. The first mention of the Indigenous owners of these resources is currently on page 22. We’d like to see the area mentioned as the “home of the Chamorro and Carolian people,” in the opening paragraph of page one and repeated throughout. The Executive Summary should also be presented in the native languages. Permit and filming fees should be returned to the MTMNM Management Team to provide outreach and educational resources directly to the local communities.

We support the government’s recommendation for CNMI and Guam residents being the only people allowed to apply for recreational, subsistence, and non-commercial fishing permits. There must be no loopholes to allow for non-residents to fish in the monument (i.e. allowing a non-resident to fish as long as residents are on board a vessel). The precautionary principle should apply to all fishing activities, and greater attention should be made to threatened or endangered species.

Permits should be required for scientific exploration or research activities by or for the USFWS or NOAA. Historically, there have been fewer than two fishing trips to the monument per year, and currently research vessels probably kill more fish than fishermen. There should be no loophole to allow for government fishing, scientific or otherwise, and proposed research activities should be made available for public inspection.

The management plan should make a specific reference to ending “parachute science” in the Marianas archipelago. Despite several dozen expeditions to the bottom of the Mariana Trench, no Indigenous Chamorro or Carolinian explorers or scientists have been a part of recent dives to the Mariana Trench. Research projects inside of the monument should have to include local researchers and cultural experts during all stages of science and exploration, starting with the planning process. A critical action item that is missing from the action items is to develop an onboard observer program to monitor activities aboard vessels permitted to conduct activities within the Monument to ensure that BMPs are being properly implemented. Research missions should also be contingent on providing outreach to the community pre- and post-mission concerning the purpose and results of the mission. This can be confirmed during the permitting process.

The Management Plan should reflect current science and all that we know today. Most of the references cited in the draft management plan are 10-15 years old, and a vast number of references are available to update the information and expand the discussion to include scientific advances and findings that have been made within the last five years. Additional public scoping should have been conducted. The last scoping meetings were held 8-11 years ago and many other activities have occurred in the Monument, including new permits and regulations. An opportunity to present oral comments in a way that is comfortable and welcoming for indigenous groups, such as the format used for tribal consultations, should be conducted before the draft is finalized.

The Management Plan should ensure accountability and transparency by giving people easy access to information such as permits, guaranteeing local oversight, and regular opportunities to evaluate management actions. The Management Coordination Team should have a standing stakeholders subcommittee to help with communication of issues to local entities, and a local outreach and education committee as there has been no permanent staff that work full time on MTMNM issues in CNMI. Include a well-developed Communications Action Plan that provides for regular communication through a variety of methods to local communities, indigenous groups, non-profits, educators, other partners, and stakeholders on all aspects of the management of MTMNM. We would like to see the management plan propose a process for developing a culturally appropriate name for the Islands Unit at a minimum, and possibly other Units. Literature suggests that communities can make deeper connections when cultural relevance is honored.

Thank you for considering our comments.


Dr. Stacy Baez


Nathan Smith


Dr. Chris Parsons


Liz Foote


Steven Mana'oakamai Johnson, Ph.D.

Ahmyia Cacapit


Maia Raymundo


Andrew Lewin


Dr. Diva Amon


Joni Miranda


Kevin He


Dr. Asha de Vos


Kent Elson Sorgon


Dr. David Shiffman


Dr. Paris Stefanoudis


Dr. Andrew Thaler


Emily Klein


Jens Currie


Angelo Villagomez



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