Discussions with the CDFW clarified that MPA spacing is measured by the, “shortest distance over water between two MPAs.” When measuring the distance between Campus Point and Point Dume, we find that it is in fact less than 62 miles, indicating that the current spacing distribution is adequate along the coast (see below Image 2).

Following the CDFW and MLPA guidelines, the shortest water distance between the two existing MPAs is ~60.60 miles, viewable by the orange line. This distance falls within the 31–62-mile MLPA spacing requirement. None of the provided measurements, including a measurement along the coastline (yellow) exceeded 73.4 miles of separation as the petitioner claims, again bringing into question the purpose for the new MPA if connectivity is already met.

In addition, the provided shore based take of finfish does allow for some form of recreational take but this now raises connectivity concerns. As mentioned in previous petitions, allowance of shore fishing of finfish reduces an MPAs LOP to moderate-low, losing its MPA connectivity with the network, this is confirmed by SeaSketch. Connectivity was a major reason for this MPAs proposal. With connectivity now lost due to these allowed take methods begs to question the purpose for this implementation in the first place if its foundational goals are not even accomplished. The LOP chart for the southern bioregion, moderate low protection is provided below.

Regarding the protection of juvenile white shark nursery grounds, a similar petition was submitted in 2020 (Petition 2020-012 AM1) to close off a smaller section of beach at Carpinteria for the same purpose. Like Petition 29, this earlier petition aimed to protect

juvenile white sharks within the currently proposed area. This 2020 petition was rejected by the Department and the Fish and Game Commission (FGC), which stated that MPAs are designed to protect nearshore ecosystems rather than individual species, especially highly migratory species like white sharks. Given that this issue was previously addressed at the same location just four years ago, the same arguments against the current petition apply today regarding white sharks.

Lastly, regarding the tribal access portions of the petition, while tribal access and co-management should be explored across the entire MPA network, current access to the area by tribes is not limited in any way. Regardless of a tribal MPA designation or not, federally recognized tribes will have access in the area just like the public. Closing this area off to all groups except those of the federally recognized Santa Ynez Band of Chumash Indians would have the additional side effect of restricting any non-federally recognized tribes, as the petition does mention. In addition to the above counter reasons of the petition’s primary claims, there exists additional effects to be considered at the proposed MPA site. The proposed area was considered during the MLPA for the southern section but was

traded off for two other SMCAs on the coast, Naples and Kashtayit that were present in different MPA alternatives that Carpinteria was not in. If allowed, the new MPA would essentially break the agreements struck during the MLPA. Lastly, the pre- and post- amended boundaries overlap existing oil infrastructure that is maintained year round, no existing exemptions or conversations have been had regarding this infrastructure overlap. For these reasons we believe the petition should be denied.