Why the Proposed Kelp Harvesting Permits Should Not Be Issued Without Independent Review

The California Department of Fish and Wildlife is considering a new round of commercial kelp harvesting permits for waters along the central and northern coast. The permits would allow mechanical harvesting of giant kelp (Macrocystis pyrifera) for use in the food, pharmaceutical, and agricultural industries. The application period is open. The environmental review is underway.

I am asking that the permits not be issued until an independent scientific review of the cumulative effects of commercial harvesting on otter foraging habitat has been completed. This is not a request to prohibit kelp harvesting. It is a request for the review process that should precede any significant expansion of extractive activity in a recovering ecosystem.

The case for review rests on three points. First, the relationship between kelp canopy density and otter foraging success is well established. Otters hunt in kelp forests. They use the canopy for rest, pup-rearing, and predator avoidance. Harvesting that reduces canopy density in areas of high otter use affects otter behavior and, potentially, reproductive success. The magnitude of this effect at different harvesting intensities is not well quantified.

Second, the proposed permits cover areas that overlap with the current and projected range of the recovering southern sea otter population. The recovery plan for the species, developed under the Endangered Species Act, identifies habitat quality as a limiting factor. Issuing permits that could degrade habitat quality in the recovery zone, without first assessing the impact, is inconsistent with the recovery plan's intent.

Third, the existing environmental review process for the permits does not include an independent scientific panel. The review is conducted by agency staff, with public comment. This is the standard process. It is not sufficient for a decision with significant implications for a listed species in a recovering ecosystem. An independent panel — composed of marine ecologists, otter biologists, and kelp forest researchers not employed by the permitting agency — would provide a level of scrutiny that the standard process does not.

The kelp harvesting industry has operated in California for more than a century. It has a legitimate place in the coastal economy. The question is not whether it should exist, but whether it should expand into areas of high ecological sensitivity without the review that would allow the expansion to be designed to minimize harm.

The permits can wait for the review. The kelp forest cannot wait for the permits to be reconsidered after the damage is done.