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A2. Provide Public Information to Restore Lost Fishing Services
[2-1](#provide-public-information-to-promote-wholesome-fishing-and-fish-consumption)

A2.1 Goals and Nexus to Injury [2-1](#goals-and-nexus-to-injury)

A2.2 Background [2-1](#background)

A2.2.1 EPA Institutional Controls [2-2](#epa-institutional-controls)

A2.2.2 The Role of MSRP [2-2](#the-role-of-msrp)

A2.3 Project Description and Methods
[2-3](#project-description-and-methods)

A2.4 Environmental Benefits and Impacts
[2-5](#environmental-benefits-and-impacts)

A2.4.1 Biological [2-5](#biological)

A2.4.2 Physical [2-5](#physical)

A2.4.3 Human Use [2-5](#human-use)

A2.5 Likelihood of Success/Feasibility
[2-6](#likelihood-of-successfeasibility)

A2.6 Performance Criteria and Monitoring
[2-6](#performance-criteria-and-monitoring)

A2.7 Evaluation [2-6](#evaluation)

A2.8 Estimated Budget [2-7](#estimated-budget)

Appendix A2

Provide Public Information to Restore Lost Fishing Services

# Provide Public Information to Promote Wholesome Fishing and Fish Consumption

## Goals and Nexus to Injury

The goal of this action is to build on the public outreach and education
work initiated by the U.S. Environmental Protection Agency (EPA) through
the establishment of the Fish Contamination Education Collaborative
(FCEC). FCEC is a federal, state, and local partnership project aimed at
addressing public exposure to contaminated fish in the Southern
California coastal area. The FCEC focuses on educating the public about
the human health hazards associated with DDT and PCB contamination in
fish. Thus, the FCEC program provides information to help people reduce
their exposure to DDTs and PCBs from the fish they eat.

The Natural Resource Trustees for the Montrose case (Trustees) will
expand this ongoing effort to increase fishing services by providing
information to anglers that allows them to make sound decisions about
where and for which species to fish. The Trustees will also provide
outreach materials that establish the link between the ecology and life
history of a particular species and its tendency to bioaccumulate
contaminants. This information would enable people to make knowledgeable
choices about where, when, and for which species to fish to minimize
their exposure to contaminants. This action has a strong nexus to the
ongoing loss of natural resource services caused by the contaminants of
the case (which have led to the imposition of state fishing advisories
and other limitations on the human use values of fish).

## Background

For several decades, high levels of DDTs and PCBs have been found in
several species of fish commonly caught by anglers along the Southern
California coast. White croaker, surfperches, kelp bass, and other
species of fish collected from several sites along the Los Angeles
County and Orange County coasts carry concentrations of DDTs and PCBs in
edible tissues that exceed the guidelines and standards set by federal
and state agencies for safe consumption (OEHHA 2003). This situation
represents a loss of natural resource value to the public and
constitutes a per se injury under the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) regulations for
damage assessment (Title 43 Code of Federal Regulations \[CFR\] Part
11.62).

The current state fish consumption advisories were established in 1991
for Southern California coastal locations between Point Dume and Dana
Point. These advisories identify eight species and species groups of
fish in eleven locations; anglers are advised to either not consume
these fish or limit their consumption of these fish (OEHHA 2003). In
addition to these fish consumption advisories released by the State of
California, the EPA and the U.S. Food and Drug Administration (FDA) have
released general fish consumption advisories for locally caught fish
(USEPA 2004b) that are based largely on mercury contamination.

The federal advisories suggest that in the absence of site- and/or
species-specific advisories generated by local governments, anglers
should consume no more than one meal per week of locally caught fish.
Thus, consumption of fish should be limited to a maximum of one meal per
week where data are absent or do not include mercury concentrations. If
data from the Montrose Settlements Restoration Program (MSRP)/EPA-funded
fish contamination survey identify species and/or locations where
contaminant levels are low enough that the consumption recommendations
may be increased to more than one meal per week (i.e., above the EPA/FDA
recommendations), this result would constitute a clear increase in
fishing opportunities for those species and locations.

Because contamination levels are not uniform but vary by location and
species of fish, and because existing data on fish contamination are out
of date and incomplete, it is difficult for anglers to make informed
choices about fishing and fish consumption. In some instances, this lack
of current information may result in anglers and those to whom they
supply some of their catch being exposed to DDTs and PCBs through
unknowing consumption of contaminated fish. The EPA's current outreach
program specifically addresses such incidences. However, in other cases,
the lack of current and complete information may lead potential anglers
to alter their fishing habits or avoid fishing altogether out of concern
about fish contamination and the uncertainties surrounding it. This
issue is the one on which the Trustees will focus their attention.

### EPA Institutional Controls

The EPA established a program of institutional controls (ICs) in 2001 as
a set of initial actions to address the immediate human health risks
associated with the consumption of fish contaminated with DDTs and PCBs
from the Palos Verdes Shelf. Public outreach is one component of the ICs
program.

The objectives of the public outreach program established by the EPA are
to reduce the health risks associated with eating fish contaminated with
DDTs and PCBs by increasing awareness and understanding of fish
consumption advisories and building local capacity to address fish
contamination issues. To implement this work, the EPA convened a Seafood
Contamination Task Force, which is now known as the FCEC. The FCEC is a
consortium of federal, state, and local government agencies, local
institutions, and community-based organizations that provides a means of
coordinating the development and implementation of a public outreach
program with direct stakeholder involvement at all levels. The FCEC also
serves as a decision-making body for the public outreach and education
component of the ICs program and serves in an advisory role to the EPA
on other Palos Verdes Shelf IC activities.

The EPA started the full implementation of the public outreach and
education program in January 2003. The MSRP Trustees have been an active
partner in the FCEC from its beginning and have consistently provided
technical support and materials for the program. The materials provided
by the Trustees were used as part of an outreach pilot project that was
designed to evaluate the viability of outreach as a restoration action.
The response to these materials has been overwhelmingly positive, with
numerous requests for additional and updated materials.

### The Role of MSRP

With adequate fish contamination data, it is possible to identify and
promote optimal fishing opportunities and thus increase public use and
enjoyment of fish services. Furthermore, by expanding the information
available to encompass other contaminants that are of general concern
with regard to fish consumption (e.g., mercury) and including analyses
of fish that are less likely to be contaminated, more complete advice
regarding the risks and benefits of eating fish can be provided to the
public.

This action complements and expands on the current outreach efforts
spearheaded by the EPA, which focus on warning citizens about where they
should avoid fishing or which fish they should avoid catching and eating
based solely on DDT and PCB concentrations. The EPA is not able to
include analyses of and therefore outreach regarding mercury due to
limitations imposed on them by Superfund laws. Although the information
generated by the EPA's outreach efforts is a critical component of
addressing the human health risks associated with consuming fish, this
information provides limited guidance regarding what is safe to eat,
largely because the basis of the information is limited to DDTs and PCBs
and species that are particularly highly contaminated by DDTs and PCBs.

## Project Description and Methods

Public outreach and education is a key strategy of the MSRP on a number
of levels. The MSRP already employs outreach and education activities as
a means of involving the public in restoration planning and plans to use
these activities to keep the public informed and involved as restoration
implementation proceeds (see Section 5.4.1 of the Restoration Plan).
Under the category of fishing and fish habitat restoration, public
outreach and education is proposed as a specific action for restoring
lost natural resource services by providing information to people that
allows them to make knowledgeable choices about where to fish, and what
to fish for. This information differs from, and will complement, the
critical information generated by the EPA regarding fish species and
locations to avoid.

The program to provide public information to restore lost fishing
services would be designed in close coordination with the existing FCEC
organization, with the goal of integrating contributions from both MSRP
and the EPA into a common and complete message. MSRP would continue to
work in close partnership with FCEC and take advantage of many of the
existing programs, points of contact, outreach materials, and other
aspects of the FCEC. This approach would reduce public confusion, reduce
the potential for these agencies to send out mixed messages, and
potentially result in substantial cost sharing.

As natural resource agencies, the agencies that serve as the Trustees
will also develop outreach materials that provide a link between fish as
living marine resources and the risks and benefits they provide to their
consumers. Contaminant bioaccumulation rates largely depend on the
specific ecological and life-history strategies of a fish. Factors such
as habitat use, migratory behavior, age, size, foraging mode, and
preferred prey all play a critical role in the level of health risk that
a fish imposes on its consumer. Thus, if anglers learn about the ecology
and life history of the fish that they typically encounter, they can
enable themselves to make more informed decisions about what to eat and
what to throw back.

Gathering updated and accurate information on the levels of
contamination in the fishes inhabiting the coastal waters of the
Southern California Bight is essential if the Trustees are to provide
public information on the species that are safe to target for fishing.
This gathering process includes continuing to identify and investigate
the species that may not impose significant human health risks. Updated
information will enable the Trustees to distribute better information to
anglers about the species and the locations for fishing that offer
minimal contaminant-related threats. Also, if contamination levels have
changed since the data for the current advisories were gathered (1987),
some advisories my need to be revised or eliminated.

In collaboration with the EPA, the Trustees have already implemented a
survey of fish contamination levels for 23 species or species groups in
the area from Point Dume to Dana Point. This data set, once analyzed,
will provide a context for the development of restoration projects and
highlight the areas that need additional sampling to better understand
where restoration activities may be implemented or where the
contamination levels are particularly dynamic (e.g., at the edges of the
highly contaminated areas).

The specific activities and products of the public information program
on fishing will be developed in a work plan once this Restoration Plan
has been approved. Although the Trustees will not provide funds to
construct specific facilities or support specific staff positions, the
budget for the project mentioned above will include a portion to fund
the design and production of outreach materials, including stationery or
traveling graphic exhibits for learning centers and associated
literature for dissemination, signage, advertising spots, public service
announcements, pier outreach, or other such activities to dispense
information to the public. The Trustees hope to cooperate with the
following groups in this endeavor:

-   Palos Verdes Peninsula Land Conservancy (PVPLC): PVPLC submitted a
    proposal requesting supplemental funding to construct an
    interpretive center at the White Point Nature Preserve. Although
    MSRP will not fund the construction of specific facilities, the
    Trustees agree that because this center will be located near the
    wastewater outfalls where the contaminants of the Montrose case
    originally entered the marine environment, this center would be a
    prime location for an educational exhibit. Another reason why the
    center would be a prime location for an exhibit is the potentially
    large number of people affected by the Montrose contaminants that
    the center would be able to reach.

-   Marine Mammal Care Center (MMCC)/Center for Marine Studies (CMS) at
    Ft. MacArthur: MMCC and CMS submitted several proposals for funding
    for educators and for transportation to expand their current
    outreach and education programs. Although MSRP will not fund
    specific staff positions or transportation, the Trustees feel that
    the location and missions of the MMCC and CMS make Ft. MacArthur
    another well-suited place for educational exhibits.

-   Other groups: The following list shows groups the Trustees currently
    work with and other groups that the Trustees hope to work with in
    the future to develop and disseminate additional outreach materials:

    -   FCEC

    -   Cabrillo Marine Aquarium

    -   Long Beach Aquarium of the Pacific

    -   EALab

    -   Channel Islands National Park

    -   Channel Islands Marine Sanctuary

This list is by no means exhaustive and will grow to include other
groups as outreach opportunities are identified and expanded.

## Environmental Benefits and Impacts

### Biological

#### Benefits

Because this action involves public outreach and education rather than
directly affecting biological habitat or organisms, the Trustees do not
anticipate any direct benefits to biological resources. However, as part
of their message, the Trustees intend to encourage conservation-minded
fishing (including the careful handling and release of fish that are not
retained by anglers for consumption), which may provide benefits to fish
populations.

#### Impacts

Because this action involves public outreach and education, the Trustees
do not anticipate any direct adverse impacts to biological resources.
Should the public information lead to changes in fishing practices in
the region, it is possible that fishing exploitation of certain cleaner
species of fish would increase. It is also possible that the public
information that the action provides may lead to increased exploitation
of fish populations in locations identified as having fish lower in
contamination. The degree to which this public information program would
result in increased fishing mortality of certain species and/or at
certain locations is not expected to be significant. However, the
Trustees will consider both contamination levels and vulnerability to
over-fishing as factors when they provide fishing advice to anglers. The
Trustees will not advise anglers to focus fishing activity on any
species that is currently over-fished or at risk of future over-fishing
due to population status or specific life-history characteristics that
might make that species more vulnerable to over-fishing. Also, the
Trustees will encourage anglers to comply with all state fishing size
and bag limits that are established to ensure sustainable fishing.

### Physical

#### Benefits

This action will not have benefits with regard to geology/earth
resources, water resources, oceanographic and coastal processes, air
quality, or noise.

#### Impacts

This action will not have negative impacts on geology/earth resources,
water resources, oceanographic and coastal processes, air quality, or
noise.

### Human Use

#### Benefits

The development and dissemination of better data on fish contamination
(including information on the locations and species of fish that offer
reduced contaminant-related risk) will lead to improved recreational
benefits for anglers and could potentially lead to improved human use of
ocean fish resources. By clarifying the current state of contamination
in fish and providing advice to anglers about locations and species that
do not trigger health advisories, this action directly addresses the
loss of natural resource services caused by elevated levels of
contamination that have led to the issuance of directives to limit or
ban consumption of several species of marine fish.

#### Impacts

Because this action focuses on providing information that will tend to
promote fishing rather than restrict fishing, the action will not have
negative impacts on human use. The action may have minor impacts to
aesthetics depending on the design, size, and placement of signs. The
designs of the program signage would be adopted from the previous
designs developed and employed by the State of California and the county
health departments in the study area. The signs would be placed in
consultation with appropriate local authorities and in coordination with
groups conducting outreach activities (such as the FCEC) in such a way
as to minimize any impacts to the aesthetics of the surrounding area and
avoid duplication of signage and/or message.

## Likelihood of success/Feasibility 

Education and awareness programs, through their display signs and
brochures, nearly always attract public attention. Successful public
educational programs instill knowledge and appreciation of the subject
considered. This approach has a high probability of increasing human use
and enjoyment of fishing resources in the targeted areas.

## Performance Criteria and Monitoring

Public feedback and reaction will be the primary means of monitoring the
success of the outreach and educational activities of this action. The
action will require the periodic updating and replacement of outreach
materials to be effective over time due to the dynamic nature of
contamination levels in the fish and changes in state fish consumption
advisories.

## Evaluation

Lack of public awareness about where fish contamination is a problem
along the Southern California coast has significantly contributed to the
loss of the natural resource services that fishing provides. Current
outreach efforts spearheaded by the EPA provide critical information
regarding the risks imposed by DDTs and PCBs, but do little to restore
the faith in the resource itself, in general due to the EPA's inability
to seek out fish that provide minimal human health risks. The Trustees
have evaluated this action against the screening and evaluation criteria
developed to select restoration actions and have concluded that this
action is consistent with these criteria. The Trustees have determined
that this action will provide immediate benefits to human uses of
injured natural resources and will be a cost-effective means of
restoring the lost fishing services that have resulted from the
contamination at issue in the Montrose case.

## Estimated Budget

The Trustees will develop a work plan for public outreach and education
efforts on fishing that addresses the specific components of the action
and assumes close collaboration with the FCEC. For planning purposes,
the Trustees have initially assumed that approximately \$1 million would
be used to conduct outreach, develop and produce materials, obtain and
review additional contamination data, and perform other activities
related to this restoration action.