The basic element of environmentalism is to recognise that resources our limited.  This is especially true with the Bermuda Government headed toward bankruptcy.  Therefore I strongly oppose the Blue Halo concept and urge the government to focus its limited resources on either debt/deficit reduction, social issues, or dealing with the “Brown Halo” of current urgent threats to Bermuda's environment (I have listed 12 at the end of this submission).

To readers, I apologise if I repeat anything and I apologise for not having a stronger basis for some of my thoughts.  However, I am a concerned private citizen and environmentalist doing in this my free time and not a paid lobbyist.

I believe that the public and supporters and advocates for the Blue Halo are often not properly informed of the scale and strength of current protection of Bermuda’s waters.  From the weak and dishonest basis of the conclusions of PEW's Economic Assessment to the attempt to link the Blue Halo to Bermuda’s reef in PEW’s "Cultural Implications of a Marine Reserve” there is a pattern of misinformation by PEW and the Blue Halo organisation.

We are all desperate for tourists and the Blue Halo advocates have promised tourism, and so many Bermudians have jumped on the bandwagon in the name of tourism.  However, PEW’s consultants and reports appear to have either fabricated tourism numbers, or produced estimates from case studies in which there was no pre-existing visitor centre or protection.  Bermuda already has a highly protected environment, and already has the visitor centres, and so we should look to the marginal increase in tourism which is more likely to be minimal if any and nowhere near what’s necessary to cover the costs of the Blue Halo.

Blue Halo advocates have made arguments for enforcing existing laws, banning long-lining, and branding Bermuda to promote eco-tourism but we must not confuse those issues with a no-take reserve.  My overall impression is that there do not appear to have been any arguments made for the creation of a no-take marine reserve.  Jumping straight to the extreme option of a no-take reserve, is like saying you are too cold, so we should set the house on fire. It’s an extreme option, and all of its aims can be achieved in ways that are not destructive to Bermuda’s economic future.

Given the current framework of million dollar fines and flexibility in Ministerial discretion in enacting specific protections of an area or species we already have most if not all of what we need to achieve the environmental protection that the Blue Halo claims to provide.  As I will discuss in more detail later, the tourism claims of the Blue Halo are overly optimistic at best and outright fabrication at worst.  Therefore in a practical real-world sense everything offered by the Blue Halo then is a branding and marketing campaign that we could easily do with a self-directed marine reserve or a tourism campaign.  

I don't find PEW's claims about illegal fishing to be credible.  If there is a major problem it should be easy for advocates to show a satellite photo of a foreign fishing fleet moving through Bermuda’s waters.  I think that with three years to prepare a case for the Blue Halo their failure to produce any specific evidence speaks volumes.  With modern smart phones it is very easy to take a GPS tagged video of an industrial fishing vessel as irrefutable that we have proof of a problem - of course, we could then prosecute them under existing laws and wouldn’t need the Blue Halo.

At a recent public forum their representative held up netting and a hook allegedly as proof of illegal fishing and claimed that he had seen a foreign industrial fishing boat in Bermuda’s waters.  I have to ask, why didn’t we go seize that ship and fine its owners $1m as we’re allowed to do under current legislation?  Hooks and nets washing up aren't evidence of fishing in the EEZ as pelagic fish carrying long-line hooks can travel thousands of miles and nets can be carried by the Gulf Stream at over 4 knots under the right conditions.  At 4 knots a net can make the journey from the Caribbean to Bermuda in under a week, and take less than two days to go from the edge of our EEZ to South Shore.  

Their representative has made the claim that a no-take reserve would “shift the burden of proof” from the local authorities to illegal fishermen.  This is garbage.  If someone is fishing illegally in Bermuda’s waters then with current GPS technology we should have no problem proving that they were.  If we would be unable to successfully seize their vessel and/or prosecute them then these are problems with enforcement and the judiciary, neither of which have anything to do with the Blue Halo.

PEW's economic claims are the least credible of all.  Public statements, their Economic Assessment paper, and their Executive Summary have all placed wildly different estimates on costs and benefits and nowhere does there appear to be proper accounting of the real enforcement costs.  I take this to mean that PEW has no faith in the numbers from their economic assessment or any other document and so neither should we.

PEW and advocates of the Blue Halo have been deliberately misleading by:

- Making up Blue Halo related tourism numbers out of thin air

- Falsely mixing the value of the Blue Halo and Bermuda's reef

- Understating costs

- Overstating benefits

- Understating or ignoring existing legislation

Some other concerns/thoughts:

- There are higher priority projects than the Blue Halo.

- Current legislation provides for $1m fines and the seizure of the vessel for illegal fishing.  Why is this insufficient?  How does a no-take reserve make fishing more illegal?

- Current legislation provides for a Marine Resources Board to advise the Minister when action is needed to protect a species or an area.  Why was it necessary to engage in public consultation?  What is the Marine Resources Board’s recommendation?

- The proposed Blue Halo will make criminals of the only tourists who currently use the outer 150 miles of our EEZ: passing fishing and cruising sailing boats who generally fish while in transit to Bermuda.

- Civil Servants' time is not free.  A fortune has undoubtedly already been spent in time and energy in the public consultation and the three years beforehand.

- We were told that Civil Servants would be "repurposed" to implement the Blue Halo.  What are these people doing now?  What will not get done because they are working on the Blue Halo?  (PEW and the government have made conflicting statements on this).

The specific documents posted by the Blue Halo advocates on bermudabluehalo.org are generally inapplicable to the Blue Halo concept and riddled with spurious conclusions or outright fabrications.  I will deal with some of them below:

Economic Impact of the Bermuda Blue Halo - An Exploratory Assessment

(http://media.wix.com/ugd/6d304e_2a6f67f5ea5dbf8af2ff25ca011aef84.pdf)

Economics is a key concentration of my academic and professional work so I am more qualified to make a judgement on this document than the scientific case.

The economic report released by the Blue Halo is weak.  It fails to account for current legislation, makes conclusions without a strong basis or without any basis at all, and if read with a critical eye is an an embarrassingly poor document which I believe makes deliberate attempts to lead readers to false conclusions about the positive benefits and costs of the Blue Halo:

- In many cases it seems to draw conclusions from the assumption that there is no current environmental protection legislation or ocean related tourism and therefore attempts to value the total possible benefits rather than the marginal benefits over the current situation or what is possible without creating a no-take reserve.  

- Fails to consider the impact of interest on costs since the Bermuda Government is borrowing every marginal dollar. With interest at a long-term norm of 6% the 10 year cost of every dollar of spending is roughly $1.50 equivalent.

- Big game fishing is a very valuable summer tourism product, and only grows with time as Bermuda gains greater recognition.  A no-take reserve will discourage these high dollar visitors.  Each boat visiting Bermuda is estimated to spend $150,000 in a month’s stay.  Nowhere is there a consideration of the cost of this loss if boats are discouraged from coming.

- A small but significant percentage of Bermuda’s high value air arrival tourists (approx 5%) come to fish.  If people are wrongly informed about the Blue Halo and have the mistaken impression that Bermuda has banned offshore game fishing then the loss of tourism alone may outweigh the tourism benefits of the Blue Halo (if any).

- Bermuda is currently on its way to being recognised as the Blue Marlin Fishing Capital of the World having won the Blue Marlin World Cup a record number of times. 

- The report admits that there is virtually no economic activity (fishing) in the proposed reserve and then infers that marine reserves improve fish stock which then migrate into unprotected areas.  If there is already no fishing, how will a reserve have any marginal benefit?

- No actual supported basis for how a no-take reserve will provide significant marginal protection over existing laws.

- Attempts to place an economic value of Bermuda's reefs, and falsely infers that the Blue Halo will protect the reef value.

- PEW list 5 primary benefits of the Blue Halo and admit that the benefits may be only roughly estimated at best.  I also question why we need a no-take reserve to achieve any of them.  They are:

  1) the net impact of the media attention and consequent increases in visitor arrivals; 

a) Why do we need a no-take reserve to do this?  This is an admission that the Blue Halo is primarily a PR exercise.  A simple Google News search for "Bermuda Blue Halo" shows only local news sources.  This seems to imply that so far the Blue Halo has failed to garner significant international interest.  It seems that the world is not watching. http://www.google.com/#q=Bermuda+Blue+halo&safe=off&tbm=nws  The Blue Halo has, however earned negative press in Billfish Magazine which reaches our highest value tourists - the international game fishermen who spend an average of $150,000 a month in Bermuda for the summer months.

b) PEW goes so far as to make up numbers of the % increase in overall tourism out of thin air.  Anyone can make up numbers.  Comparables used to estimate increases in tourism were totally dissimilar, using a festival/giving journalists tours as a basis for their estimate, neither of which have anything to do with a no-take marine reserve.  This is the worst kind of faux-economic logic.  If a group is willing to use such dissimilar events to make up numbers we should seriously question their honesty.  It is also worth noting that in the public presentation at the Hamilton City Hall in October 2013 Blue Halo director Chris Flook cited an entirely different and far more favourable tourism increase number, but one no doubt equally speculative and without any objective basis in reality.  In PEW's Executive Summary there is yet another number.  All are presumably equally worthless of an indicator of the real positive benefit.

  2) direct and indirect spending at dedicated exhibits;

We already have exhibits in the Aquarium and BUEI.  Cited case studies where a visitor centre was built and attracted tourists such as Papahnaumokukea Marine National Monument are therefore not relevant because we already have these visitor centres.  We would need to look at the marginal improvement, which will undoubtedly be orders of magnitude lower.  This is also the fatal weakness of the "General Business Model for Marine Reserves" paper cited by PEW. 

  3) visits by research scientists and students; 

We already have BIOS, and "personal conversations" are not reliable sources for an economics paper.  Second, it cites possible "high-end" tourism where "pseudo-scientists pay to accompany scholars in submersibles or perhaps in the BIOS research vessel".  Why can't that be done now without a no-take reserve?  A submarine already tried and failed to become profitable in Bermuda. 

  4) potential payments for carbon offsets;

Again, why can't we do this without a no-take reserve?

  5) biological support for the fisheries, turtles, birds, and other species

Again, if there is virtually no current fishing how will a no-take reserve provide a marginal benefit?  Why are current protections inadequate?

... continued criticism of the Economic Impact Report...

- Makes the claim that "illegal fishing...would be less likely if a reserve were created and the area policed more thoroughly".  Of course there would be less illegal fishing if the area were policed more thoroughly, but why do we need a no-take reserve to do that?  Why are existing laws inadequate?

- The section on policing fails to mention that existing laws allow for policing, seizing, and fining offending vessels and that the cost of surveillance could with current law be offset by fines.  It also includes no estimate on the cost of seizing a vessel or how that might be accomplished, and no estimate of the potential fines making this another baseless assertion.

- Table 4: Annual Management Costs do not include debt service, which would increase costs by roughly 50% over 10 years, making the $691,788 figure for annual management closer to $1.05 million in actual expense to the Bermudian taxpayer.  Over 10 years that would mean $10,500,000 in additional taxpayer expense.  Note that the estimated cost cited in PEW's Executive Summary "Scientific, Economic, and Cultural Assessments: Bermuda Blue Halo Marine Reserve" cites an entirely different figure for annual expense so apparently they aren't even willing to rely on their own economic study.

- Table 4: Annual Management Costs of ~$700,000 do not include any money for enforcement.  It seems to be purely administrative staffs salary costs: managers, administrators, technicians, and clerks.  None of which seem to be an enforcement title such as "Warden”.  Presumably in addition to salaries we would also be paying for their office space, insurance, pension, interest on the debt incurred, and other costs so we can safely say that the costs have been wildly understated for personnel alone.

- Table 4 contd.:  Notably absent are costs for satellite surveillance or policing vessels, presumably both of which would be many hundreds of thousands or millions of dollars annually, to say nothing of the capital expense of purchasing aircraft and/or an enforcement fleet.

- The telephone survey cited in the report to measure potential increase in tourism numbers found that people would be more likely to visit Bermuda in "a scenario where Bermuda legally protected its endangered species” and less likely in situations that involved “bycatch of turtles and seabirds” or “ocean floor mining”.  Since we already legally protect endangered species, restrict techniques with bycatch, and have no undersea mining, this survey question is like asking people if they’d be more likely to come to Bermuda if we had pink sand beaches.   It in no way supported the creation of a no-take reserve.  At best it suggested that Bermuda further educate visitors of the decades old environmental protections that Bermuda already has.  

The takeaway here is that in this document PEW has again and again tried to overstate the case for the Blue Halo and deliberately mislead readers about the impact that the Blue Halo would have on our island.

The Protection and Management of the Sargasso Sea

(http://media.wix.com/ugd/6d304e_b3abe8245b7094de439237e1d2f72e68.pdf)

This document has literally nothing to do with creating a no-take reserve around Bermuda.   I’ll repeat that: Nowhere does it make a case for a no-take reserve.  We already have the Fisheries Act, the Marine Mammal Sanctuary, Marine Resources Board, etc.  Why are these inadequate to protect the Sargasso Sea within Bermuda’s jurisdiction?  It is an interesting document about the ecology of the Sargasso Sea but but at best it is an argument for better policing of Bermuda's offshore waters.  Even then it fails to make the case that there is significant pirate fishing or sargasso harvesting threatening the small pocket of the Sargasso Sea within Bermuda's EEZ.

Conclusion

Before taking any further steps we should conduct an honest, sober assessment of our national priorities and place the Blue Halo at the bottom of our list where it belongs, behind feeding families, paving roads, educating students, preventing crime, putting fuel in our Fisheries boats, and cutting the grass at the St. George’s Golf Course! 

I am a private Bermudian citizen and environmentalist with no agenda beyond a passion for what is best for my beloved island.  I'm not a fisherman, not a miner.  What I want is for Bermuda to have its priorities straight and the Blue Halo seems to be the ultimate case of putting the cart before the horse.  It is unfathomable to me that we are spending time and resources on the Blue Halo when Bermuda has blatant illegal fishing going on in our Coral Reef Preserve on a Sunday afternoon in September while the Fisheries boats are moored in Castle Harbour (and yes, I saw this).

Alternatives

Personally I would strongly urge the Bermuda Government to focus on the "Brown Halo" around Bermuda.  These are the real, current, and urgent threats to our inshore waters, reef, and island.  Here are 12 current environmental problems that I believe should be higher priority than the Blue Halo:

- Raw sewage dumping into the ocean from the cities and hospital ending up on our South Shore beaches.

- Lionfish infestation of our reef.

- Growth of Mexican Peppers replacing virtually every tree on the island.

- Illegal fishing/lobster diving within the current protected areas on the reef platform.

- Pollution of Mill Creek to dangerous levels by the Pembroke Canal.

- Ignoring bag limits for lobster diving and spearfishing.

- Poorly stored and un-disposed of asbestos at the airport and public works quarry.

- The unsightly and environmentally damaging airport dump.

- Raw sewage dumping in Mangrove Bay and Paradise Lake and resulting dangerous bacteria levels.

- Oil and other chemical pollution at Morgan's Point and former bases.

- Coastal erosion undermining the island's cliffs.

- Lead acid batteries and other toxic trash at the Sally Port Dump.

...and no doubt many many more.

Thank you for reading, feel free to contact me.

Alex Jones

c: 333-2753