1. FROM THE DESK OF
LINDA LINGLE
November 29, 2011
National Oceanic and Atmospheric Administration
1401 Constitution Avenue, NW
Room 5128
Washington, D.C. 20230
To whom it may concern:
I have been made aware of a recent proposal by the Department of the Interior
and the National Oceanic and Atmospheric Administration (NOAA) to make 4,787
square miles of land and water in Hawaii a federal critical habitat for the Hawaiian Monk
Seal. This action is another example of government over-reach and insensitivity to the
concerns of the people of this State.
I am calling upon the federal Department of the Interior to postpone this action
until such time as the economic and social consequences to the people of Hawaii are fully
understood and addressed.
While I support efforts to protect and preserve endangered species, such as the
Hawaiian Monk Seal, these efforts should be carried out with a sensitivity to the people
and activities they impact. And they should be based on extensive public input and solid
economic and scientific data.
I understand that the proposal by NOAA is to designate almost the entire coast-
lines and surrounding waters of Oahu, Hawaii, Maui, Kauai, Molokai, Lanai, Niihau and
Kahoolawe as a critical habitat for monk seals. The designation would include the shore-
lines up to 16 feet inland and the oceans out to a depth of 1,640 feet. The total area
would cover 4,787 square miles. To put this into perspective, the entire State of Hawaii is
6,459 square miles. The habitat would be equal to almost 75% of the size of our State.
NOAA published the proposed rule last June in a Federal publication that few
citizens read: The Federal Register. They gave the public only 60 days to respond to a
proposed rule that could last for over 50 years. Only after receiving letters from elected
officials who were alerted by concerned fishermen, native Hawaiian groups, and commu-
nity activists, did NOAA agree to re-open the public comment period.
P.O. BOX 4559 HONOLULU, HAWAI‘I 96812

2. NOAA - NOVEMBER 29, 2011 - PG. 2#
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As the former Governor of the State of Hawaii, I am concerned about the potential
adverse impacts this rule could have on such important activities as clean energy projects
(such as wave energy, ocean-thermal energy, and seawater air conditioning), aquaculture,
fishing, military activities, harbor improvements and near-shore construction (including
airports modernization and highway reconstruction). NOAA's economic report ac-
knowledges that insufficient information currently exists to measure the financial impacts
on these activities.
NOAA also acknowledges the monk seal population has been declining in those
areas where the critical habitat designation has been in place for over 20 years (the
Northwestern Hawaiian Islands) but the seal population has been increasing where no
designation is in place (the main Hawaiian islands).
These proposed rules are yet another example of the "one size fits all" approach
from the Federal government in Washington, D.C. I believe it is essential that we put
People First and find solutions that allow the seal population to increase without ad-
versely harming humans.
Given the large size of the proposed habitat designation, the extended length of
time it could be in place, the fact that the seals are doing better in the main islands with-
out a habitat designation and that most of the economic impacts have not been quantified,
I am calling upon NOAA and the Department of the Interior, to postpone action on their
rule-making until such time as the economic and social consequences to the people of
Hawaii are fully understood and addressed.
Sincerely,
LINDA LINGLE
!
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