[Paddlewise] Protect kayaker's constitutional rights -- respond!

From: Michael Kundu <projectseawolf_at_seanet.com>
Date: Tue, 28 Jul 1998 09:35:30 -0700
Two days ago, the US Coast Guard published a federal proposal which the
public now has 45 days to respond to before the government decides whether
to turn it into a law or not.  At this point, enough opposition will
prevent this proposal from becoming a law.

This proposed law includes sea kayakers, and is a precedent setting action
that our community should address.  The proposal will create a 1500-foot
‘exclusion zone’ around any Makah tribal whaling vessel in the act of
chasing, hunting or killing a gray whale during their first annual whale
hunt this October.  The Makah whale hunt is scheduled to happen this autumn
only 4-hours away from Seattle, WA.

What this proposal will do is to make it impossible and illegal for anyone
-- animal advocates, kayakers, media, boaters, etc. -- from seeing and
effectively opposing the Makah gray whale hunt -- a hunt that might signal
the return to coastal whaling world-wide.  The federal government notice
essentially states that the US Coast Guard and Justice Department -- at the
taxpayer expense -- will help the Makah kill whales by protecting their
whalers AND excluding anyone from protesting this hunt.

It is paramount that EVERYONE who resides in the US comment against this
proposal before September 8th, 1998.  We are attaching a draft 'talking
points' bulletin to use in the formation of your letter of opposition.

Citizens must retain their constitutional rights to witness, document or
protest such a hunt at their own risk.  Please inform your regional network
of activists, marine trade or recreational associations, commercial
boating/fishing and marine commerce businesses, whale-watching or anyone
you know that can respond to this notice.

The entire text of this Federal Register notice can be found on the Sea
Shepherd website _at_ www.seashpherd.org.  Please visit this site and add any
additional points to your letter.

If you care about preventing a new era of whaling, please act today.
Please cc. your local legislator and Project SeaWolf with your response.  

Michael Kundu, Director
Project SeaWolf
***************************************
DRAFT LETTER/TALKING POINTS

Commander(m)
Thirteenth  Coast Guard District
915 Second Avenue
Seattle, WA 98174

This letter is in response to Federal Register rulemaking notice
#CGD98-023, published on July 22, 1998.

I am opposed to the proposal to establish a Mobile Exclusion Zone around
Makah whaling vessels. My objections are based on the additional taxpayer
costs associated with the establishment, enforcement and execution of this
proposed rule, as well as the constitutional infringements that such an
exclusion zone will have on the rights of individual citizens to oppose and
protest the Makah whale hunt.

Similar exclusion zones are not in place in other areas where hunting
occurs each year, or where large caliber rifles are used in hunting
activities. Therefore I am opposed to the idea that a special law will be
implemented to facilitate a special activity conducted by a single group of
individuals involved in an exclusive hunting activity.  I believe that
regulations passed under these circumstance are unwarranted and inequitable.

My objections to the draft notice include:

Section 1: Background and Purpose
The assertion by Departments of Justice and the Interior that “physical
interference with the hunt is inconsistent with federal law,” has not been
substantiated nor documented by any evidence presented in the 1855 Treaty
text, nor in any other formal US regulation or law.  Hereby the
establishment of an exclusion zone can be construed as being an
unconstitutional restriction on citizen’s rights.  I am opposed to these
restrictions placed on my constitutional rights.

Section 2: Discussion of Proposed Rule
a) Stray rifle fire and ricochets off the water will travel much further
than 1500-feet.  All regional commercial, recreational and shore-based
travelers will be prone to danger from the use of high-caliber bullets in a
hunt.  A moving exclusionary zone will make it even more difficult and cost
intensive for federal and emergency personal to implement reasonable safety
procedures.  I am opposed to the physical dangers, travel restrictions and
additional expense that this activity will entail to myself and other US
taxpayers.

b) The broadcasting of a SECURITE announcement by Makah whaler 1-half hour
prior to a hunt is inadequate notice for commercial and recreational
travelers in the area.  Many travelers rounding Cape Flattery will not have
adequate time to change their course or route of travel.  I feel that the
federal government should not implement such an unpredictable and
unreasonable demand on recreational travelers and others using the public
Olympic Marine Sanctuary waters.

Section 3: Regulatory Evaluation
I feel that the public cost associated with the implementation and
enforcement of this proposal for an exclusion zone does indeed make it a
significant regulatory action under section 3(f) of Executive Order 12866,
and that it thereby does require an assessment of potential costs and
benefits under section 6(a)(3) of that Order.  I am opposed to this
additional added, unanticipated expense borne by taxpayers and US citizens,
and I request that a complete budget disclosure be presented tp the public
for comment prior to any additional action.

Section 4: Small Entities
The prospective cost to small entities, non-profit groups and other
eco-tourism related businesses and interests have not been quantifiably
estimated nor considered by any government agency, so there is no direct
evidence to support this section’s assertions.  I am opposed to the
potential taxpayer-borne costs that supervision and enforcement of this
exclusion zone will entail, particularly since these expenses have not been
presented to the public.

Under the circumstances of the added cost of enforcing this new proposed
rule, I request that a public hearing and budgetary forecast be prepared
prior to any final implementation.  Thank you for the opportunity to
express my comments.

Sincerely.....







Michael Kundu
Project SeaWolf/Arcturus Adventure Communications
"The Source for Extreme Adventuresports Photojournalism"
respond to ProjectSeaWolf_at_seanet.com

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Received on Tue Jul 28 1998 - 09:33:29 PDT

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