Section 10664 applies to several different marine refuges, including South Laguna and Doheny Beach. The way I read section 10664, allows the taking of specified fish, mollusks and crustaceans, and it bans the taking of "all other fish and acquatic life." The issue here is are sand crabs considered "acquatic life." Are they a crustacean (I would think so)? Section 10667 applies to the Dana Point Marine Refuge. It contains the same restrictions, although it has several subsections not in 10664, and specifically states it applies to the inter-tidal zone (although that is a difference without distinction to a surf fisherman, since all of our activity is in that zone). Interestingly, subsection (b) to 10667 specifically refers to the "gathering of fishing bait" as an example of an activity that does not qualify as an allowed minimum impact on the marine life.