June 20, 2024
The Honorable Mary Sattler Peltola
153 Cannon Home Workplace Constructing
Washington, DC 20515
Expensive Congresswoman Peltola:
We write to specific our deep concern relating to H.R. 8507[1]—laws you will have launched that will create sweeping new federal mandates constraining the efficient administration of our nation’s fisheries. If enacted, H.R. 8507 would straight hurt fishermen and coastal communities in Alaska and all through our nation, together with numerous different individuals who depend on a wholesome home seafood sector for meals, jobs, and their lifestyle. We ask you to withdraw this laws.
Federal fisheries administration in america beneath the Magnuson-Stevens Fishery Conservation and Administration Act (“MSA”) is well known as setting a world gold commonplace. Eight Regional Fishery Administration Councils (“Councils” or “FMCs”) meet strict conservation necessities whereas balancing advanced administration tradeoffs via a rigorous, clear, and stakeholder-informed decision-making course of. Over time, this administration system has turn into stronger. NOAA’s newest Standing of Shares report reveals that the variety of federal fish shares topic to overfishing reached an all-time low in 2022, whereas efficient administration approaches have restored a complete of fifty fisheries that had been beforehand depleted to wholesome ranges since 2000.[2]
H.R. 8507 disregards the teachings of the MSA’s success. Its top-down mandates would completely wall off huge sections of ocean territory from essential sustainable fisheries, boxing in not solely fishermen but in addition scientists and managers who could be prevented from adapting their administration approaches to altering ocean circumstances over time. Our considerations are described intimately beneath.
- Science and Local weather Change
On the coronary heart of our federal fishery administration system is science. The Councils always draw upon the perfect accessible science—together with detailed scientific assessments from six regional NOAA Fisheries Science Facilities—to tell their decision-making processes. More and more, this science exhibits climate-related shifts in our nation’s marine ecosystems, together with important adjustments within the distribution of fish populations and different marine life. With a view to reply successfully, consultants agree that administration should be each dynamic and adaptive. Local weather-resilient fisheries administration should always anticipate, consider, and reply to adjustments within the ocean surroundings, and make sure that administration actions stay calibrated to realize outlined goals in gentle of these adjustments.
H.R. 8507 does the other. It compels Councils to undertake the archaic and counterproductive strategy of making everlasting area-based closures that can’t be evaluated and modified as crucial over time. As fish shares and different marine biota shift, the static space closures mandated by this laws would depart managers hamstrung of their response. It’s the improper technique to strategy fisheries administration in an period of fixing ocean circumstances.
- Habitat Conservation Beneath the Magnuson-Stevens Act
All fishery contributors have a robust vested curiosity in conserving the marine habitat that drives fisheries manufacturing and ensures the well being of the broader ocean surroundings. In consequence, there’s broad assist throughout our business for science-based habitat conservation measures. Robust habitat conservation necessities are presently enshrined in U.S. legislation and rules and carried out by the eight Regional Councils. These necessities are much more thoughtfully designed than the inflexible and finally unscientific strategy your laws would require.
The Council Coordination Committee[3] lately examined all the area-based conservation measures carried out in america Unique Financial Zone (“EEZ”) by the FMCs and different federal actions.[4] They calculated that 648 conservation areas protecting greater than 72 p.c of the EEZ have been established.[5] They additional calculated that area-based conservation measures particularly designed to advance conservation of the broader marine ecosystem span greater than 56 p.c of the EEZ, whereas administration measures establishing prohibitions on all cell backside tending gear now covers greater than 34 p.c of the EEZ.[6]
Dozens of Council actions in recent times illustrate the persevering with scale of habitat conservation efforts on the regional degree. In 2017, for instance, a brand new Deep Sea Coral Safety Space[7] spanning greater than 38,000 sq. miles was established off the Mid-Atlantic Coast with assist from each business fishermen and environmentalists. The next yr, the Pacific FMC voted to guard greater than 145,000 sq. miles of delicate habitats alongside the West Coast, after a years-long cooperative course of initiated by the fishing business and environmental organizations.[8] In 2020, the New England FMC adopted sweeping new measures for the conservation of deep-sea corals within the area, spanning greater than 25,000 sq. miles south of Georges Financial institution.[9] Later that very same yr, a Gulf of Mexico FMC Modification utilizing the Important Fish Habitat (“EFH”) provisions of the MSA turned remaining, extending new protections to 500 sq. miles of deep-sea coral habitat spanning 13 reefs and canyons stretching from Texas to the Florida Keys.[10] In the meantime, the North Pacific FMC has established area-based conservation measures throughout greater than 65 p.c of the a million sq. nautical miles of ocean territory beneath its jurisdiction.[11]
These and tons of of different present area-based measures are designed by the Councils to realize acknowledged conservation goals regarding fisheries and marine ecosystems. The exact nature of those measures varies enormously, reflecting the distinctive regional complexities of the goals and administration tradeoffs which are related in every case. Critically, beneath the MSA’s habitat conservation necessities, the Councils periodically re-examine earlier designations based mostly on up to date assessments of environmental circumstances.
Even now, the method for reexamining space closures as new info turns into accessible or circumstances change is usually too restrictive. Current Marine Monument designations protecting important parts of the EEZ restrict the flexibility of some Councils, most particularly the Western Pacific FMC, to optimally handle fisheries beneath their jurisdiction. Equally, any designation of a Habitat Space of Explicit Concern (HAPC) might be tough to revisit whilst new proof involves gentle. In 1984, the South Atlantic FMC designated a 92 sq. nautical mile space off the East Coast of Florida, the Oculina HAPC, to guard corals. The world was subsequently expanded twice, including a further 353 sq. nautical miles of historic fishing space to its territory. But a latest vote by the South Atlantic FMC to reopen parts of the Oculina HAPC to shrimp fishing the place corals had been discovered to not be current was rejected by the Secretary of Commerce. H.R. 8507 will completely legislate inflexibility in advanced conditions similar to these.
We should proceed to strengthen the flexibility of fisheries managers and scientists to make habitat conservation determinations based mostly on the perfect present info fairly than outdated determinations. As an alternative of shifting us additional in that route, H.R. 8507 takes us backwards.
- Unworkable Federal Mandates and Timelines
The Regional Fishery Administration Councils are presently enterprise myriad essential analyses and actions to realize essential conservation and administration targets for the good thing about the marine surroundings and the individuals who depend on it. Your laws would require them to deprioritize that very important work to fulfill new and poorly designed federal mandates.
Particularly, Part 2 of H.R. 8507 would require institution of recent gear definitions and categorizations, in addition to the event of recent “monitoring and enforcement” plans based mostly on these definitions. This is able to have to be accomplished inside 18 months. Part 3 of H.R. 8507 particulars further new mandates. Inside 12 months, Councils are required to ascertain new areas inside their jurisdictional waters that shall be completely closed to sustainable American fisheries—closures that beneath this laws the Councils might by no means revisit.
These new federal mandates and timelines are totally unworkable. They might impose an infinite new subject of labor upon the Councils with none new sources or any reallocation of present workloads. In our view this constitutes large and deeply misguided political overreach, which might hurt the essential work of federal fisheries administration that goes on day by day via the Councils.
- Conclusion
We must always all take nice delight in America’s seafood harvesters and the broader U.S. seafood business they assist. Our fisheries produce distinctive environmental outcomes; and so they present an reasonably priced, low-carbon, and extremely nutritious protein to tens of hundreds of thousands of American customers. Business fisheries additionally make a significant contribution to the nationwide financial system, supporting $183 billion in gross sales.[12]
Maybe most significantly, nevertheless, these fisheries assist working households and coastal communities all through our nation. They create 1.6 million jobs,[13] usually offering an financial lifeline to rural and socio-economically deprived areas the place few various financial drivers exist. Many of those fishery-dependent employees and communities are presently going through acute challenges resulting from unprecedented market circumstances, strict rules, climate-related adjustments in fisheries abundance or distribution, and elevated prices of manufacturing. The introduction of H.R. 8507 shakes the boldness of seafood consumers and customers in U.S. seafood, thereby casting an extended shadow of uncertainty over the long run alternatives of fishery-dependent communities and companies on the worst attainable time. With that essential context in thoughts, we as soon as once more urge you to withdraw your invoice, and to redirect your policymaking to initiatives that may help fairly than hurt this proud American business.
Sincerely,
Julie Bonney
Govt Director
Alaska Groundfish Information Financial institution
Rebecca Skinner
Govt Director
Alaska Whitefish Trawlers Affiliation
Alvin D. Ostberback
Mayor
Aleutians East Borough
John Whiteside, Jr.
Basic Counsel
American Scallop Affiliation
Trey Pearson
President
American Shrimp Processors Affiliation
Stephanie Madsen
Govt Director
At-sea Processors Affiliation
Vincent Tutiakoff, Sr., Mayor
William Homka, Metropolis Supervisor
Metropolis of Unalaska
Eric Hansen
Chairman
Fisheries Survival Fund
Jerome Younger
Govt Director
Florida Keys Business Fishermen’s Affiliation
Scot Mackey
Govt Director
Backyard State Seafood Affiliation
Paige Morrison
President
Georgia Business Fishermans Affiliation
Chris Woodley
Govt Director
Groundfish Discussion board
Acy Cooper
President
Louisiana Shrimp Affiliation
Heather Mann
Govt Director
Midwater Trawlers Cooperative
Lisa Wallenda Picard
President & CEO
Nationwide Fisheries Institute
Jerry Leeman
Chief Govt Officer
New England Fishermen’s Stewardship Affiliation
Jackie Odell
Govt Director
Northeast Seafood Coalition
Glenn Skinner
Govt Director
North Carolina Fisheries Affiliation
Yelana Nowak
Director
Oregon Trawl Fee
Alexis Meschelle
Govt Director
Organized Fishermen of Florida
Julie Decker
President
Pacific Seafood Processors Affiliation
Aja Szumylo
Govt Director
Pacific Whiting Conservation Cooperative
Kiley Thompson
President
Peninsula Fishermen’s Coalition
Christopher Brown
President
Rhode Island Business Fishermen’s Affiliation
Nick Edwards
Secretary
Shrimp Producers Advertising and marketing Cooperative
Rocky Magwood
President
South Carolina Shrimpers Affiliation
John Williams
Govt Director
Southern Shrimp Alliance
Captain Bob Zales
Govt Director
Southeastern Fisheries Affiliation
Captain Bob Zales
Fisheries Administration Advisor
Southern Offshore Fishing Affiliation
Hank Soule
Supervisor
Sustainable Harvest Sector
Maria Barrera-Jaross
Govt Director
Texas Shrimp Affiliation
Brent Paine
Govt Director
United Catcher Boats
Bryan Jones
Director
United States Shrimpers Coalition
Lori Steele
Govt Director
West Coast Seafood Processors Affiliation
Corporations:
Sam Martin
Chief Working Officer
Atlantic Capes Fisheries, Inc.
Michael Scola
President
Boston Sword & Tuna, Inc.
Colin Bornstein
President
Bornstein Seafoods, Inc.
Terry Molloy
Basic Supervisor
Chesapeake Bay Packing, LLC
John Norton
President
Cozy Harbor Seafood, Inc.
Deb Sanderson
Chief Govt Officer
Japanese Merchants Ltd.
Craig Weatherley
President
The Florence Group, Inc.
Wayne Reichle
Proprietor & President
Lund’s Fisheries, Inc.
Todd Michalik
President
Marder Trawling, Inc.
Ronald Enoksen
President
Nordic Fisheries, Inc.
Ruth Christiansen
Director, Authorities & Business Affairs
Ocean Peace, Inc.
Lindsey Wells
Managing Director
Omega Sea, Inc.
Scott Hutchens
Govt Vice President
Uncooked Seafoods, Inc.
Meghan Lapp
Fisheries Liaison
Seafreeze Ltd / Seafreeze Shoreside
Man B. Simmons
Chief Working Officer
Sea Watch Worldwide
Ray Drouin
President
Skip’s Marine Provide, Inc.
Tom Dameron
Authorities Relations & Fisheries Science Liaison
Surfside Meals LLC
Ryan Clark
President & CEO
The City Dock
Kirk Larsen
President
Viking Village, Inc.
cc: The Honorable Bruce Westerman
The Honorable Raul Grijalva
The Honorable Cliff Bentz
The Honorable Jared Huffman
The Honorable Lisa Murkowski
The Honorable Dan Sullivan
[1] https://www.congress.gov/invoice/118th-congress/house-bill/8507
[2] https://www.fisheries.noaa.gov/nationwide/sustainable-fisheries/status-stocks-2022
[3] https://www.fisheries.noaa.gov/nationwide/companions/council-coordination-committee
[4]https://static1.squarespace.com/static/56c65ea3f2b77e3a78d3441e/t/6489c43523c0b1595a5b8d54/1686750280097/Analysis-of-Conservation-Areas-Report-2023.pdf
[5] Id., Tables 5 and 6.
[6] Id., Tables 6 and seven.
[7] https://www.fisheries.noaa.gov/useful resource/map/frank-r-lautenberg-deep-sea-coral-protection-areas-map-gis
[8] https://www.fisheries.noaa.gov/story-map/story-map-west-coast-groundfish-amendment-28
[9] https://www.fisheries.noaa.gov/bulletin/final-rule-designate-deep-sea-coral-protection-areas
[10] https://public-inspection.federalregister.gov/2020-21298.pdf
[11]https://static1.squarespace.com/static/56c65ea3f2b77e3a78d3441e/t/6489c43523c0b1595a5b8d54/1686750280097/Analysis-of-Conservation-Areas-Report-2023.pdf, Desk 6.
[12] https://www.fisheries.noaa.gov/useful resource/doc/fisheries-economics-united-states-report
[13] https://www.fisheries.noaa.gov/useful resource/doc/fisheries-economics-united-states-report
