Oddly, until now there had never been an overarching U.S. national seafood strategy to guide federal policies that affect our seafood industry. To NOAA’s credit, this changed in August 2023 with the publication of the first-ever NOAA Fisheries National Seafood Strategy.
This article takes a closer look at the strategy, what it means and how it might best be implemented. Goals and quotes below are from the document itself.
Goal 1: Maintain or Increase Sustainable U.S. Wild Capture Production
“Fisheries Science. Provide the natural and social science necessary for fisheries management to adapt under changing ecosystem dynamics.”
Sustainable fisheries management must always be based on the best available science. Science-based fisheries management is also required by law (Magnuson-Stevens Fishery Conservation and Management Act (16 U.S.C. Sec. 1801 et seq.)).
Yet fisheries-related research, and particularly the data collection needed to make good management decisions, is always grossly underfunded by Congress and lacks long-term continuity or stability by being forced to compete each year with hundreds of other Congressional pet projects.
And how should all this fisheries science get paid for? PCFFA has long advocated for creating a “national fisheries trust fund,” funded by a poundage fee assessed against foreign seafood imports, that would specifically fund U.S. fisheries management data collection systems that help us better manage our nation’s fisheries.
Such a trust fund would be a “lock box” separate from annual Congressional appropriations and all the messiness that being utterly dependent on Congress for annual funding of collection programs entails. (See May 2011, Fishermen’s News, “Time for a National Fishery Trust Fund,” cited below.)
“Fisheries Management. Optimize and diversify fishing opportunities … Identify and address bottlenecks in management to support the commercial fishing industry and fisheries communities in their efforts to adapt to climate change and thrive in a changing ocean economy.”
To “optimize and diversify” brings up the perpetual, but fundamental debate on how commercial fishing fleets should be organized: whether on the “industrial model” (a small number of corporate-owned, large factory boats, based in industrial ports like Seattle) versus the “community model” (a diverse array of smaller, owner-operated boats, based in and supporting jobs in local coastal fishing-dependent communities).
PCFFA represents the small-boat, locally based fleet and so has always advocated for the “community model” of a diverse fleet of smaller, independent and largely owner-operated fishing boats, which is far more sustainable and more resilient to impacts like climate change and also much more beneficial to coastal fishing-dependent communities.
A floating factory fleet organized under the “industrial model” hands over sole access to local fisheries to large (often multi-national) corporations, and so drains wealth from these coastal communities to pay outside investors.
This is also why PCFFA has historically opposed such financial mechanisms as “individual transferrable quota” (ITQ) systems, which are another hallmark of the “industrial model.” By carving up a public resource (fisheries) into privately-owned, individual quota shares, all this leads to (sooner or later) is loss of local control over local fisheries when those quota shares are transferred out of the hands of local fish harvesters and into the hands of banks and big investment speculators.
Creating a speculative market for those quota shares also jacks up the price of entering those fisheries well beyond the financial means of the younger generation, and so operates as a major financial barrier to entry-level new faces.
ITQ and similar “industrial model” fisheries privatization schemes also promote centralization and consolidation of shares in the hands of a small number of share-owner speculators (ultimately banks). This makes a small number of quota monopolists very wealthy, but runs exactly counter to the Seafood Strategy goal to diversify the fleet and “optimize” the financial benefits of local fisheries to their local communities.
“Efficient use” of fisheries should be measured not in engineering or profit-loss terms, but in how much local and widespread economic benefit those fisheries produce. In other words, not in how much profit a fishery makes for a quota owner, often an absentee corporation with no local community loyalties.
The best application of the “community model” fishing fleet is the creation of Community Fishing Associations (CFA), which is encouraged under the Magnuson Act as an ownership mechanism for holding quota shares dedicated to the use of local community members.
A CFA keeps access to local fisheries in the hands of local fish harvesters and keeps the economic benefits of those fisheries in the local economy. Unfortunately, there are only a handful of CFAs to date. Encouraging more CFAs and discouraging ITQ programs should be part of the implementation of the Seafood Strategy in order to “optimize and diversify” national fisheries.
“Habitat Conservation in Support of Fisheries. Protect and restore habitat important to our nation’s fisheries and support resilient coastal communities.”
Now we get into some fundamentals: without healthy and abundant habitat to nourish and support key fishery species there is no harvestable surplus and no fishery can long exist. This is nowhere more obvious than the sad plight of most of the West Coast’s badly damaged (and in 2023, mostly closed) salmon fisheries.
Decades of poorly regulated inland-land and water-use practices (blockage by dams, excessive water diversions leading to fatal water temperatures, logging and mining sediment, toxic water pollution, etc.) have destroyed most of the salmon productivity of once-abundant West Coast rivers.
The 2023 California and southern Oregon salmon fishery closures have been the direct result of this on-going habitat loss. Without much more aggressive fish habitat protections, both inland and in the ocean, many more fisheries may be closed.
Goal 2: Increase Sustainable U.S. Aquaculture Production
“Marine Aquaculture Management and Regulatory Efficiency. Accelerate progress on implementing an efficient, predictable, timely and science-based regulatory framework for marine aquaculture.”
“Aquaculture Science. Provide science-based advice and tools to minimize potential effects of an aquaculture operation on the environment and conduct coordinated, applied scientific research in support of sustainable industry development.”
There are two primary forms of aquaculture being proposed for open-ocean, industrial-scale operations: (a) finfish aquaculture and (b) algal (seaweed) or bivalue (shellfish) aquaculture. They are very different in scope and impacts, but no distinction between these two types of operations is made in the Seafood Strategy.
The assumption of the strategy is also apparent that industrial-scale aquaculture is, or can be made, compatible with wild fish commercial fisheries. This is a false assumption—some forms of aquaculture (particularly finfish operations) are simply not compatible with wild stock fisheries!
Currently there is little or no federal regulation for open-ocean net pen operations. And experience has shown that finfish aquaculture can be a disaster for local fisheries for many reasons, including: (a) spatial exclusion of traditional fishing operations from historic fisheries areas, leading to compaction of effort into other areas where that may not be appropriate; (b) finfish operations that generate major pollution problems with few water pollution controls that apply in the oceans; (c) farmed fish, crowded together in ocean net-pens, can easily spread diseases to migrating wild stocks (such as in British Columbia, where salmon net-pen operations spread sea-lice to wild populations); (d) escapes are inevitable, which amounts to the introduction into the wild of invasive species that compete with wild fish for limited carrying capacity, can colonize non-native areas, and there can then be interbreeding between wild fish and escaped GMO fish (particularly salmon) that can pollute entire gene pools; (e) when fish meal is used as the primary food sources, as in common, there will be “step-down” effects where it takes more fishmeal protein than can be obtained from the crop-fish, thus wasting ocean resources; (f) marine mammal entanglements and collisions are likely to occur, and (g) net-pen systems create navigation hazards, including from break-away cages during storms.
Since President Trump signed Executive Order (EO 13921) on May 7, 2020, (Executive Order on Promoting American Seafood Competitiveness and Economic Growth) creating an Aquaculture Opportunity Areas (AOAs) designation process, there has been a top-down policy mandate to build out industrial-scale aquaculture operations, regardless of and with little consideration of fisheries impacts.
There’s now an AOA designated off the Port of Santa Barbara in the Ventura Flats, a continental shelf area that has always supported abundant fisheries. Another lies offshore Humboldt County in northern California. Building out industrial aquaculture operations in these areas is a direct threat to local fisheries.
PCFFA and IFR have challenged the legality of the U.S. Army Corps of Engineers’ Nationwide Permit (NWP No. 56) that allows the building of aquaculture operations in these AOAs. (Don’t Cage Our Oceans, PCFFA, IFR, et al. vs. U.S. Army Corps of Engineers, U.S. Dist. Ct. of Washington, Western District (Seattle), Case No. 2:22-cv-01627.
A far better finfish aquaculture alternative is closed-cycle inland or lake-based aquaculture, not open-ocean net pens. It is better to avoid negative impacts on ocean wild stock fisheries entirely, rather than to have to clean up problems than never had to exist.
Algal and bivalve aquaculture operations are typically less of an impact, but still produce some of these problems.
Goal 3: Access to Domestic and Global Markets
“Communication and Promotion, and U.S. Market Development. Increase public awareness of the availability, sustainability, and nutritional value of all U.S. seafood.”
“U.S. Market Development. Work with federal partners and others to identify and develop U.S. seafood markets and put more U.S. seafood on U.S. plates, particularly for the underserved.”
“Fair Trade. Promote fair seafood trade by combatting IUU fishing and related harmful fishing practices around the world and by expanding access to foreign markets for U.S. seafood.”
The first two goals are laudable, but also require protection for habitat so we actually have U.S. product to deliver! Good marketing alone does no good without fish.
But on “fair trade” issues, the U.S. seafood industry is embedded in an international trade system mostly supplied by countries with far less regulation of their fisheries, which make far less of an effort to keep their own fisheries sustainable as compared to the U.S.
Countries that poorly regulate their own fisheries thus often compete in U.S. seafood markets at a distinct cost advantage, sometimes deliberately flooding U.S. markets in an effort to capture our markets by driving U.S. producers out of business.
We saw this happen in our U.S. salmon markets with years of a massive influx of (heavily dyed) farmed salmon from Chile, Norway and other countries—until the U.S. finally passed a law requiring the labeling of farmed fish, so consumers could distinguish vat-raised products from natural wild fisheries.
Also, there are constant attacks by other countries on the higher standards of U.S. fisheries laws before the World Trade Association (WTO) and under the General Agreement on Tariffs and Trade (GATT), all claiming that these laws create “unfair trade barriers” to (in essence) prevent other countries from flooding our markets with inferior products raised unsustainably! The years of debate over U.S. “dolphin-friendly tuna” import rules is a good example.
There are also unfair trade subsidies provided by other countries in efforts to prop up their own unsustainable fisheries practices or to allow foreign companies to outcompete the U.S. fishing fleet in international markets.
One clear need for any U.S. seafood marketing strategy to succeed is for our federal government to stick to its high seafood quality and health standards under the Magnuson-Stevens Act and other U.S. environmental and public health laws that protect our fisheries.
“Dumbing down” our own high seafood health and safety standards is never an answer, and risks losing the hard-earned trust of seafood consumers.
Goal 4: Strengthening the U.S. Seafood Sector
“Seafood as a Vital Part of the Blue Economy. Support the U.S. commercial fishing, marine aquaculture and other seafood communities to adapt and thrive in a changing ocean economy.
“Seafood Infrastructure. Work across federal agencies to modernize and maintain U.S. seafood infrastructure (e.g., vessels, hatcheries, port and dock facilities, processing, storage and working waterfronts) in order to strengthen and enhance opportunities for coastal seafood commodities and regional food networks.
“Workforce Development. Foster a growing and diverse seafood workforce and attract young harvesters and seafood farmers to the sector.
“Equity and Environmental Justice. Improve understanding of barriers to access to seafood, challenges to diversity of opportunity and scale in the seafood industry and workforce demographics.”
These are all high-minded goals, but the most important is to invest more federal and state resources in upgrading the crumbling infrastructures of the nation’s seafood-producing ports.
As climate change and degradation of habitat (particularly inland salmon habitat) have triggered more and more commercial fisheries closures, the financial drain on working seaports has been devastating.
And without more resources coming to these ports, their landing and fueling docks, ice plants and processing facilities will continue crumbling away.
The U. S. government has also eliminated a lot of the money for dredging smaller ports, prioritizing funds instead for dredging only larger industrial ports. Assuring fishing boats have basic port access is also an important part of port infrastructure.
The creeping threat of “gentrification” facing these ports is also shoving working port facilities aside. On the West Coast, California has strong zoning and planning laws that protect “working fishing ports” from rampant real estate speculation leading to gentrification (CA Public Resources Code Secs. 30234 and 30703), but few other states do.
And finally, much of our industry already has been pushed out of its historic fishing grounds by poorly thought-out ocean industrial development designed for offshore oil and gas and is facing immanent exclusions from planned offshore wind energy development. Industrial scale aquaculture and subsea mining threatens to do the same.
If we must engage in “ocean zoning,” then it should be done on an equitable basis. There must also be areas deliberately set aside that are specifically devoted to commercial fisheries and for no other competing purposes.
If we continue as a country to consider fisheries only as an afterthought, providing them only whatever space is left over, and continue to prioritize industrial developments that gradually push productive and sustainable fisheries aside, it will not take long before we have no domestic fisheries left, and we become entirely dependent on other countries for our seafood.
NOAA fisheries is working now to develop an Implementation Plan for this new National Seafood Strategy, with specific actions, timelines, partnerships and milestones. It will be important for our industry to watch this process closely and participate fully to see that the actions taken under this Seafood Strategy match its rhetoric.
Links
August 2023, NOAA Fisheries (NMFS) National Seafood Strategy: https://www.fisheries.noaa.gov/s3/2023-08/2023-07-NOAAFisheries-Natl-Seafood-Strategy-final.pdf.
NOAA Fisheries Strategic Plan 2022-2025: https://www.fisheries.noaa.gov/feature-story/noaa-fisheries-strategic-plan-2022-2025.
May, 2011, Fishermen’s News article, “Time for a National Fishery Trust Fund,” https://pcffa.org/wp-content/uploads/2016/05/FN0511_PCFFA.pdf.
Glen Spain, J.D., is the Acting Executive Director of the Pacific Coast Federation of Fishermen’s Associations (PCFFA) and its sister organization, the Institute for Fisheries Resources (IFR). He is also the PFMC-appointed Commercial Fisheries Representative to the PFMC’s Habitat Committee. He can be reached by email at: fish1ifr@aol.com and by phone at the PCFFA/IFR office: (541) 689-2000. PCFFA’s website is www.pcffa.org. IFR’s website is www.ifrfish.org.