NOAA Fisheries Draft National Seafood Strategy_Public Comments

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Bob Gill

Floridano responseSD

no response

South Dakota

no responseSD

no response

South Dakota

no response

South Dakota

no response

South Dakota

no response

SD

General comments/feedback
Although the implementation plan will be more specific, I suggest that your goals be standalone SMART (Specific, Measurable, Achievable, Relevant, and Time-Bound). That way
the strategy plan is upfront definitive about WHAT the goal is. The implementation plan will
provide the HOW with the steps to achieve the goals. In the current form, the goals areamorphous, feel good objectives with no boundaries. They do not inspire one to achieve.
Definitive goals that are SMART can inspire the team and stakeholders.
I think the plans you have will help and i believe we will start to see change when we starttaking action
I think it’s really important to look at the money involved with this sort of thing. It won’t becheap. It’s possible to start fundraisers and other small campaigns to help. A part of me
feels it will continue to get better but not to the end goal we all want it to. In the end, to mostpeople it is all about the money.
Hello my name is ___ and I'm stevens high school and my environmental science teacher
was asking us to write feedback to you guys I'm wondering what steps is president Biden
taking to address this issue of over fishing and what is congress doing to address the threatof over fishing.
I think that the government should focus less on the economic benefits of the seafoodindustry and focus more on the environmental take away. There is clearly no way to satisfy
both sectors of the issue entirely, but I think the U.S. should give the environment a little bit
more thought seeing as how we've only focused on the economy in the past. When we talkabout the vitality of the seafood industry it is only fair to also express the negative impacts
that commercial fishing has on the oceans. The biodiversity crisis is a rising issue inenvironmental news. Although the population tends to take note of the lack of biodiversity
on land I believe that it is also fair to recognize the biodiversity crisis taking place in thewater. Although this issue may feel "out of sight, out of mind," because it takes placebeyond the surface, I think it is just as concerning as above ground biodiversity.
You may be wondering, "what does the lack of biodiversity really harm?" Taking away
species of fish from the life cycle of oceans, can be speculated to cause the entire aquatic
ecosystem to collapse. Taking out one piece of a puzzle causes the puzzle to beinconmplete, or taking out a brick from a building, can cause the building to collapse. It is
important to restore the balance in ecosystems as we take away from them.
Obviously, just complaining about the issue and noting that it is; in fact, an issue, is only the
first step. What can we do to solve this? There are already some regulations in place
limiting how people are allowed to fish, but do we have regulations in place affecting
commercial fishing? No, we do not. I also believe that it would be beneficial to have fishing"seasons." Just like other forms of hunting. I believe the aquatic ecosystem would benefit
heavily if people were restricted by how much and of what they were allowed to take fromthe ocean at any given time.
I believe that the actions being taken in this article to help the fisheries is good and will help
fish habitats and fish live longer and have a longer species life.
I think the ideas are really good and that this is a huge problem that I think this plan is goingto help fix.
I think what you guys are doing is great for the environment. But what does it mean interms of cost? Also, how many sustainable hatcheries will there be across the U.S.? Other
than that, I think you guys are making a good decision.

no response

no response

no response

South Dakota

I think the NOAA's mission has potential. It's nice to finally see companies taking action to
the serious and very relevant problems our oceans face. One of the huge problems that
affect our oceans, is overfishing. I hope this new technique focuses on restoring the ocean
ecosystems, and depleting species, as well as being able to meet consumer needs, andeconomic growth. And since the economy comes first to many businesses, I feel there isnothing people can do except to wait and see what will happen. Putting our oceans first iswhat matters most, and I hope this helps boost the lively spirt the ocean once had.
From what I read it looks like you guys are implimenting some very good strategies after
the pandemic to get the fish industry back and more sustainable. This is very importantbecause of the amount of fish that are available for spawning and that allow the industry tocontinue. There was one thing I thought would be effective that either wasn't included or I
missed it. I think that no fishing zones would be effective to put in place because studies
have shown that they increase the population so much they begin to overflow into thefishing zones.

South Dakota
Pennsylvania

If fish are the holy grail of proteins and essential vitamins why haven't we switched over tothem yet? would the cost of fish runs, filtration, monitoring and harvesting outweigh things
like chickens, quail or even insects that require a fraction of the space and cost? instead of
focusing on producing fish on the main lands, we should focus on producing food items thatwill give the natural ways the ocean produces fish to produce what we need
You make a positive difference!

no response
Carolyn Raasch

NOAA Fisheries Draft National Seafood Strategy_Public Comments

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Mary E Riley

Ohio

General comments/feedback
I love to eat fish. Especially tilapia. I think we should increase aquaculture and I haveheard that tilapia is fairly easy to raise. I would prefer not to eat fish from China as I don’t
have faith in their quality and sanitation practices. Thanks for asking.
While of course I support sustainable seafood and a diverse, fairly treated andcompensated workforce to support it, I don’t support increasing seafood production,aqucaculture, workforce etc. In my opinion, despite US fisheries being the most well andsustainably managed fisheries generally, we take entirely too much and waste more. The
collapse of the Alaskan crab fishery is a good example. When will the trawling of thosewaters be stopped? If NA right whales go extinct because of pigheaded lobster fishermen,
what a goddamn stain that will be on us. And aquaculture, to me, is a gross alternative.
The pressure on fish including sharks, especially sharks, continues to devastating effect.
Overfishing and bycatch continues to be a problem. Recreational fishing of sharks iscontroversial and proven to negatively impact their populations but NOAA looks away under
the guise of science. What a farce.
Climate change is here and affecting us big time. The only thing everyone worries about isthe economy and capitalism while the environment burns and resources are squandered.
We should be transitioning fishermen to other jobs, not increasing the workforce. Fishshould be left for indigenous people and communities who rely on it as their only source ofcheap protein. It should not be for anyone else, especially the rich who exploit everything
possible.

LaurieAmandaChuck Erickson
Larry Buchananno response

So no, I don’t support your National Seafood Strategy, sorry to say.
This is so important and a long time coming. The promotion of local fish in theregions/states where they are caught and building domestic markets for those fish should
be your first priority in strengthening US wild-capture fisheries. There are too many local
fish here in the Northeast that go severely under-utilized as foreign seafood, Alaskan
pollock, tilapia (not seafood!) and farmed salmon dominate the markets. Many of our mostplentiful species - spiny dogfish, monkfish, butterfish - rely too heavily on foreign markets,
which has been the near-demise of the monkfish fishery in recent years. Why are New
Englanders so unaware of all the great fish right off the beach? Between weakening
markets, consumer unawareness, and regulations based on incomplete science, Northeast
fisheries are in dire need of assistance. Especially here in New York, where major saltwater
ports lack any infrastructure at all for value-added, processing, etc., competing is difficult. I
implore NOAA invest in promotion and infrastructure here in the Northeast to rebuild thecountry's first major ports.
New York
Combine Pacific Fisheries Manage Council & North Pacific Management Council into
United States Pacific Fisheries Management Council. Stake holders want a voice so we canrestore the body size of the salmon. Alaska dumping 1.4 billion smolts for cat foodWestern United Staes products. Stop the monopoly games being done by the hack fish managers.
Nothing the Biden Administration implements for this country is any good for it , so why do
Oregonyou think there policy is going to be any different for you ?
Under goal 1, NOAA should also aim to support innovation of new seafood technology that
reduces bycatch and other negative ecosystem impacts (such as entanglement).

Nicole Adamson

California

Nathan Everett (Still Kickin'Seafood)

VA

Martin Gary

MarylandUnder goal 2, NOAA should specify that "aquaculture" relates to seaweed, shellfish, andfinfish. This provides more clarity, as many members of the public typically only think offinfish when imagining aquaculture. Seaweed and shellfish aquaculture have fewer
environmental concerns than finfish aquaculture.
Please incorporate entry level Processing facilities as well as entry level Fishers into thisdecision making process.
Blue Catfish, Spanish Mackerel, Blue Fish, Spiny Dog Sharks, Black Drum, Red Drum,
Speckled Trout, Spot are all plentiful in VA area. We are building a seafood processing
facility from the ground up that is located in White Stone VA. Please contact us(252)945-2757(804)436-6650
stillkickinseafood42@gmail.com
Please provide a system which allows consumers to trace the origin of the seafood as
specifically as possible so we can support domestic fisheries and know where our seafood
is coming from.

NOAA Fisheries Draft National Seafood Strategy_Public Comments

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TAKING THE OCEAN INTO ACCOUNT IS CRITICAL FOR SUCCESSFULLYADDRESSING CLIMATE CHANGE, AND ADDRESSING CLIMATE CHANGE IS CRITICALFOR THE FUTURE OF ALL OF US. Fishing is a major source of ocean pollution and plastic
contamination due to discarded and lost fishing material. Overfishing is a major problem.
Fish populations are dwindling and the lack of biodiversity caused by overfishing, along withthe contamination caused by aquafarms, could have disastrous results to human life. It’seasier than ever to leave fish and other animals off our plate with all of the plant-based
foods available. If we truly cared about a livable planet we'd encourage people to STOP
eating sea life and we would leave the oceans alone. With bottom trawling, everything that
happens to be in the way gets swept up in the net, leading to huge amounts of bycatch andalso the damaging of the seafloor, which creates harmful algae blooms and oxygendeficient dead zones. Long lines are indiscriminate and by-catch is a huge problem. Every
year around 650,000 whales, dolphins, seals, sea lions and turtles are killed each year
because of the fishing industry - which equals more than one every minute.
It is estimated that 50 million sharks are unintentionally caught as bycatch each year, which
is about half as many as are killed intentionally for their meat and fins.The number ofoverfished species has increased three-fold in the past 40 years alone, with the United
Nations FAO stating that 87% of the world’s fisheries are either overexploited or fully
exploited, with nearly one third of edible fish and seafood species having declined by 90%,
and a study from an international team of researchers published in the Journal Science,even predicted that we could actually have fishless oceans by the year 2048.
It is reported that as much as 70% of macroplastics found floating on the surface of theocean are fishing related. A recent study of the “great Pacific garbage patch”, an area ofplastic accumulation in the north Pacific, showed that 86% of the macroplastics in this area
were fishing nets.

no response

no response

Robert A. Sparks

AlaskaMeryl Williams

no response

Famed fish, which now provide around half of all the fish that are consumed globally,
actually leads to even more fishing, because many of the fish raised on these farms arecarnivores, meaning they need to eat smaller fish to live. Billions of wild fish are therefore
caught in order to feed these farmed species. For example, it can take up to five pounds ofocean fish to produce just one pound of farmed salmon.
You need to end trawling in the Bering Sea because its screwing up the marine
environment and the bycatch waste is immoral and unsustainable.
The statement on Workforce Development - "Foster a growing and diverse seafood
workforce and attract young fishermen and seafood farmers to the sector." - was a shock
because it suggests that the seafood industry is for men.
Women play an incredibly important role in US fisheries and aquaculture but statements
such as these seem to not consider encouraging them. In this case, what is meant by"diversity"? At the least, this Seafood Strategy should be harmonising with the draft NOAA
strategy for Equity and Environmental Justice in US fisheries.

NOAA Fisheries Draft National Seafood Strategy_Public Comments

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The absence of any mention of the recreational fisheries in the National Seafood Strategy
is a significant shortcoming of the policy. In no definition that I have seen is seafood
assigned exclusively to the commercial fishing sector. Seafood is defined as any produced
harvested from the ocean for use or consumption, meaning, fish harvested by recreational
anglers is seafood. Recreational fishing is perhaps one of the most sustainable ways toharvest fish. All fish harvested by recreational anglers are consumed within our country,
they are not exported as seen with commercially harvested fish. It should be further notedthat by not included recreational fishing, the strategy dismissing a significant portion of the
public who go recreational fishing as an affordable way of accessing our nation's marine
resources. Many cannot afford to pay the market rate for many commercially landed
products. Even in the fish market, many of these products are too expensive. However,for the price of a single seafood dinner in a restaurant, a family can purchase rod/reel,tackle and bait and have the opportunity land double or triple the amount of seafood fortheir own consumption. If you were to go to many urban, coastal areas, you would bepleasantly surprised to find a significant number of anglers and families taking advance for
their access to the water. Many could not afford the seafood being sold in restaurants andstores in that city, but they have the means to catch their own. This aspect must berecognized in the national seafood strategy. Benefits provided to commercial fishermen
should also be provided to the recreational angler for they too are providing seafood forthemselves and their families. Furthermore, the economic output of recreational fishingmust not be ignored. To provide a simple example, the largest single marine industry
employer in the state of New Jersey is not a commercial fishing operation or processing
plant, it's a boat manufacture that builds boats specifically for offshore recreational fishing.
The recreational sector provides similar economic output and jobs in providing seafood tothe nation as commercial fishing operations.
It is imperative that NOAA acknowledges the definition of seafood and stops excluding
recreational fishing from the discussions or the resources being put forward by NOAA to
help the seafood industry. Recreational fishing produces seafood, it is part of the seafoodindustry. Please revise the seafood strategy so that it is fair, equitable and includes thosemembers of the public who can't afford high priced seafood provided by commercial fishing
operations and catch their own seafood. This is all about equity and the strategy, in its
current form, excludes a significant portion of the American public.
I don't see mariculture mentioned at all in the draft national seafood strategy... There is a
growing interest in the US seaweed and shellfish industry and we farmers are alreadyworking towards the objectives outlined in Goals 3 and 4 of the draft national seafood
strategy. As part of the Blue Economy and Seafood Industry I feel it is appropriate to see
mariculture goals included in the next version of this draft. Thank you ~ Sean
I am 100% for seaweed aquaculture, but farmed fish have too many problems-too crowded,
dirty water, disease, and pollution and taking up space needed by wild fish species. Unless
those issues can be fixed, we need to support wild caught fish and adjust the amount we
eat vs overfishing. Have you had a farmed fish recently? Ugh
Please look at slowing down the by-catch especially by- catch And killing of salmon, halibut,
crabs, dolphins, killer whales, sharks by trawlers in Alaskan waters. Pollock caught this way
isn’t worth the by-catch. Thank you
I feel an element missing from this strategy is the consumer. I would love to see part of thestrategy address the value of consumer education and engagement. Creating increased
demand for the seafood sector’s products will be a critical factor for long-term successful
outcomes. Also, making sure the retail settings where consumers buy seafood do a goodjob of sharing information about the seafood and ensuring its quality will go far to building
consumer demand and repeat purchase. I’ve been writing about seafood for the home cookfor many years, and am conducting a survey about seafood shopping to learn more about
improving consumer experiences with seafood. Working toward greater supply of domestic,
sustainable seafood is great. But I believe that to ensure the biggest impact for theindustry, consumer engagement should be part of the plan. I could see it as an added bullet
point with Goal 4 of the draft strategy.

John DePersenaire

New Jersey

Sean Den Adel

AK

Valerie

OregonHans Brons

AlaskaCynthia

Washington

Cynthia Nims, cnims@comcast.net

Francisco Ramos Torres

Puerto Rico

Lex Ludtke

Washington Stateno response

AZ

in a need of funds to repaired all costal zones for fisherman's in the island
Vision for Resilience your showing # 2Increase sustainable U.S. aquaculture productionThe question or guidance why is Washington states governor closing the aquaculture
salmon nets on Washington coast line... can someone reach out to Inslee and share thiswith him so we can get on the same page.
I hope that part of your sustainable strategy is to do some serious, ongoing, mass
marketing/advertising for the least-threatened types of fish, to encourage people to eat
more of those (sardine, herring?) as opposed to more popular and over-fished types of
seafood. Thanks.

NOAA Fisheries Draft National Seafood Strategy_Public Comments

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Larry Franks

Washington

no response

Maine

General comments/feedback
Two critical issues: first REDUCE US wild capture production. Data indicates we are overharvesting in a wide range of fisheries. Second, limit 'aquaculture' to Recirculating
Aquaculture Systems (RAS) with concomitant non-forage fish based feed development.
Windmills are NOT the answer! Not on land and Especially not in our ocean! Not only are
they not "green" but they're an navigational hazard!
Also like to add...Look at how many whales that are washing up on the beaches and/or
floating dead in the ocean do to "exploratory sites" for these windmills.
Thank you for the opportunity to comment. First, I applaud NOAA in developing such a
concise draft strategy. I work in fisheries policy and community engagement, and a lot of
my time in the last 10-years has been providing technical assistance to the wild-harvest
shellfish industry in Maine, which is co-managed between the municipalities and the state.
I'd like to speak primarily to Goal 4, and the strategy around seafood infrastructure,
although this also applies broadly to Goals 1 and 2.
One of the big issues facing the shellfish harvesters is a loss of access to the fishery as
informal agreements they had to access the mudflats through coastal landowners private
properties is being lost due to gentrification and other changes along the coast of Maine. If
access is lost through private property, the harvesters have to go elsewhere (public accesspoints, town docks, and boat ramps), and this shift can result in user conflicts with othercommercial fisheries or recreational users. Access to the coast, and working waterfront
infrastructure is the gateway for America's seafood to get to domestic and international
markets.
My business, Tidal Bay Consulting, has recently started working with Maine Coast
Fishermen's Association on working waterfront preservation and how towns can inventory
and monitor their infrastructure. Since starting this work, I've noticed that there is very
limited funding at the state level for municipal working waterfront planning andimplementation grants, and I am not aware of any direct federal funding programs aside
from grants through FWS (I believe) for marinas that cater to larger recreational vessels.
(Of course, NOAA CZM funding provided to the Maine Coastal Program is one source.)

Jessica Joyce

Maine

Jocelyn Juliano

South Carolina

If Goals 1, 2 are about supporting and/or growing wild harvest and aquaculture production(and balancing these with other ocean uses), it is important to understand that if theworking waterfront infrastructure and/or coastal access is a limiting factor, that theseindustries will not be able to grow using the approaches currently in use from moorings andmarinas and offloading to wharfs, etc. Having a federal funding program to support the Goal
4 strategy of seafood infrastructure will enable Goals 1 and 2 to be realized throughproviding much-needed resources to the towns and states planning for the future andinvesting in the infrastructure to support their local marine economy. Looking acrossexisting NOAA funding programs and new funding programs and considering the 'right size'
I want to emphasize the following needs: infrastructure improvement and assistanceparticularly through public avenues since privately owned docks and shoreside
infrastructure are not secure long-term; workforce assistance and professionalizing theindustry; fuel subsidies; increase domestic processing capacity to reduce export processing;no response

I support the focus of the seafood strategy on sustaining wild harvests, allowing
aquaculture to grow more efficiently, fostering market access, and strengthening thesector. There is little mention of innovation in the strategy - and we know that the sector is
far behind agriculture and other industries in terms of innovation adoption that could
improve data collection and usage, reduce carbon emissions, improve seafood quality(supporting all facets of this strategy) and reducing environmental impacts of processing
and packaging from the industry. I believe that support for innovation should be explicitly
mentioned in the strategy as well as improving the overall quality of US seafood (which will
likely result in waste reduction as well). Finally, support for extension of many of the USDA
policies - which have supported US farmers over the past century effectively and protected
them against unforeseen events or bad actors in the system - should be extended to theaquaculture and fisheries industries. These policies were put in place almost a century ago
when US farmers were experiencing many of the issues that US fishers and fish-farmers
are today. There is no reason why they should not be extended to the seafood industry.
Thanks for your work on this and your attention to this feedback.

Monica JainNOAA Fisheries Draft National Seafood Strategy_Public Comments

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Casey Emmett

New York

Angela Wilson

Floridano response

no response

no response

no response

General comments/feedback
To whom is may concern, my company, The Crop Project Inc, is a next-generation
ingredients company based in Brooklyn, NY. We contract with kelp farmers in the US -primarily in the Northeast and Alaska -- and turn the resulting crop into useful ingredientsfor CPG companies in the food and beauty industries. We believe that much of the future offarming in the United States will be performed on the ocean, via mariculture: seaweeds,
shellfish, and bait fish, such as sardines and mackerel. Kelp alone is potentially as
impactful to the marketplace as soy has ever been, but far more beneficial to theenvironment and human health, not to mention jobs. In order for these highly beneficial
mariculture crops to scale, however, we require the federal government's support. And it
begins with the farmer, for without them, there will be no mariculture industry. There areexisting USDA programs that support traditional commodity agriculture crops such as cornand soy that should be applied to the mariculture industry. For example, basic crop
insurance and the ability for farmers to be reimbursed if qualified industry buyers, such as
my company, are unable to pay. The majority of innovation and companies in the spaceright now are very small, and thus face natural market headwinds. What is naturally a riskybusiness endeavor -- be it farming a "new" crop or selling that crop wholesale -- is madeeven more so by the void of financial backstop that the federal government provides toplenty of other crops that frankly are demonstrably worse for human health and the broader
environment. Please help. Thank you very much.
I would like fisheries returned to local stewards. I don't approve of foreign ships fishing righton the edge of our boarders. Fish do not perceive the boundaries we draw. I would also likefishery preservation areas. These areas would be closed permanently to fishing to allow
populations a space to recover from fishing pressure.
The Food and Agriculture Sector (FAS) accounts for 20% of the United States (US)economy and has been designated a Critical Infrastructure Sector by the Department ofHomeland Security (DHS). This sector consists of an extensive, open, globallyinterconnected, diverse, and complex array of privately owned "just in time" networks; andencompasses a variety of goods and services including the production and manufacturingof crops, livestock, poultry, and seafood products and by-products. As such, the threats tofood and agricultural resources will come from various sources including foreign anddomestic events, naturally occurring and/or human-induced, and the interdependencies of
FAS with other critical infrastructures. Given the broad scope of these possibilities, the2021 Threats to Food and Agriculture Resources (TFAR) DHS teams focused on the
myriad of threats that could disrupt or devastate supply chains within the vast FAS of theUS; examine shortfalls in US capacity to prevent and mitigate the threats; and recommend
best practices, policy, and research priorities that will foster preparedness and resilience of
the FAS against all threats. The TFAR discussions centered on terrestrial and aquatic
environments in the context of food and agricultural systems, climate change, foodadulteration, disruptions in the transportation sector, water shortages, globalization of
trade/travel, biosurveillance limitations, social culture, cyberthreats, agro/bioterrorism, andeconomic coercion. In-depth capability and vulnerability analyses of the FAS identified
several key areas for utmost attention by the public and private sectors, withrecommendations to prepare for and address the likelihood of emerging threats that could
severely impact the food, agriculture, and aquaculture industries, including:Aquatic/seafood safety and biosecurity.
Globalization will remain the determinant factor to the world's economic, technological, andsocietal progress; with caveats that geopolitical disputes amongst dominant world powers
for access to natural resources, including agricultural and aquaculture/seafood products,
may change the dynamics of the global food supply chain. This will significantly impact the
FAS and its interdependencies with other critical infrastructures. This report can beleveraged to support and address a variety of research requirements embedded within
existing US government policy and doctrine. In particular, six key recommendations were
provided, one of which was: The US government needs to promote domestic aquaculture
for food production. National Security Memorandum-16 (NSM-16) on Strengthening the
Security and Resilience of United States Food and Agriculture (2022) assigns key roles to
It is important to emphasize (Re: NOAA National Sea Grant Aquaculture 5-Yesr Strategy)
that meeting the current and future US seafood demand will require commercial fishing andaquaculture together--not one or the other. It should be important to state this to both US
fishermen and US fish farmers (stakeholder groups) that they are both needed and that thestrategy cannot be "us or them". It is domestic US seafood production versus foreignimports.

NOAA Fisheries Draft National Seafood Strategy_Public Comments

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Kristin Uiterwyk

Massachusetts

General comments/feedback
NOAA’s National Seafood Strategy appears to be a solid framework touching upon many
important pieces of the seafood system. The only addition I would recommend forconsideration is a goal to improve the sustainability of fishing activities. Under this goal, I
would add bullets about (1) supporting efforts to modernize fleets in ways that reduce
emissions, (2) addressing lost/derelict/abandoned gear that contributes to ghost fishing andpollution, and (3) developing technology to address conflicts between gear and othernatural resources (e.g., lobster traps and North Atlantic right whales). Not only will thesetypes of actions contribute to healthier oceans and therefore more vibrant fisheries, butthey also advance the important message to consumers that the seafood industry is
working to maintain a low environmental impact.
Related to the Strategy Implementation plan, please reach out if you would be interested inlearning about the National Working Waterfront Network. The Network may be able to help
gather/distribute information and assist in other ways. I currently serve as Interim Chair andwould be happy to speak with members of your team. (Though to be clear, the comments
above are my own and I am not submitting them on behalf of the Network.)
U.S. seafood continues to be produced sustainably•Offer grant assistance for fisheries that seek sustainability certifications. Offer incentives
for fisheries already certified sustainability or rated A in a Fishery Improvement Plan.
•Provide incentives for sustainable fisheries with grant programs for new equipment, facility
development/expansion, and niche markets (dried shrimp, soft-shell crab, etc.).
•Along the lines of sustainability, NOAA continues to manage (sometimes driven by acts ofCongress) contrary to the idea of sustainable domestic seafood, and as a result forcing
importation, by imposing more and more regulations on US fishermen that are the mostsustainable in the world while ignoring the importation of unsustainable or illegal practices.
One example of this is the ban on the possession of legally harvested shark fins in the US
market. These fins are legally harvested and landed on an intact shark as part of asustainable US shark fishery.
● The U.S. seafood sector contributes to the nation’s climate-ready food production and tomeeting critical domestic nutritional needs•Assist with the purchase of domestic products, especially from those that are certified
sustainable. Promote the purchase of sustainable seafood over imported products.
● U.S. seafood production increases to support jobs, the economy, and thecompetitiveness of the U.S. seafood sector•Grants to assist people entering into a fishery.
•US Fishery jobs will decrease if regulations continue to become more and more restrictivein the US while not taking steps to deal with the importation of seafood that is harvested ina manner inconsistent with US regulations and therefore puts US fishermen at acompetitive disadvantage due to increased compliance costs. Funding to keep US
harvesters competitive is essential if these contradictory management vs. importation
practices are going to continue.

Chris Schieble Louisiana
Dept. of Wildlife & Fisheries

Louisiana● Supply chains and infrastructure are modernized with more value-added activity in the
United States•Tighten the country of origin labeling on value-added products. It is common that imported
seafood products are brought into the U.S. and then go through some value-added process
and are then labeled product of USA.

NOAA Fisheries Draft National Seafood Strategy_Public Comments

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United States fisheries are a sustainable and healthy choice in the diets of many
Americans.
In order to stay competitive and resilient, the fishing industry is going to need NOAA’s
support in the face of massive offshore wind development on and around prime fishinggrounds, aquaculture expansion, and the effects of climate change.
Goal 1: Sustain or increase sustainable U.S wild capture production. Investment is neededin replacing the surveys that the NMFS will be losing due to offshore wind development in
the northeast. US fisheries can’t afford to lose the valuable time series that informs ourassessment and catch advice. Any uncertainty added to our management system due tothis loss will be detrimental to our businesses and markets. With offshore wind starting
development this year, developing a new survey system needs to be a priority. Fisheries
on both sides of the coasts are extremely worried about the effects offshore wind will haveon the ecosystem, oceanography, and access to fish in and around the area. These
potential changes to the ecosystem and oceanography need to be tracked and measured
as soon a steel goes into the water and well after the life of the project.
Fisheries are going to need management flexibility as stocks shift and/or expand into newareas. Changes are going to need to be made in the way we manage fisheries and who
manages specific fisheries. For that flexibility to take shape we are going to need NOAA to
help facilitate those changes to make sure they are done fairly and based on soundscience.

The Town Dock

Rhode Island

no response

no response

Clarice Owens

California

Goal 3: Foster access to domestic and global markets for the U.S seafood industry. The
sustainability of U.S caught seafood needs a massive domestic campaign educating our
citizens about the benefits of choosing domestic caught and managed seafood. We have
many underutilized species here that could benefit from a marketing campaign that would
introduce them as a healthy sustainable option. This could greatly improve our markets for
those species and take pressure off domestic species like cod and some US shrimp thataren’t doing well but are still in high demand. That high demand or species like cod andshrimp draws fish from foreign, and sometimes unsustainable, markets into the country. If
we could market and sell fish that aren’t typically part of our normal fish choices it would
increase jobs, improve markets, and hopefully help us rely less on foreign products.
Support for these markets could come from the government purchasing US wild-caught fish
Within Goal 1, Fisheries Management, I would hope that the strategy includes discussion ofa proposal to adopt improved nationwide standards for fishing gear. From gill nets togroundline traps, these kinds of equipment are certainly not sustainable for the ocean'slargest creatures, particularly the North Atlantic right whale and its ongoing unusual
mortality event (which is primarily due to entanglement). The Ropeless Consortium and its
on-demand gear initiative can serve as potential inspiration.
We have applied to the SK grant program in multiple cycles. The comments from thereviewers are increasingly surprising and seem to betray a basic failure to understand the
dynamics of seafood markets and especially the challenges being faced by the domestic
fleets and processing sector. NOAA seems to also have a defensive posture that does very
little to engender increased understanding. It would be very helpful to convene stakeholders
throughout value chains, reduce the cronyism and protectionism and try to better
understand the issues on the water and in our communities.

NOAA Fisheries Draft National Seafood Strategy_Public Comments

Your name (optional)

Your state/territory(optional)

Molly Lutcavage, Ph.D.

MA and HI

Loretta Roberson

MA

Michael Rust

Washington

General comments/feedback
We have allowed our US fisheries, the best and most sustainably managed in the world, tofail to compete on US market place shelves alongside imported products. Many of theseproducts are sourced from poorly managed fisheries, to say the very least.
-The US needs to do more to support its coastal states fishermen and fishing communities
in terms of recognition at the highest levels of government, so that it's on par with
agriculture and other natural resource commodities.
- NMFS must become more pro-active in debunking false claims made by eNGOs about
US managed fisheries, and stated population status of some species that conflict withdeterminations made by NMFS and scientific bodies of RFMO's determination of status.
NMFS remains the highest standard for reporting on the status of US fisheries.
- NMFS should more vigorously promote the health and economic benefits of eating USsourced ocean products.
- In order for Atlantic commercial and recreational fishermen for tunas and other pelagic
species cannot fully promulgate their economic returns from their businesses (harvest andharvest charters), and have transparency and predictability, NMFS must allow
Congressional action to bring Atlantic HMS species oversight under the scientific andeconomic standards of national MSRA standards, i.e., a Council and SSC, or equivalentsystem. The highly outdated Atlantic Tunas Convention Act framework has failed
miserably, and led to questionable practices of participation, funding, lack of accountability,
non transparency, and a vastly underutilized opportunities for US fishermen and theirbusinesses. Until this is remedied, Atlantic tuna and billfish fishermen struggle toovercome the lack of adequate oversight of these fisheries, with associated high losses ofrevenue, and impacts on consumers and retail markets.
-NMFS must remove the current unsupportable, unscientific determination that sustainably
caught, Pacific billfish species landed by US fishermen in highly monitored longline
fisheries cannot be sold outside of the Main Hawaiian islands or shipped for commercial
sale to the US mainland or elsewhere. This regulation damages economic returns to US
commercial fishermen without justification, and appears to favor special interests.
Given current genomic or other tracking technologies, the justification that Pacific sourced
billfish can not be distinguished from Atlantic billfish is false.
-NMFS should directly work with the USDA, and promote their calls for proposals for $$economic development, value-added, and other food-related grants that are, in fact, open
to ocean producers. This is not well represented in many of their RFP calls, and someThis is much needed to produce more sustainable food and feed, but the permitting
process for new aquaculture operations in both nearshore and offshore areas is broken in
the US and in some states almost impossible, and is also different state to state. Federal
guidelines and cooperation could help make this process more efficient and timely.
NOAA is to be congratulated on developing a seafood plan. I only have three areas of
feedback. 1) In Goal # 1 NOAA includes "increasing" capture fisheries as an option. I am
not sure this should be the top goal, given the unknowns over climate variability (see IPCC
reports) and the cost of management as populations near maximal sustainable yield in an
increasingly variable environment. Rather I would propose using any excess production asa buffer given the extremes in environmental conditions predicted by the IPCC in theirlatest assessment. Holding steady would be enough of a goal. 2) The "gradual" increasein aquaculture under goal 2 is unlikely to significantly increase US seafood for a long longtime, especially if it is only going to be "gradual" - Goal 2 should be Goal 1 and someurgency added. 3) The plan ignores the vast majority of our seafood supply - imports. Our
imports cannot be taken for granted, and largely come from countries that are not on goodterms with the US or have increasing domestic demand (e.g.China). Given that climate
impacts are largely predicted to impact small island development states and developing
countries, might the US seek to use some of it's seafood development resources, to standup sustainable aquaculture for import to the US, in countries friendly to the US, and inregions that will suffer under climate change? That may have the additional benefit ofreducing the pressure for those populations to migrate because they will have sustainableeconomic activities at home. NOAA science has developed plenty of tools that would help
such locations develop a sustainable industry that will likely develop faster than in the US. I
understand that the US seafood industry will not support what they may perceive as thestrategic development of overseas competitors, however the US consumer will benefit withincreasing supplies of sustainable and affordable seafood. I also do not agree with thatindustry assessment, If handled well, the US industry could also benefit. When thinking
about real seafood supply needs in the US, we should be working with friendly countries todevelop a few aquaculture species that can be cultured in numerous countries and at scale.
Otherwise, you are only producing seafood for happy hours at expensive bars catering toprofessionals. Where will the seafood come from for the average blue collar American? It
is time to think about another world fish like farmed salmon. The US does not have theresources devoted to aquaculture to go it alone, so it either needs to step up the resources(unlikely) or partner with other countries to develop a few world fish.

NOAA Fisheries Draft National Seafood Strategy_Public Comments

Your name (optional)

Your state/territory(optional)

no response

California

Brick Wenzel

New Jersey

Veronica G StellyLouisiana

Toby StellyLouisiana

Brad

Fl

General comments/feedback
All efforts to expand marine protection and reduce takes of wildlife should be made.
Aquaculture feeds should not rely upon wild caught fish, krill or other wildlife. Shift to raisingbivalves or herbivorous fishes instead. Fishing methods that result in any bycatch should
be phased out - especially trawls, traps and long lines.
Seafood Gleaning is an important part of any fisheries management plan and should be
mentioned in NOAA's National Seafood Strategy moving forward.
Need help on wild seafood shrimp prices
It's rediculous the low prices we r getting at the docks. How r we supposed to stay inbusiness with very high fuel prices & pitiful low prices we get for our shrimp then to top that
off the expenses to maintain our boats have all gone up since the covid disaster. Pleasefind us solutions. This business is our lives it's what we know it's what we have always
done. Thank u kindly. 🙏
Any help on us getting higher prices for our catch and lower fuel prices would be greatly
appreciated. We can't keep operating like this. The money just s
Isn't there since the covid disaster. It's terrible what's happening to commercial fishermen.
ThanksNOAA’s National Seafood Strategy will be undermined as long as the Gulf of Mexico
Fishery Management Council remains severely imbalanced and heavily-recreationallyfavored.
There is now only 1 commercial fishing representative on the 17-voting-member Gulf
Council that has experience in the commercial fisheries the Gulf Council manages.
The consequences of this imbalance are very real:conservation successes are being unraveled,commercial fishing and seafood businesses are being destabilized,
illegal actions are being recommended,fishing quotas are being slashed, andthe public’s access to wild Gulf seafood is being severely restricted.
This Administration is failing the working people in the Gulf’s seafood industry - the men
and women who support one of the most accountable fishery management systems in theworld - and is instead favoring wealthy boat owners who are being rewarded for consistently
exceeding their science-based annual catch limits.
This is unacceptable to the Gulf’s small seafood businesses and should be to our federal
fisheries agency too.
NOAA should do everything in its power to encourage and support the Secretary ofCommerce rebalancing the Gulf of Mexico Fishery Management Council with commercial
fishing representatives.

Because of continued fishery quota cuts, high quota prices and unavailable quota tomajority of Gulf reef permit holders. High majority of fishery quota being moved over torecreational sector. A huge imbalance of recreational sided voters/ stake holders on Gulf
council making rules cuts and laws.
Tons of the smaller fishery businesses are getting forced out of work. Our profit margin
has collapsed and the fish we are able to harvest are there. But without any quota orcommercial portions of the fishery we are unable to fish them. We provide domestic fish to
the 99 percent of the US that can not afford a boat or have the capability to fish. The
quality and our fishery is light-years ahead of and better than international fish.
We are being forced out of work ; doing what we love and being able to provide food andhousing for our own families.

Zack Istre (Straight Hooks Inc) FL Gulf

I speak for a majority of friends, business partners, other fisherman and family in theabove. Please make a change so we can start making a living again and provide U.S. fish
to U.S. citizens.

NOAA Fisheries Draft National Seafood Strategy_Public Comments

Your name (optional)

Your state/territory(optional)

General comments/feedback
Toxic nitrogen from chlorinated sewage treatment is the culprit and major reasons tofisheries depletion
The poisoning of the fisheries

We should be seeking disaster relief from these injuries! We have chemical poisoning to
the nitrogen base that is the foundation of the marine food web. The marine feeding
system needs good healthy nitrogen, not a poisonous nitrogen, such as the millions of tonsof chlorinated treated sewerage, which has toxic chlorinated by-products that are fed into
marine food chain.
In Narragansett Bay alone, DAILY! We add tons of hypochlorite (chlorine) into the sewage
nitrogen base, then we add tons DAILY! of sodium bisulfate, at the very end of thesewerage outlet pipes that flow into the Bay. Why is sodium bisulfate added at the end?
Because it neutralizes the remaining smelly, free chlorine from flowing into the Bay in orderto make a claim that very little, in fact, just a few gallons of FREE CHLORINE went into theBay. WHAT HAPPENES TO ALL THE TOXIC BY-PRODUCTS? When this chemicalconcoction is fed into the marine food web the poisoning of the entire fisheries begins.
There are two excuses that allow governmental agencies to do this to our fisheries.
One, is the Clean Water Act which states wastewater treatment must follow the E.P.A.
testing standards. Do you think the Trillion-dollar Chlorine industry, may have an influenceon the E.P.A. testing standards? Anyone with common sense will tell you the E.P.A.
testing methods are a joke. The E.P.A. do not research the several hundred Chlorinatedby-products that are toxic to marine life. The biggest fact of all is that Chlorine is a gluttedhazardous waste product, with no place to go. In fact, China pays the U.S. chlorine
industry a disposal fee to get their excess chlorine out of their country. The Russians got
caught mixing their chlorine into the oil pipelines that they were being sent to western
nations.
Bob Morris

Rhode Island

Gary Jarvis

NOAA’s National Seafood Strategy will be undermined as long as the Gulf of Mexico
Fishery Management Council remains severely imbalanced and heavily-recreationallyfavored.
There is now only 1 commercial fishing representative on the 17-voting-member Gulf
Council that has experience in the commercial fisheries the Gulf Council manages. The
consequences of this imbalance are very real and conservation successes are being
unraveled,commercial fishing and seafood businesses are being threatened by unreasonable
reallocation efforts and US citizens access to wild Gulf seafood is being severely restricted..
This Gulf council is failing the working people in the Gulf’s seafood industry - the men andwomen who support one of the most accountable fishery management systems in the world- and is instead favoring wealthy boat owners who are being rewarded for consistently
exceeding their science-based annual catch limits. This is unacceptable to the Gulf’s small
seafood businesses and should be to our federal fisheries agency too. NOAA should do
everything in its power to encourage and support the Secretary of Commerce rebalancing
Gulf of Mexico Florida the Gulf of Mexico Fishery Management Council with commercial fishing representatives.

Second, is leadership from the top. Some marine fisheries and water quality people may

NOAA Fisheries Draft National Seafood Strategy_Public Comments

Your name (optional)

Your state/territory(optional)

William Cochrane Sr.

Texas

General comments/feedback
You say - you are committed to supporting a thriving domestic U.S. seafood economy andenhancing the resilience of the seafood sector in the face of climate change and otherstressors.
I order to do this you should make the Gulf Council balanced with equal members ofCommercial and Recreational.
•NOAA’s National Seafood Strategy will be undermined as long as the Gulf of Mexico
Fishery Management Council remains severely imbalanced and heavily-recreationallyfavored.
There is now only 1 commercial fishing representative on the 17-voting-member Gulf
Council that has experience in the commercial fisheries the Gulf Council manages.
The consequences of this imbalance are very real:- conservation successes are being unraveled,- commercial fishing and seafood businesses are being destabilized,- illegal actions are being recommended,- fishing quotas are being slashed, and- the public’s access to wild Gulf seafood is being severely restricted.
- This Administration is failing the working people in the Gulf’s seafood industry - the men
and women who support one of the most accountable fishery management systems in theworld - and is instead favoring wealthy boat owners who are being rewarded for consistently
exceeding their science-based annual catch limits.
- This is unacceptable to the Gulf’s small seafood businesses and should be to our federal
fisheries agency too.
- NOAA should do everything in its power to encourage and support the Secretary ofCommerce rebalancing the Gulf of Mexico Fishery Management Council with commercial
fishing representatives.

In relation to Fisheries Science in support of Goal 1, it’s discrediting that “economic andsocial analyses” are littered as separate from science when social sciences is an entire
domain of science. Likewise, there is no mention to cultural analyses despite this being a
crucial factor of fisheries and socioecological systems at large. As a third note, ecosystem
dynamics are indeed changing but so, too, are social dynamics. With this in mind, this point
could instead be reworded to “Provide the ecological, economic, social, and culturalscientific analyses necessary for fisheries management under changing socioecologicaldynamics.”
Under Goal 2, the language here reflects attention being paid to aquaculture in its more
modern form, with no mention being made to Indigenous aquaculture technologies andpractices. Given the explicit mention of wanting to partner with Tribes to support
subsistence fishing and traditional Tribal fishing rights, excluding Indigenous aquaculture
from this section seems like a grave absence, particuyltural that Indigenous aquaculture
technologies often work to enhance local ecosystems rather than causing detrimental
impacts.
For Goal 3, there is no mention of science and monitoring to ensure that goals are being
met in regards meeting local demand with local supply, as well as for assessing changing
market dynamics amidst changing ecological and social systems. This is particularly urgent
for ensuring the accessibility of seafood across diverse populations, especially
economically disadvantaged communities, for whom food security and food sovereignty is agrave concern. If we do not devote particular attention to such science and monitoring, we
won’t know if we’re actually successful at accomplishing these goals.

Jonathan Fisk

Hawaiʻi

In regards to the point of Seafood Infrastructure in Goal 4, as with aquaculture before thefocus here is on modernizing things, which certainly has its role, but it also is excluding
Indigenous technologies surrounding seafood infrastructure, which often involve less in theway of imported materials, electricity, and other inputs that might be cut off or otherwise
inaccessible after extreme climatic events or in the case of rising prices. Investing in adiverse array of seafood infrastructure technologies that match local needs and cultures
would increase the diversity of potential solutions, therein bolstering resilience in a myriadof ways and allowing fishing communities to have greater agency over their seafood

NOAA Fisheries Draft National Seafood Strategy_Public Comments

Your name (optional)

Your state/territory(optional)

General comments/feedback
NOAA’s National Seafood Strategy will be undermined as long as the Gulf of Mexico
Fishery Management Council remains severely imbalanced and heavily-recreationallyfavored.
There is now only 1 commercial fishing representative on the 17-voting-member Gulf
Council that has experience in the commercial fisheries the Gulf Council manages.
The consequences of this imbalance are very real:conservation successes are being unraveled,commercial fishing and seafood businesses are being destabilized,
illegal actions are being recommended, fishing quotas are being slashed, andthe public’s access to wild Gulf seafood is being severely restricted.
This Administration is failing the working people in the Gulf’s seafood industry - the men
and women who support one of the most accountable fishery management systems in theworld - and is instead favoring wealthy boat owners who are being rewarded for consistently
exceeding their science-based annual catch limits.
This is unacceptable to the Gulf’s small seafood businesses and should be to our federal
fisheries agency too.
NOAA should do everything in its power to encourage and support the Secretary ofCommerce rebalancing the Gulf of Mexico Fishery Management Council with commercial
fishing representatives.
My boat fishes for Frenchys seafood and catches reef fish for Frenchys retail seafood
house and 10 restaurants .
Tourist come from all over to eat fresh wild caught seafood .

Brian lewis

Clearwater,Florida

no response

FloridaElizabeth Cerny-Chipman

Washington, DC

I purchased 250,000 worth of grouper quota to try to keep our boat fishing economicallyand without having to lease quota .
I have lost 60 percent of our quota due to overfishing practices by the recreational sector .
This Gulf of Mexico council needs to be balanced for the commercial sectors and theircommunities.
Noaa needs to urge the secretary of commerce needs to do a Better job on who they selectto be on the council before we are gone for good .
While I agree with the scope of this Strategy I would like to mention a very important aspectthat is clearly missing? The Gulf of Mexico Fishery Management Council is severely
imbalanced and heavily -recreationally FAVORED? We only have 1 commercial
representative on the 17 voting member Council that has experience in the commercial
fisheries the Gulf Council manages. The consequences of this imbalance are very real. 1
conservation successes are being unraveled 2. Commercial fishing and seafoodbusinesses are being destabilized 3. Illegal actions are being recommended 4. Fishingquotas are being slashed 5. The American public access to wild caught Gulf seafood isbeing severely restricted.
This Administration is failing the hard working people in the Gulf seafood industry? The men
and women who support one of the most accountable fishery management systems in theWorld are being kicked to the curb in favor of wealthy purely recreational boat owners thatare being consistently rewarded by overfishing their science based annual catch limits. The
is unacceptable to the Gulf small seafood businesses like mine? Which I’m a 3’dgeneration fisherman. It should be unacceptable to our federal fisheries agency too. We
believe NOAA should do everything in its power to encourage and support the secretary ofcommerce rebalancing the Gulf Council with commercial fishing representatives. Thank you
Please see the attached letter from Ocean Conservancy, Natural Resources Defense
Council, Mystic Aquarium, Seattle Aquarium, Oregon Coast Aquarium, and Point Defiance
Zoo & Aquarium. Thank you for the opportunity to provide comment on the draft National
Seafood Strategy.

NOAA Fisheries Draft National Seafood Strategy_Public Comments

Your name (optional)

Your state/territory(optional)

Jimmy Hull

FloridaRobert Rheault

East Coast

General comments/feedback
I am happy that you are developing a National Seafood Strategy. I own and operate 4commercial boats a Seafood Market and a Seafoood Restaurant . I employ over 100
people. We provide the General Public Consumers access to our Fisheries resources.
Currently many of our fisheries stocks are being underharvested and mis managed
because of lack funding for stock sampling, monitoring, and timely stock assessments. A
large increase in Fisheries science Funding is needed.
Commercial Harvesters, Fisherman must comply and work with the most complex,
restrictive, expensive regulations and rules to produce Domestic Seafood.
We need regulations reduced and simplified to become more efficient. We should be able
to retain what we catch, not dead discard our catch wasting the resource because of
inaccurate stock status because of a lack of Science. Commercial Fisherman Seafood
consumers and the entire Seafood Industry is underrepresented on the Regional
management councils. Non boating Seafood consumers are losing access to Domestic
Seafood thru reallocation of Seafood quota to Private Recreational sector.
If the Federal Government really wants to increase and improve Seafood production, They
will take their boot off Fishermans necks by reducing overbearing regulations. Also Fundyear round data collection,monitoring and timely stock assessments. And require a equalbalance of representation of Commercial members on Regional management councils.
My business example and story is multiplied thousands of times in coastal communities
across this Nation. Seafood Consumers are by far the largest stakeholder of our fisheries
resources and they need protection to Domestic seafood access. Perhaps the National
Marine Fisheries Service should be in the Department of Agricultural and Fisherman
treated like Farmers.
Thank you
Captain James G. Hull Jr.
I would like to commend NOAA on a brief and succinct policy statement that hits many of
the critical elements. I would especially like to confirm a few key points that i feel are worthyof additional emphasis. NOAA can be a trusted voice that helps get the message out thataquaculture under US regulations is sustainable, and that domestic seafood (wild andcultured) has the highest quality and the lowest carbon footprint. That our seafood domestic
supply is safe and well regulated. A national seafood marketing campaign would help get
this message out.
i would also confirm that we are challenged by several forces: 1) aquaculture science isunderfunded, 2) public use conflicts are blocking development of aquaculture nationwide.
3) a lack of processing capacity hampers the use of underutilized species and cultured
species like kelp 4) the disappearance of working waterfront access is blocking
opportunities to grow the blue economy (including aquaculture, commercial andrecreational fisheries) and in many cases is killing existing farms.
NOAA needs to make substantial creative investments to address these challenges if wewant the domestic seafood sector to grow.
In the wake of Covid, rampant food inflation, and cuts to SNAP we are seeing consumers
turn away from seafood to cheaper and less healthy food options. This will have negative
impacts on our producers and our national health. Unless we see substantial investments inprocessing, messaging, research and waterfront access we can expect our domestic
seafood sector to shrink in the years ahead.

NOAA Fisheries Draft National Seafood Strategy_Public Comments

Your name (optional)

Your state/territory(optional)

General comments/feedback
Below are my comments on various aspects for NOAA's Draft National Seafood Strategy
PurposeNOAA can and should play a role in increasing consumption of seafood, by providing
information about meal preparation and health benefits (or other means). None of the otherparts matter very much if we don't have a customer base that wants seafood and knows
how to prepare it. Ideally, it would be great if an emphasis could be placed on getting
Americans to consume more domestic seafood. This is somewhat addressed within Goal 3,
but feel like it probably should be stated as a purpose as well.
I am not sure "value added" products should be a specific point of emphasis, perhaps tothe detriment of "simpler" product forms. Value-added also means cost added. If moreconsumers could purchase fresh or (properly) frozen dressed fish, that would allow
suppliers to hit a lower price point and broaden the market for seafood. Yes, they'd have tofillet their own fish, but that's great if they want to. Personally, I think filleting most fish iseasier than breaking down a whole chicken. Seafood is seen as pricey, and it is, to a large
degree. Also, fish is more susceptible to quality loss once filleted, than say
beef/pork/chicken. so keeping it intact (for as long as possible prior to consumption) isn't a
bad idea if consumers are willing to cut their own fish. This dressed fish approach also
reduces packaging waste/cost.
Goal 1
I am highly supportive of more adaptive management strategies. Many fisheries havequotas or similar approaches based on sampling the same areas (in the Bering Sea for
instance). But climate change has driven some species to move around a lot more, so it's
imperative that science/mgmt adapt to get a clear picture of stock abundance - not juststock abundance in the places they've historically inhabited.
Goal 2

Andy Wink

no response

Scott Hickman

Texas

Tom Marvel

Floridarandy lauser

florida gulf of mexico

Michael Miglini

no response

If funding is going to be directed towards aquaculture specifically, it only seems reasonable
Great plan but with our unbalanced heavy recreational led gulf council it won’t be of any use
in the Gulf of Mexico.
I whole heartily support this effort to recognize the important role the harvesters ofsustainably harvested seafood fulfill. However, am I the only one who finds it ironic, at best,or hypocritical, at worst, for this measure to be on the table shortly after the Gulf Council
shifted a significant amount of red grouper allocation from the public sector to the private
recreational sector?
we are slowly being pushed out of business do to the unbalanced of the council how do getanything done with 1 commercail and 17 recreational it is not right at all they keep taking
fish from us and giving it to the recs every meeting i go to they already have there mind
made up its getting old we have no one fighting for the commercail side qouta is threw theroof and now with the gags its not right we told them what was going to happen with
amendment 53 and they didnt care
The proposed national seafood strategy is not going to be possible unless the Gulf of
Mexico Fishery Management Council has balanced representation between commercial
and recreational members. There is only one member with commercial fishing experiencein the Gulf of Mexico. NOAA needs to tell the Secretary of Commerce to put morecommercial reef fishing members and federally permitted 6-pack operators on the Guld
Council. Many of the good changes to sustainable fishing are being undone by theimbalanced council and allocations are being taken away from seafood harvesters. The
current administration is not being equitable to commercial harvesters who are the mostaccountable sector in the Gulf of Mexico.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

SOUTH ATLANTIC FISHERY MANAGEMENT COUNCIL
4055 Faber Place Drive, Suite 201, North Charleston SC 29405
Call: (843) 571-4366 | Toll-Free: (866) SAFMC-10 | Fax: (843) 769-4520 | Connect: www.safmc.net
Carolyn N. Belcher, Ph.D., Chair | Trish Murphey, Vice ChairJohn Carmichael, Executive Director

South Atlantic Fishery Management Council Comments
NOAA Fisheries Draft National Seafood Strategy
March 15, 2023
The South Atlantic Fishery Management Council (Council) appreciates the opportunity tocomment on the NOAA Fisheries Draft National Seafood Strategy (Strategy). The Council has
followed development of the Strategy through updates to the Council Coordination Committee
and discussed the Strategy during its March 2023 meeting. The Council supports the visionstatement and objectives and is committed to working with NOAA Fisheries to ensure asustainable and viable US seafood sector.
Infrastructure emerged during Council discussion as a critical and necessary component toensuring a thriving seafood economy. Without adequate infrastructure none of the strategy goals
can be met. While the strategy addresses a vision to modernize infrastructure, within the South
Atlantic there is an added need to preserve existing, and replace lost, infrastructure. The threatsof climate change, increasing coastal populations, and waterfront development have combined in
the South Atlantic to greatly reduce fishing related infrastructure. It is impossible to gain benefits
to employment and communities or support thriving seafood markets and restaurants if there isno place in the community to land fish, berth, and service vessels. Access to fresh seafood is one
reason so many South Atlantic locales make lists of top coastal tourist destinations, yetdevelopment to support increasing tourism often replaces the fishing industry infrastructure thatis part of the appeal of these areas. Increasingly, this loss extends to the for-hire recreational
industry as well as the seafood industry. In addition to working with federal agencies tomodernize infrastructure as noted, the Council recommends that NOAA Fisheries use the Goalsof the Strategy to promote partnerships with municipalities to support and expand infrastructure.
Many of the species managed by the Council are considered ‘data poor’ and are unassessed, andsignificant uncertainty buffers are applied to most assessed stocks due to gaps in data andshortcomings in our understanding of stock characteristics. Such buffers may help ensure stock
sustainability in the face of uncertainty, but they pose a challenge to ensuring fisherysustainability as desired under Goal 1 and they impose a significant loss of revenue on theseafood economy in the South Atlantic. Additionally, chronic data deficiencies hinder our efforts
to adapt to climate change. It is impossible to know how a stock is changing when there isinadequate baseline information on the stock historically. The Council considers increased fishery
data, independent population monitoring, and stock assessment capabilities critical to improving
management and maximizing opportunities and production as required to meet Goal 1.
The Council agrees that there is a significant labor shortage in the seafood industry. Barriers to
new entrants are also an issue, and include more than just permit limitations. Regulations arecomplex, challenging, and subject to change with little warning relative to business planning
timelines. Some common regulations, such as trip limits, can reduce the potential for profitability

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

from each trip. The lack of clear pathways to fully joining the industry in the future can deter
young fishermen from entering the industry as the deckhands of today. Fishing businesses canhave difficulty securing the kinds of financial support and assistance that are available to moreconventional businesses. The Council recommends that NOAA Fisheries develop and support
fishing industry vocational education programs directed at fishing industry participants incommunities that still have a fishing influence. Additionally, the Council recommends thatNOAA Fisheries develop financial infrastructure or build relationships with financial institutions
to increase the financial support available to seafood businesses, including facilitating loans or
grants for new fishery entrants where permit or share costs are prohibitive.
The Council strongly supports efforts in Goal 3 to increase public awareness of the value of US
seafood. Markets are under constant threat from imports and consumer opinion is too easily
swayed by incorrect and inappropriate information about which stocks are sustainable. The
Magnuson-Stevens Act is built upon the ideals of conservation and precaution and has resulted in
US fish stocks being arguably the best managed in the world. NOAA Fisheries monitors thesustainability of all managed stocks and should work to ensure that consumers have access to fairand unbiased information about stock conditions. The Council recommends developing
marketing approaches that promote factual information to educate consumers about the value offresh, wild seafood and the highly regulated industry that exists to provide seafood products.
Working with existing trade groups, such as the National Restaurant Association, could greatly
expand the impact of such efforts. The Council also recommends that NOAA Fisheries beproactive in addressing false and misleading information about fishing practices and stock
sustainability put forth by advocacy groups.
The Council supports the Goals of the Strategy and commends NOAA Fisheries on identifying
the many significant threats to the seafood economy. We appreciate the opportunity to provide
these comments, and look forward to continued collaboration as actions, timelines andmilestones are developed. Please feel free to contact John Carmichael, Executive Director(john.carmichael@safmc.net) if you require any additional information.

Sincerely,

Carolyn N. Belcher, Ph.D.
Council Chair
LN# 202305
cc: SAFMC members and staff

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

March 31, 2023
Ms. Janet Coit
Assistant Administrator
National Oceanic and Atmospheric Administration
NOAA Fisheries
1325 East-West Highway
Silver Spring, Maryland 20910
Re:

Shareholders’ Alliance comments on NOAA Fisheries’ Draft National
Seafood Strategy.

Dear Administrator Coit,
On behalf of the Gulf of Mexico Reef Fish Shareholders’ Alliance (Shareholders’ Alliance),please accept these comments on the NOAA Fisheries Draft National Seafood Strategy.
The Shareholders’ Alliance is the largest organization of commercial grouper and snapper
fishermen in the Gulf of Mexico. We work hard to ensure that our fisheries are sustainably
managed so our fishing businesses can thrive and our fishing communities can exist for future
generations. We are harvesters that provide the American public with a reliable source ofdomestically-caught wild Gulf seafood, and we do this through a philosophy that sustainableseafood and profitable fishing businesses depend on healthy fish populations.
To that end, please accept the following comments on the NOAA National Seafood Strategy.
GOAL 1: Sustain or increase sustainable U.S. wild capture production
The Shareholders’ Alliance actively supports this goal. Science-based fisheries management is
the keystone to sustainable wild capture production and we continue to fight to protect the
Magnuson-Stevens Fishery Conservation and Management Act (MSA) and promote its coretennants of accountability, sustainability, and scientific integrity.
That being said, the biggest threat to sustaiable U.S. wild capture production in the Gulf of
Mexico is the severely imbalanced Gulf of Mexico Fishery Management Council (Gulf Council).
The Gulf Council has had its commercial representation steadily whittled away and replaced byprovate recreational interests. The disregarding of commercial fishermen’s voices continued in
2022 as the Biden Administration announced that the Mississippi seat on the Gulf Council – aseat held by Mississippi commercail fishing representatives for more than 20 years – was handed

Gulf of Mexico Reef Fish Shareholders’ Alliance1902 Wharf Rd
Galveston, TX 77550
www.shareholdersalliance.org

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

over to a private recreational angler, further marginilizing ocmmercial fishing and conservationinterests.
This has left the Gulf of Mexico’s commercial fishermen with one single representative on this17-member body who has experience in the commercial fisheries this Gulf Council manages.
One.
The Gulf of Mexico’s seafood industry deserves better.
The consequences of this imbalance are very real: conservation successes are being unraveled,commercial fishing and seafood businesses are being destabilized, illegal actions are being
recommended, fishing quotas are being slashed, and the public’s access to wild Gulf seafood isbeing severely restricted. Red snapper, the remarkable stock that bounced back faster thananyone expected, are now in decline due to mismanagement of the private recreational sector andits chronic overfishing; yet the Gulf Council almost-unanimously recommended – and NOAA
Fisheries is poised to implement – an increase in catch levels. Gag grouper and amberjack
quotas now have to be cut by as much as 80% because their populations are so low, due in part tothe high volume of recreational discards and high mortality. Red grouper were just reallocatedfrom the commercial sector to the recreational sector despite NOAA Fisheries’ own analysis
concluding that this action will increase bycatch, increase management uncertainty, and increaserisk of overfishing of the red grouper stock.
The United States Departent of Commerce and NOAA Fisheries should be better than this. The
Biden Administration is failing the working families in the Gulf’s seafood industry, who support
one of the most accountable fishery management systems in the nation, and is instead favoring
wealthy boat owbers who are being rewarded for consistently exceeding their science-based
annual catch limits.
This is unacceptable to the Gulf’s small seafood businesses and should be to NOAA Fisheries,
too. NOAA should do everything in its power to encourage and support the Secretary ofCommerce rebalancing the Gulf Council with commercial fishing representatives and allow thisstakeholder body to start prioritizing the health of the Gulf’s fish stocks once again. Otherwise,
any attempts to sustain or increase sustainable U.S. wild capture production in the Gulf of
Mexico will be udnermined and thwarted.
Thank you for considering our comments.
Sincerely,

Eric Brazer
Deputy Director

Gulf of Mexico Reef Fish Shareholders’ Alliance1902 Wharf Rd
Galveston, TX 77550
www.shareholdersalliance.org

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

March 28, 2023

North Pacific Fishery Management Council Comments
NOAA Fisheries Draft National Seafood Strategy

To Whom It May Concern:
The North Pacific Fishery Management Council appreciates the opportunity to comment on the Draft
National Seafood Strategy. We support the purpose of the National Seafood Strategy and the goals ofsustainable seafood production, climate-ready fisheries and communities, market access and economic
competitiveness, and a growing and diverse workforce. Our focus of these comments is on Goal #1,
sustaining U.S. wild capture production.
The North Pacific Council has a successful record of science-based, sustainable fisheries management
since the Magnuson-Stevens Fishery Conservation and Management Act was implemented in 1976. Eachyear for the past 40 years, the sustainable harvest of groundfish in the North Pacific totals 2,000,000
metric tons or greater. Harvest off Alaska currently accounts for over 60% of the total U.S. catch and iscritical to ensuring food security for the nation due to both the size and the stability of the annual yield.
These yields are a direct result of Council management for sustainable fisheries that provide benefits for
harvesters, processors, recreational and subsistence users, and fishing communities, which (1) aremaintained by healthy, productive, biodiverse, resilient marine ecosystems that support a range ofservices; (2) support robust populations of marine species at all trophic levels, including marine mammals
and seabirds; and (3) are managed using a precautionary, transparent, and inclusive process that allows
for analyses of tradeoffs, accounts for changing conditions, and mitigates threats. The North PacificCouncil has a four-decade track record of demonstrating that sustainable fisheries production is possible
when based on robust fisheries science and conservative fishery management policies.
Sustainable wild capture fisheries require sound science and monitoring programs, particularly in the faceclimate change. The North Pacific Council has invested significant time and resources, along with NOAA
Fisheries, to initiate several efforts to better understand and respond to ecosystem effects in the marine
environment driven by climate change. The Council reviews annual Ecosystem Status Reports thathighlight trends and anomalies tailored toward supporting the Council’s annual process to set groundfish
harvest specifications. The Council has also initiated a multi-year effort to evaluate the vulnerability of
key species and fisheries to climate change and to strengthen resilience in regional fisheries management.
A recently published Climate Readiness Synthesis evaluates whether North Pacific Council management
tools, stock assessments, and information onramps are able to accommodate and consider theunprecedented conditions and unique challenges presented by long-term climate change.
To maintain sustainable production in the North Pacific and improve our resilience in the face ofincreasing change in the ecosystem, NOAA must prioritize fisheries-independent and -dependent surveys.
These surveys are the fundamental data source for groundfish stock assessments and ecosystemassessments, and are the most critical responsibility of the NOAA Alaska Fisheries Science Center to beable to meet its mission of monitoring the health and sustainability of living marine resources and theirNational
Seafood
Strategy
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March 28, 2023
Page 2

habitat. The Council would also like to stress the importance of re-evaluating and potentially expanding
survey designs as conditions and stock distributions change.
Adequate funding for fisheries management and science surveys is critical to meeting the goal ofsustaining or increasing wild seafood production. Without significant increases to the base funding for
NOAA Fisheries Science Centers, the scientific research possible will be insufficient for the Councils tosustain or increase fisheries production in the U.S. With reduced funding and staffing for research, theAlaska Fisheries Science Center has already had to drop critical surveys of the slope region and the Gulf
of Alaska. With fish and crab moving deeper and northward due to ocean warming (e.g., pollock, Pacificcod, and snow crab), it is imperative to secure permanent funding necessary to provide comprehensive
and consistent data for stock assessments and research projects, including in the northern Bering Sea, tounderstand and manage for the impacts of climate change. Inadequate scientific surveys result in an
unnecessary reduction in sustainable yields of wild stocks. Under the Council’s precautionary catch
control rules, less scientific information increases the uncertainty buffers, resulting in lower annual catch
limits and reduced yields. It is also critical to ensure that all necessary ecosystem scientist positions andstock assessment scientist positions at the Alaska Fisheries Science Center are filled and fully funded.
Fewer assessment biologists necessitate longer intervals between assessments, which will potentially haveadverse effects on the sustainability of marine resources and reduce the U.S. seafood supply.
Additional funding for the Regional Fishery Management Councils is necessary to support effective andefficient management. Costs for the Councils (including personnel, health care, meeting, and travel costs)
are rising at much faster rates than the small incremental increases received for Council funding.
Combined with the additional mandatory requirements the Councils must complete over time (including
regular program reviews, allocation reviews, essential fish habitat reviews, etc.), the ability of theCouncils to manage for optimum yields, provide effective management, and react to changes in ocean
conditions is greatly reduced without sufficient funding.
Lastly, we suggest that the implementation plan for increasing seafood production under Goal #1 consider
ways to reduce discards of wild fish, increase utilization, and reduce waste. This may include evaluating
regulatory barriers that force discards of edible wild seafood (e.g., size limits, bag limits, retention limits),
as well as development of management measures and marketing support that could encourage retention offish that are discarded due to being a currently unmarketable species or of a size that is not profitable toretain or process. We suggest that, as part of the implementation plan, NOAA fisheries highlight thesemanagement challenges as priorities to be addressed, and work with the regional fishery management
councils and the fishing industry to develop alternative management approaches and incentives toincrease retention and utilization of wild seafood.
In conclusion, the North Pacific Fishery Management Council supports the Draft National Seafood
Strategy and its goals. However, we suggest incorporating the changes mentioned above to ensure its
success as you develop an implementation plan. Please continue to include the Councils as you finalize
the strategy and develop a timeline for its implementation. We thank you for considering our comments.
Sincerely,

Simon Kinneen
Chair, NPFMC

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

March 16, 2023
Janet Coit
Assistant Administrator
National Oceanic and Atmospheric Administration
National Marine Fisheries Service1325 East-West Highway
Silver Spring, MD 20910
Re: Comments on NOAA Fisheries’ Draft National Seafood Strategy
Dear Assistant Administrator Coit:
We appreciate the opportunity to comment on the National Marine Fisheries Service’s (“NOAA
Fisheries”) Draft National Seafood Strategy (“Strategy”). This Strategy lays out the initial steps
to ensuring the U.S. seafood industry remains resilient, sustainable, accessible, and profitable.
Domestically produced seafood is among the lowest carbon footprint protein and incredibly
nutritious, underscoring the importance of our industry in addressing climate change andsecuring our nation’s food security. We applaud NOAA Fisheries for its work on this strategy
and appreciate the opportunity to provide feedback.
Seafood Harvesters of America (“Harvesters”) is a national commercial fishing organization with
21 member groups representing thousands of fishermen from Alaska to Hawaii to Florida to
Maine. We are proud stewards and harvesters of America’s seafood, our nation's strategic
protein reserve and a critical component of our country’s food security. We work closely withNOAA officials around the country to ensure our fisheries are accountable, sustainable, andprofitable, and that domestic seafood products are accessible to American consumers.
We appreciate the high-level framework laid out in the Strategy, as well as the comments in the
introduction highlighting the importance of wild capture seafood, its sustainability, and its role asa low-carbon, nutrient dense source of protein. Today, we will provide feedback and comments
on parts of the strategy that we believe are particularly important. We also request additional
opportunities to comment on the Strategy as NOAA Fisheries develops more detailed
implementation plans.
Goal 1: Sustain or increase sustainable U.S. wild capture production
Fisheries Science: This briefly stated goal captures one of Harvesters’ key priorities: support
NOAA’s work to expand data collection through both traditional and innovative methods. We
1

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

wholeheartedly support the importance of fisheries science to the sustainable management of
our ocean. It is critical to both maintain existing longstanding federal fisheries surveys and otherlong-term data sets while also working to incorporate new data collection methodologies,
including uncrewed systems, buoys, fishing gear sensors, etc. Additionally, in the face ofincreasing uses of federal waters (offshore wind energy development, offshore aquaculture, forexample), NOAA should also aim to expand cooperative research efforts with fishing industry
participants to maximize data collection. NOAA should prioritize core fisheries surveys and datacollection efforts above all else; any expansion of data collection cannot occur at the cost of
NOAA’s core mission work.
Fisheries Management: We appreciate NOAA Fisheries’ nod to the need to maximize fishing
opportunities while ensuring the sustainability of our fisheries resources, particularly in the faceof a changing climate. This will require significant work at the headquarters and Council level,
including supporting more proactive and agile management informed by real-time data. We
continue to hear from our membership that the time lag between data collection and surveys,
and management decisions significantly hinders the industry’s ability to capitalize on upswingsof a fish population and hammering them on the downswing. The agency’s ability to support
adaptive management in the face of climate change will also require easier and more timely
data sharing between regions. As marine animals react to changing ocean conditions, we not
only need to be able to observe those reactions, but we also need for Fishery Science Centersaround the country to be able to readily access that data regardless of their stated jursdiction.
As we all know, fish don’t care about arbitrary lines on a map. Improving data systems to
support real-time data collection and analysis, as well as accessibility, will go a long way toachieve this goal.
Goal 2: Increase sustainable U.S. aquaculture production
We encourage NOAA Fisheries to work towards this goal in an informed and mindful way. The
onshore infrastructure required to support increased aquaculture production will be significant.
At a time where commercial fishing access to working waterfront infrastructure is alreadydecreasing, we urge NOAA Fisheries to not further exacerbate this pain point for wild capture
fishermen. We also encourage NOAA Fisheries, and other permitting agencies, to continue tobe transparent in the siting process for any potential offshore aquaculture facilities. Again, as
competition for offshore waters is increasing, we urge NOAA Fisheries to not harm the ability of
the wild capture sector to harvest seafood for the American people.
Goal 3: Foster access to domestic and global markets for the U.S. seafood industry
Communication and Promotion: We appreciate NOAA Fisheries’ recognition of the need toincrease the public’s awareness of the availability, sustainability, and nutritional value of all U.S.
seafood, and we strongly support the agency’s work in this specific area. There is room toincrease and better use the funding available through the Saltonstall-Kennedy (SK) Grant
program to support the needs of the seafood industry in marketing and promoting domestic
seafood products. We also urge the agency to better promote Fishwatch.gov as an educational
tool to help American consumers not just learn about different types of seafood, but to learn
about the management context and the health of a particular fishery or fish stock. Because
there are multiple competing eco-labels and standards that can confuse consumers, NOAA
Fisheries should play an important role in serving as an unbiased, science-focused source of
information for consumers.
U.S. Market Development: We have long encouraged the U.S. government to aid in keeping
domestic seafood products here in the U.S. on the plates of our fellow Americans. Reducing ourreliance on imported seafood not only reduces the carbon footprint of the wider seafoodindustry, but provides a valuable opportunity for U.S. consumers to support their local fishermen2Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

and learn about local products. In addition to identifying and building domestic seafood markets,
we encourage NOAA to examine how to reduce reliance on overseas processing capabilities.
By increasing domestic processing capabilities, we will increase the seafood industry’s
resiliency, reduce the carbon footprint of our industry, and create job opportunities.
Goal 4: Strengthen the entire U.S. seafood sector
Seafood Infrastructure: The U.S. seafood infrastructure, including vessels, processing, working
waterfronts, and others, is aging. In particular, our fishing vessels are decades old and we facesignificant barriers to building new vessels that are safer, more efficient, and reduce our carbon
footprint. Investments to modernize our processing facilities would increase efficiency while
creating opportunities for more value-add processing in the U.S. Additionally, investments topreserve working waterfront access for the seafood industry would provide stability for theindustry around the country, especially as development threatens to squeeze access in many
coastal communities. Prioritizing investments to upgrade and modernize our seafood industry
will significantly strengthen the U.S. seafood sector against the backdrop of climate change andglobal dynamics.
Workforce Development: Harvesters have long supported workforce development and training
for the commercial fishing industry, as well as our related support industries (welding,hydraulics, diesel mechanics, etc.). There is growing concern that fewer young people are
opting to become commercial fishermen, which threatens our national food security. We
encourage NOAA Fisheries to work with the National Sea Grant College to fully implement theYoung Fishermen’s Development Act to provide the necessary training and business planningsupport for those interested in the seafood industry. Additionally, rapidly changing fisheryconditions have spawned an unprecedented number of fishery disasters across the country inrecent years. This has highlighted the need for much faster disaster relief to fishermen andcommunities, as well as the need for other mitigation measures when necessary for fishingbusinesses and individual fishermen (e.g. SBA EIDL program or job retraining resources).
We appreciate the opportunity to provide our feedback on NOAA Fisheries’ Draft National
Seafood Strategy. We understand the agency will prepare an implementation plan that contains
more specific actions, timelines, partnerships, and milestones, and we request the opportunity
to review and comment on that plan when it becomes available.
We are available to answer any questions you may have or provide additional information
should you require it. Thank you for your consideration of our comments and feedback.

Respectfully,

Chris Brown
President

Leigh Habegger
Executive Director

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Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Responsible Offshore Development Alliance

March 31, 2023
NOAA Fisheries
Re: NOAA Fisheries Draft National Seafood Strategy
Submitted online via - NOAA Fisheries Draft National Seafood Strategy
The Responsible Offshore Development Alliance (RODA) and the undersigned fishing industry
representatives appreciate the opportunity to submit the following comments on the NOAA
Fisheries Draft National Seafood Strategy (Draft Strategy).1 RODA is a national coalition of
independent fishing businesses, associations, companies and community members committed toensuring the compatibility of new offshore development with their businesses. RODA members
operate in federal and state waters and shoreside throughout the New England, Mid-Atlantic, andPacific coasts.
We very much applaud the intent behind the document - supporting a thriving domestic U.S.
seafood economy and enhancing the resilience of the seafood sector in the face of climatechange and other stressors. As noted in the Draft Strategy, the U.S seafood industry is an
important contributor to our nation’s economy and food security. Moreover, we provide millionsof Americans access to the living marine resources of our coasts.
In February, NOAA Fisheries published the Fisheries Economics of the United States Report,
2020 (FEUS 2020).2 U.S. commercial fisheries supported 1.1 million jobs in 2020 andgenerated $154.7 Billion in sales and another $62.5 Billion in value added economic benefits.3
These are down from 2019’s 1.2 million jobs, $165 Billion in sales and $68 Billion invalue-added.4 When one considers the impacts of the COVID-19 pandemic on harvesters,
processors, and other integral components of the supply chain, the slight reduction in jobs, sales
and value-added speaks to the importance and resiliency of our domestic seafood industry. In
short, our fishermen and women rose to the occasion and fed the nation when other foodproducing sectors were forced to shutter because of the pandemic.
1

Published on the NOAA Fisheries website on February 14, 2023. See https://www.fisheries.noaa.gov/s3/2023-02/Natl-Seafood-Strategy-Final-Draft-Public-Comment.pdf
2

See - https://www.fisheries.noaa.gov/resource/document/fisheries-economics-united-states-2020

3

FEUS 2020 describes value-added as the contribution made to the gross domestic product in a region. See - FEUS
2020, page 9. Available athttps://www.fisheries.noaa.gov/resource/document/fisheries-economics-united-states-2020

4

See - https://www.fisheries.noaa.gov/resource/document/fisheries-economics-united-states-report-2019

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Our domestic harvesters are also integral to the culture and fabric of many coastal communities
and the foundation upon which many ports and harbors were built. The State of Rhode Island
named calamari the state appetizer in 20145. The author of The Rise and Fall of Commercial
Fishing in Morro Bay says it best, “Not only is the fishing industry of Morro Bay a powerful linkto the past, but it is also an integral part of the city’s identity and provides a great sense of pridefor its local residents.”6 We suggest this sentiment is felt in many ports and harbors across the
U.S. The allure of the fishing heritage in ports and harbors across the U.S. continues to be a draw
for tourists to those areas to watch local fishermen ply their trade and to sample their catch inrestaurants on the waterfront.
In May of last year, the Administration set a goal of ending hunger and increasing healthy eating
and physical activity in the U.S. by 2030.7 It is beyond dispute that wild capture seafood is ahealthy dietary component. The United States Food and Drug Administration (US FDA) has
repeatedly touted the health benefits of including seafood in your diet(s). Positively Groundfish
recently published a nutrition and health benefits fact sheet outlining species-specific nutrient
information.8 America’s seafood consumers are rightly concerned about where their seafood
comes from. When choosing to purchase domestically sourced wild capture seafood, those
consumers can rest assured the product was harvested under strict management frameworks
implemented in accordance with the Magnuson-Stevens Fishery Conservation and Management
Act (MSA).9 In addition to being sustainably sourced by gear types that minimize impacts toprotected and bycatch species, our wild capture harvesters provide this protein source with lessof an impact on climate than imported seafood and most domestic terrestrial-based protein
sources. In 2018, Dr. Ray Hilborn co-authored a study entitled “The environmental cost ofanimal source foods.”10 This study found that a diet that included seafood, in particularwild-capture seafood, would result in less environmental costs compared to diets rich in otheranimal source foods. Similarly, a 2021 study quantified the climate forcing (potential impacts on
climate drivers) per unit of fish protein associated with several U.S. tuna fishing fleets, among
the most important capture fisheries by both volume and value. That study found that skipjack5

See https://www.providencejournal.com/story/news/politics/county/2014/06/21/20140620-calamari-as-official-appetizergets-ri-assembly-approval-ece/35345757007/

6
See - http://historicalmorrobay.org/wp-content/uploads/2019/06/Hidden-History-Final-Project-Copy-1.pdf. Last
accessed March 14, 2023.
7

See https://www.whitehouse.gov/briefing-room/statements-releases/2022/05/04/white-house-announces-conference-on-hunger-nutrition-and-health-in-september/8

See - https://www.positivelygroundfish.org/nutrition

9

16 U.S.C. §§ 1801 et seq

10

Hilborn, R., Banobi, J., Hall, S. J., Pucylowski, T., and Walsworth, T. E. (2018). The environmental cost of animal
source foods. Front. Ecol. Environ. 16, 329–335. doi: 10.1002/fee.1822

2

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

tuna caught by purse seine, results in lower climate forcing than all other sources of proteinsexamined with the exception of plants.11
Above, we briefly mentioned our role in providing the vast majority of Americans access to theliving marine resources off our coasts. While some of us have the ability to go out on the ocean
to catch our own fish; most do not. Concerns about environmental and social justice are
inexorably linked to food consumption. The U.S. has strong labeling requirements. “Women
that are pregnant or trying to become pregnant need to monitor the kinds of fish they eat due tohigher mercury concentrations in some species of fish. A mislabeled fish could unexpectedly
raise mercury levels in the body and create problems for an unborn baby. Though uncommon, if
a fish has a drastically different nutritional profile than its label would indicate, some people,
particularly women, could be at risk as mercury in fish can cause birth defects. Pregnant womenare advised to avoid certain species of high-mercury fish during pregnancy. If a high-mercury
fish was passed off as a low-mercury fish, a mother and unborn child could be at risk.”12
Americans worried about the nutritional value of the seafood they consume, can rest assured that
our labeling requirements address those concerns.
We provide the above to reiterate the importance of the seafood industry to the United States andhighlight that it is one worth supporting, promoting, expanding and protecting. We areconcerned that neither of those are likely given the unprecedented challenges facing industry, as
outlined in the Draft Strategy.
● Climate change
We agree that changing ocean conditions are impacting stock distribution(s) andaccessibility for harvesters. As stocks shift, infrastructure will be needed to support
fisheries in those new areas. For example, on the west coast, market squid (loligo
opalescens) is available in new areas. In recent years, harvestable quantities havegathered off the Oregon coast. The local fishermen have been able to harvest theresource because suitable infrastructure exists in the local ports and harbors.
● Coronavirus pandemic
As noted above, U.S. fishermen and women navigated the pandemic admirably.
11

McKuin, B, Watson, JT, Stohs, S, Campbell, JE. 2021. Rethinking sustainability in seafood: Synergies andtrade-offs between fisheries and climate change. Elementa: Science of the Anthropocene 9(1). DOI:
https://online.ucpress.edu/elementa/article/9/1/00081/116726/Rethinking-sustainability-in-seafoodSynergies-and
12
University of Washington Sustainable Fisheries blog post entitled, Social & Environmental Justice in Seafood.
Available at https://sustainablefisheries-uw.org/seafood-101/social-environmental-justice-in-seafood/. See also
Relationships between seafood consumption during pregnancy and childhood and neurocognitive development: Twosystematic reviews Joseph R. Hibbeln, Philip Spiller, J. Thomas Brenna, J.J. Strain et al October 11,2019
DOI:https://doi.org/10.1016/j.plefa.2019.10.002

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Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Developing new and creative ways to get seafood from the vessel to an eager public by
off-the-boat sales, home delivery services, etc. The fishing industry is still feeling theimpacts of the pandemic - especially by those fisheries which are dependent on shipping.
Container availability and logistics remain problematic.
● New technologies
As a member of the Pacific Fishery Management Council recently said, “Offshore windis the biggest threat to the fishing industry that I have seen in my lifetime.” The Draft
Strategy is incorrect when it suggests that offshore wind will “potentially result in
conflicts.” Offshore wind, and other potential new ocean uses, will result in conflicts
for the U.S. fishing industry.. The process being utilized by the Bureau of Ocean
Energy Management (BOEM) all but assures that. We acknowledge and appreciate thework being done by NOAA’s National Centers for Coastal Ocean Science (NCCOS) in
developing a spatial suitability modeling tool that can help in identifying areas on theouter continental shelf suitable for offshore renewable energy developments. In
determining suitable sea space, those areas which are important to our commercial,recreational, tribal and subsistence fisheries should be deemed unsuitable.
Not only will these technologies create conflicts, they will significantly impact ourfisheries. While some of these impacts are identifiable (loss of fishing grounds, reduced
harvest guidelines, etc) others are reasonably foreseeable; but the magnitude is unknown.
For example, how will upwelling, nutrient transfer, larval transport and other ecosystem
functions be impacted? Changing migratory patterns of whales and other protected
species may have profound impacts on the west coast dungeness crab fishery and otherfixed gear fisheries. NOAA Fisheries, as a science provider, is integral to our operations.
It is disappointing that NOAA Fisheries is not pushing back on the rush to industrialize
our oceans with unproven technology with unknown impacts.
● Labor shortages and infrastructure
The Greying of the Fleet is a significant issue and the lack of the next generation offishermen and women should be a concern to all Americans. One strategy to address thisis messaging the importance of our profession to the public. Far too often, our fisheries
and the men and women who operate in this profession, are vilified in public. Whether it
be whale entanglements, overfished status of a stock, etc - those become newsworthy
events that some groups highlight in their fundraising efforts. Particularly with regard to
overfished stocks, fishing might have had no role in the stock status change. For
example, Pacific sardine was declared overfished in June of 2019, nearly 4 years after
the directed fishery closed.
We touched on infrastructure needs above. In addition to ensuring ports and harbors are4

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

equipped to support fisheries new to an area, the dilapidated condition of existing
infrastructure is a concern.
Missing from the Draft Strategy is any mention of policy initiatives that have the potential togreatly curtail our ability to access living marine resources. Section 216 of Executive Order
1400813 established a goal of conserving at least 30% of our lands and waters by 2030. In
October of 2020, the Governor of California executed Executive Order N-82-20 which
established “the goal of the State to conserve at least 30 percent of California’s land and coastal
waters by 2030.”14 Neither of these executive actions define “conserve”. We expect similaractions to be proposed and/or initiated in other coastal states. Similarly, earlier this month theUnited Nations announced it had reached agreement on an international legally binding
instrument15 under the United Nations Convention on the Law of the Sea on the conservationand sustainable use of marine biological diversity of areas beyond national jurisdiction.16 U.S.
based fisheries which operate on the high seas are rightly concerned about implementation of theagreement. While we understand and appreciate the need to conserve biodiversity, it must be
understood that U.S. fisheries are managed towards that goal. Any definition of conservationthat fails to acknowledge the important social and economic contributions of our fisheries andfails to identify specific threats to biodiversity from our operations should be avoided.
Many RODA members will be submitting comments specific to their fisheries or concerns. We
defer to their sector-specific expertise and individual experiences.
GOAL 1: Sustain or increase sustainable U.S. wild capture production
We very much support and applaud this goal. For the reasons highlighted above, the U.S. wild
capture seafood industry is one worth protecting, supporting, and expanding. Unfortunately, thechallenges identified in the Draft Strategy and addressed above represent significant barriers to
the attainment of this goal.
We are at the precipice of industrializing the ocean with technologies whose impacts on themarine environment, ecosystem, and marine species remain largely unknown. To RODA and our
13

86 Fed. Reg. 7627 (February 1, 2021)

14

See - https://www.gov.ca.gov/wp-content/uploads/2020/10/10.07.2020-EO-N-82-20-.pdf

15

See https://www.un.org/bbnj/sites/www.un.org.bbnj/files/draft_agreement_advanced_unedited_for_posting_v1.pdf
16

See https://www.un.org/sg/en/content/sg/statement/2023-03-04/statement-attributable-the-spokesperson-for-the-secretary-general-intl-legally-binding-instrument-under-the-un-convention-the-law-of-the-sea?_gl=1*8sc79t*_ga*NDIyMjY
0MTcyLjE2NzYxNzAyODE.*_ga_TK9BQL5X7Z*MTY3ODA3MjkyMS43LjAuMTY3ODA3MjkyMS4wLjAuM
A..

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Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

members, this is unacceptable. More science is coming out highlighting the need for a
precautionary approach to offshore developments.17 In May of last year, a NOAA Scientist
submitted a letter to BOEM raising concerns about potential “population-level effects on an
already endangered and stressed species.”18 If a fishery participant was to propose a new methodof harvest, not only does the proponent have to show it will operate as intended; but also will nothave unacceptable impacts on protected species, bycatch species, habitats, and the marine
ecosystem. We must hold other new ocean uses to the same standards. On the west coast, werushed to build dams in support of hydroelectric power to answer energy goals. Now we areseeing the impacts of dams on our iconic salmon runs and the peoples dependent on salmon for
their livelihoods, recreational opportunities, cultures, and ceremonial purposes. It is almost
certain that California and Oregon commercial and recreational salmon fisheries will be greatly
curtailed, if not fully closed, this year due to declining Klamath and Sacramento River runs. It isbeyond dispute that failed water policies have exacerbated the drought and its impacts on thosesalmon runs. Later this year, we are likely to see the beginning of dam removal on the Klamath
River. There is increasing talk of additional dam removals to assist in the recovery ofanadromous fish stocks and restoration or important habitats.
Fisheries science is key to our operations and a necessity to support Goal 1. New ocean uses
have to be sited and designed to avoid impacts to NOAA’s marine surveys. These surveys, andresulting long-running datasets, are integral to our understanding of the marine environment(including impacts of climate change) and the foundation for stock assessments which are thecornerstones of our fisheries management processes. Disruptions to those surveys, or
long-running datasets, result in less certainty for stock assessments and other tools utilized insetting harvest guidelines for our fisheries. The MSA establishes a management framework for
U.S. fisheries based on the precautionary principle. As uncertainty in stock assessments
increases, harvest guidelines are reduced to account for that uncertainty.
GOAL 2: Increase sustainable U.S. aquaculture production
We look forward to public facing efforts intended to develop and identify gaps in aquaculturescience so it can be implemented and deployed in a manner that considers and avoids impacts on
marine life, protected resources, essential fish habitat, and marine ecosystems and mitigates for
those impacts which are unavoidable.
GOAL 3: Foster access to domestic and global markets for the U.S. seafood industry
Our reliance on imported seafood comes with a climate cost. We are fully supportive of any and17

A recent example is a study released in late 2022 which caution that offshore wind farms change marine
ecosystems. https://phys.org/news/2022-11-offshore-farms-marine-ecosystems.html

18

See May 13, 2022 letter from NOAAs’ Chief of Protected Species to BOEM’s Lead Biologist https://newbedfordlight.org/wp-content/uploads/2022/11/UR1-2023-000009_10_17_2022.pdf

6

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

all efforts which level the playing field for the U.S. seafood industry, including the recent
agreement reached at the United Nations addressing areas beyond national jurisdiction. There isa very real fear that vessels flagged under certain nations will disregard any Marine Protected
Areas established on the high seas, which in turn will impact U.S. fisheries.
GOAL 4: Strengthen the entire U.S. seafood sector
While the pandemic surely highlighted systemic challenges to industry; as noted above, it also
highlighted its resiliency, creativity, and ingenuity. The Draft Strategy specifically mentions
seafood infrastructure. There are significant concerns about that infrastructure in the face of new
ocean uses that will need space in our ports and harbors. A holistic approach to planning forthese new uses, both at sea and on land, needs to be prioritized.
Concluding remarks
RODA’s members provide an invaluable service to residents of the U.S. and the world. A
thriving and expanding domestic seafood economy, resilient to climate change and otherstressors, should be a top priority for this administration and all that follow. We must reduce ourreliance on seafood products harvested by nations with lower conservation and management
standards for their fisheries and a higher climate cost to get that seafood to the plates ofAmerica’s seafood consumers. As they Draft Strategy highlights:● Seafood is good for people;● Seafood is good for the economy; and● Seafood is good for the planet
Actions which could negatively impact the ability of U.S. fishermen and women to provide
seafood for our people, the economy, and for the planet, should be closely scrutinized. We verymuch appreciate the opportunity to comment on this important document. RODA and its
members are looking forward to working with NOAA Fisheries as it implements its National
Seafood Strategy.
Thank you for your consideration of these comments.
Sincerely,

Mike Conroy, West Coast Director

Lane Johnston, Programs Manager
Responsible Offshore Development Alliance7

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

See below for additional signatories.
Alan Alward
Co-ChairAlliance of Communities for Sustainable
Fisheries
California

David T. GoethelAngela Sanfilippo

Owner/Captain

Executive Director
President Gloucester Fishermen's Wives
Association
Massachusetts

New Hampshire

Owner/Manager
RiverCenter Marine LLC

Executive Director
Massachusetts Fishermen's Partnership
Massachusetts

CT, RI, NY, NJ, MA, VA, NC

President

Policy Manager
Commercial

F/V Anne Kathryn

Edward Barrett

Aubrey Ellertson Church
Fishermen's

Massachusetts

Massachusetts Fishermen's Partnership
Massachusetts
Eric Hansen
Owner

Beth Casoni

Hansen Scalloping Inc.

Director
Massachusetts Lobstermen's Association
Northeast Region

F/V Endeavor
F/V Intrepid
Massachusetts

Bonnie Brady

Erik Anderson

Executive Director
Long
IslandAssociation

F/V Ellen Diane

Dick Grachek

Angela Sanfilippo

Cape Cod
Alliance

David LeveilleManager
II Northeast Fishery Sector Inc
MassachusettsCommercial

Fishing

President
NH Commercial Fishermen's Association

New York

New Hampshire

Dave Aripotch
Owner
F/V Caitlin & Mairead
New York

Frederick J Mattera
Executive Director
East Farm Commercial Fisheries Center
Rhode Island
8

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Gerry O' Neill

Jon Silva

President/Director

President

Cape Seafoods Inc

F/V Jeanette Marrie

F/V Endeavour

OregonF/V Challenger
Massachusetts

Joseph J Myers

Glen H. Spain

SeniorDirector,
Sustainability

Executive Director

Sea Watch International, Ltd.

Pacific Coast Federation of Fishermen's
Associations

DE, MA, MD, ME, NJ, VA

Institute for Fisheries Resources

Joseph J. Gilbert

US West Coast

Owner/Operator

Innovation&

Empire Fisheries
Guy B Simmons

New England & Mid-Atlantic

Senior Vice President
Sea Watch International

Julie Lofstad

DE, MD, NJ, MA, ME

Owner
Sea Breeze Fisheries

Heather Mann

F/V Julie Rae

Executive Director

New York

Midwater Trawlers Cooperative
CA, OR, WA & AK

Katie Almeida

Jackie Odell

Sr. Representative, Government Relations& Sustainability

Executive Director

The Town Dock

Northeast Seafood Coalition

Rhode Island

New England
Kelley Retherford
James M Gutowski

Family owned and operated business owner

F/V Kathy Ann

F/V Winona J

Mid-Atlantic

F/V Mandy J
F/V Excalibur

John Haran

OregonManager
Northeast Fishery Sector XIIINortheast Fishery Sector X
MA, RI, CT, NJ

9Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Ken Bates

Matthew Gilley

President

Owner/Captain

California Fishermen’s Resiliency

F/V Catherine G

Association

Maine

California
Meghan Lapp
Larry Thevik

Fisheries Liaison

President

Seafreeze Ltd.

Washington Dungeness Crab Fishermen's
Association

Seafreeze Shoreside
Rhode Island

Washington
Mike Okoniewski
Lori Steele

Secretary

Executive Director

West Coast Pelagic Conservation GroupWest Coast Seafood Processors Association

North PacificOregonNatalie Webster
Lyndsey Pyrke-Fairchild

Director of Operations

Policy Analyst

Ocean Harvester Operative

Empire Fisheries

CA, OR, WA

Connecticut
Priscilla Wells
Mark E. DeCristoforo

Treasurer

Executive Director

Briarpatch Enterprises

Massachusetts Seafood Collaborative

Connecticut

Massachusetts
Rex LeachMark Fina

Owner

Executive Director

F/V Ms. Julie

California Wetfish Producers Association

F/V Texas Lady

California

OR, CA

Matthew Froelich

Samuel A Martin

Crew

Chief Operating Officer

F/V Liberty

Atlantic Capes Fisheries Inc

New York

MA, RI, NJ, MD, VA, NC

10

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Sarah Schumann

Timothy Froelich

Owner

Owner

Shining Sea Fisheries Consulting LLC

Miss Independence LLC

New England

F/V Independence II
New York

Scot Mackey
Executive Director

Timothy Thomas

Garden State Seafood Association

President

New Jersey

American Albacore Fishing Association
California

Shelly Jackson
Bookkeeper

Timothy Thomas

Cutting Fisheries

Owner

F/V Bernadette

F/V Steel Fin

F/V Stormie C

OregonF/V Cape Foulweather
OregonTodd Bragdon
Owner/Operator

Steve Scheiblauer

F/V Resilient

Owner

Massachusetts

Marine Alliances Consulting
California

Valerie Edwards
President/Owner
Oneonta Fisheries, Inc

Thomas Dameron
Government Relations
Science Liaison

andFisheries

Massachusetts

Surfside Foods, LLC

Vincent Doyle

Mid-Atlantic

Operator
F/V Verna JeanTim Novotny

CA, OR, WA

Executive Director
Oregon Dungeness Crab Commission

11

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

March 16, 2023
Ms. Janet Coit
Assistant Administrator
National Marine Fisheries Service (NOAA Fisheries)
National Oceanic & Atmospheric Administration
1315 East West Highway
Silver Spring, MD 20910
Re: National Saltwater Recreational Fisheries Policy
Dear Administrator Coit,
The Association of Fish and Wildlife Agencies (“Association”) is the professional organization that
represents the collective voice of the state fish and wildlife agencies, including the U.S. Virgin Islands
and the District of Columbia (“state agencies”). These agencies exercise primary statutory authority for
management of fish and wildlife as public trust resources within their borders and engage substantially inthe conservation of marine wildlife and habitats in partnership with the National Oceanic & Atmospheric
Administration (“NOAA”). We appreciate the opportunity to provide NOAA with the following
comments on NOAA’s National Seafood Strategy Draft.
Though the Association represents the collective voice of the 50 state fish and wildlife agencies andincludes Canadian provincial and territorial agencies in its membership, NOAA may receive comment
letters from individual member states. These are vital and important sources of input for NOAA toconsider as it proceeds with development of this strategy. This letter does not supersede or alter the views
or input of any state and should not be viewed as representing the perspective of any individual state,province, or territory.
We thank you for the opportunity to share our perspectives on the draft National Seafood Strategy(“Strategy”) as it relates to the conservation of coastal and marine resources and connected ecosystems. If
you have any questions about these comments, please contact Kurt Thiede at kthiede@fishwildlife.org or(202) 838-3468.
Sincerely,

Curt Melcher
President
1

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Association Comments on NOAA National Seafood Strategy
Consultation with State Fish and Wildlife Agencies
The Association supports a National Seafood Strategy that promotes collaboration between stateand federal agencies and industry, and that recognizes the distinct jurisdictions and authorities of
the agencies. As states exercise primary authority to manage coastal resources and are
responsible for the biosecurity of fish and wildlife species that rely on interconnectedecosystems, it is vital that state agencies are meaningfully consulted during the earliest possible
stage of any action related to implementation of the Strategy. It is likewise important that theStrategy remain appropriately broad to give regional administrators and Fisheries Management
Councils maximum flexibility in working with states and Marine Fisheries Commissions to
implement the Strategy according to geographic-specific needs and considerations.
The Association strongly recommends that explicit direction to consult with state agencies be
included in the Strategy. We appreciate NOAA’s commitment to partnering with “…state andother federal agencies… Tribes, non-government organizations…and other stakeholders” toimplement the Strategy. However, it is necessary to recognize that the rights, roles, andauthorities of states and tribes call for a higher degree of collaboration than the weight andconsideration given to the perspectives of non-managing partners. We encourage NOAA to
apply a high standard for government-to-government consultation that occurs prior to, andseparate from, solicitation for comment from general stakeholders.
Involving the states early and often is necessary for ensuring the agencies’ public trust
responsibilities are fulfilled and to facilitate the best available science to inform aquaculture
efforts. Science support and data are vital to improving management of coastal resources, and the
Association supports a Strategy that accounts for the effects of a changing climate and facilitates
increased focus on climate adaptation. Developing resilient, climate-smart policies requires
coordination and collaboration across all regions and partnerships and should therefore besupported in the national Strategy. It is crucial to provide resource managers with the necessary
data to respond to shifting habitats and the effects of increasingly frequent storms and dynamic
weather events across ecosystems.
Support monitoring and enforcement of state managed fisheries
State managed fisheries are a significant source of seafood for the nation, but tend to be underresourced from a monitoring and enforcement standpoint. Both monitoring and enforcement
become increasingly complex as climate change impacts the ranges of species targeted, as wellas those non-targeted species managers may be attempting to exclude in fisheries harvests.
Continued funding for cooperative agreements such as those for Dungeness crab and pink shrimp
is essential. Additionally, there is a lot of great work being done in federal fisheries to plan forclimate change and adopt an ecosystem-based management approach. We suggest that the1

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Strategy should support training and workforce development that enhances states’ capacity andexpertise to make state fisheries more climate resilient.
Invest in the future of the fishery by supporting young commercial fishermen
Commercial fisheries are a valuable part of the U.S. Blue Economy. Our fishing industry helps
ensure food security, provides jobs, and supports the well-being of coastal communities. But
today many U.S. commercial fishermen are on the cusp of retirement. This “graying of the fleet”
poses concerns for industry resilience and national food security if there are not enough young
fishermen willing and able to take their place.1 Reduced opportunity and increasing costs
associated with boats, equipment, and fishing infrastructure have made it hard for new fishermen
to get into the industry. We encourage a strategy that supports apprenticeship programs for new
fishermen and grant programs to help them purchase equipment, whether they are starting up,
shifting practices to adjust to new management regimes, or investing in equipment with a lower
carbon footprint.
Elevate voices of historically under-represented communities
As the seafood sector modernizes, we encourage state and federal partners to consider ways tohighlight historically under-represented communities. As fleets become increasingly diverse, it iseven more important that advisory committees, industry forums, and other groups reflect thatdiversity. We encourage NOAA to consider ways to highlight and increase the diversity in theseafood sector as it develops the Strategy.
Sustainability
One element of the vision for the National Seafood Strategy is that “US seafood continues to be
produced sustainably.” It is important to note that sustainability is dependent on adequate
funding for stock assessments. In addition to funding, additional consideration should be given to
the development of offshore wind and the disruption of long running systematic surveys if/when
offshore floating wind platforms conflict with those survey areas. The Association recommends
that the Strategy highlight the need for the increased funding and scientific expertise needed toadapt policies and management with additional ocean uses.
Support local seafood supply chain by marketing sustainable seafood
We also encourage NOAA to develop a strategy that can support state certification ofsustainability standards, as some states have begun exploring certification as a tool to boost
marketing efforts and establish a framework for best management practices where there may begaps in regulation. While price is an important factor for consumers when purchasing seafood,
local consumers are willing to pay a premium for local seafood because of the high quality andsustainability of the product. We recommend supporting location-based branding for regional

1 Building the Next Generation of U.S. Commercial Fishermen | NOAA Fisheries

2

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

seafood to help increase visibility in local markets, strengthen local supply chains, and promotesustainable fisheries.
Infrastructure to support direct sales and small businesses
We encourage NOAA to support infrastructure to support small-scale processing, direct sales,and dockside sales in coastal communities to help reduce overhead to small businesses andincrease accessibility to fresh local seafood. Such infrastructure may include filet stations inmarinas, commercial kitchens, or processing space to support growth of direct sales.
In closing, the Association appreciates the opportunity to comment on NOAA’s Draft National
Seafood Strategy and thanks NOAA for its consideration. We stand ready to assist the developmentof a national Strategy that fully respects the distinct roles and authorities of state and federal
agencies, empowers actions based on the best available science, enables resource managers tobetter serve the public and ensure resilient habitats for healthy, abundant populations, and supports
America’s seafood industry.

3

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Post Office Box 1229 / Sitka, Alaska 99835 /907.747.3400 / alfastaff@gmail.com

March 29, 2023
To: Ms. Janet Coit
Assistant Administrator, National Marine Fisheries Service
1314 East-West Highway
Silver Spring, MD 20910
Submitted electronicallyComments on NOAA’s National Seafood Strategy
Dear Assistant Administrator Coit,
I am submitting these comments on NOAA’s National Seafood Strategy. Thank you for taking astrategic look at the country’s seafood industry and inviting comment from tribes, stakeholders,
and the broader public. We deeply appreciate the work you and your agency are doing tomaintain sustainable fisheries in the face of increasing challenges.
The Alaska Longline Fishermen’s Association (ALFA) is an organization of independent small-scale
fishermen who promote sustainable fisheries and thriving fishing communities through research,
policy, and education. We are deeply committed to ocean health and the sustained access ofcommunity-based fishermen to local fisheries. Our work is guided by a firm commitment to triple
bottom line solutions that maintain or restore social, ecological, and economic health.
Climate Action
Our oceans are under siege from climate change, marine plastics, industrial pollution, and ocean
acidification. Likewise, our fishing communities are struggling to withstand the impacts of shifting
stocks, rising operational costs, and the impacts of industrial fisheries. NOAA must play an activerole in navigating the seafood industry through these troubled waters while also working at every
level to address the challenges. NOAA cannot be passive as fisheries collapse, nor can theagency be solely reactive to de facto dislocations or reallocations associated with climate change
or bycatch. As the highest priority in the seafood strategy, NOAA should commit to aggressive
climate action through national policy initiatives, decarbonization investments, and nature-based
climate solutions that maintain or enhance fish habitat while also building resilience into local
fisheries and fishery dependent communities. NOAA can and should play a lead role inadvocating for meaningful climate action while also championing fishermen friendly climate
solutions. Climate action that also promotes healthy fisheries is a win for the nation’s food security,
workforce, and economy.
Fishing Community Partnerships
In general, ALFA supports the broad strokes of this seafood strategy. NOAA’s stated purpose iswell-aligned with our own mission. Clearly NOAA plays a critical role in assessing fish stocks,

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

monitoring fisheries, and enforcing fishing regulations, all of which will only become more
important with climate change and ocean warming. Without reducing that importance, ALFA sees
room for improvement and growth within NOAA through deepened commitment to the Nation’s
fisheries and fishermen—in particular, to the small-scale fishermen who are the backbone of theindustry and the socioeconomic cornerstone of regional economies. As NOAA moves forward withcreating a seafood strategy for the times, we urge you to center small-scale fisheries and fishingcommunities in that process. NOAA’s seafood strategy should include genuine partnerships withthe fishing organizations that are working hard every day to sustain ocean health, maintainproductive fisheries and provide high quality protein to our nation. Working with community
partners across the country will allow NOAA to co-design strategies that are keyed to different
fisheries, scaled to meet local needs, and appropriate to each region. We are eager to work withNOAA to design these strategies.
Fishery Access
The rising cost of fishery access means small scale fishermen are struggling to remain viable
participants in local fisheries. Fishery trusts and community permit banks have worked to anchor
access in fishery dependent communities while also preventing overfishing. Providing capital andlow interest loans to fishery trusts and permit banks will support access for young fishermen,
fishermen of color, and others who are currently struggling to access permit and quota systems.
Enhanced attention and investment are also needed in our nation’s working waterfront
infrastructure and human resources. Coastal development that does not support the harvest ofseafood reduces our country’s food security. Many seaports have aging infrastructure and risingcompetition for waterfront property. Concerted investment is needed to reclaim waterfront
access and build forward facing services that propel the industry toward decarbonization, value
added seafood processing, and efficient/affordable services. ALFA members are eager toreduce our fleet’s carbon footprint, but we need resources that support energy transition, including
demonstration projects, alternative fuel delivery systems, and local businesses with the skills andcapacity to perform the work. Prioritizing this investment as part of the seafood strategy will
ensure our industry contributes to climate solutions, our domestic fisheries are at the forefront, andour coastal economies survive and thrive.
Finally, NOAA needs to change course on industrial fisheries and bycatch management. Federal
systems currently prioritize bycatch over historic directed harvesters, allowing a de facto
reallocation of valuable fish stocks to high bycatch users. This prioritization is destroying thecultural, social, and economic health of fishery dependent communities around the Nation and will,
ultimately, bankrupt fisheries. Changing course will require substantially improved socioeconomic
data collection, a rebalancing of National Standards, and a deeper commitment to social equity,
environmental justice, and regional food security. We urge NOAA to incorporate these changes
into the evolving seafood strategy.
Aquaculture
ALFA has a long-standing mistrust of finfish aquaculture born of extensive data documenting theimpacts on wild capture fish and fisheries. ALFA opposes federal investment in aquaculture thatcompetes or disadvantages an existing wild capture fishery. Any national aquaculture policy
must allow individual states to opt out of aquaculture, and prior to require an assessment ofpotential impacts to adjoining states from aquaculture development prior to permitting. We
recognize the potential benefits of mariculture and strongly recommend finfish aquaculture andmariculture be differentiated in national policy development.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

In closing, ALFA appreciates the NOAA’s decision to evaluate the nation’s seafood strategy andto solicit comment from tribes, stakeholders, and the public. We urge NOAA to center fishingcommunities and small-scale fishermen in an ongoing process to develop that strategy, and tofoster meaningful partnerships to inform forward facing policy development. Climate changedemands an active response from NOAA, and a response that builds resilience into our fisheries
and fishing communities. We urge NOAA to maintain its active role in the science of fisheries
management while building a stronger presence in advocating for healthy fisheries and thriving
fishing communities, fishermen friendly climate action, and meaningful investment in fisheries
access and working waterfronts. Finally, we oppose federal investment in finfish aquaculture thatcompetes with or negatively impacts wild capture fisheries and urge national policy that avoids
these downstream effects.
We look forward to working with NOAA to advance a seafood strategy that meets thechallenges of our times.
Sincerely,

Linda Behnken(Executive Director, ALFA)Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

March 31, 2023
Re: AWTA Comments on NOAA’s National Seafood Strategy
Dear Assistant Administrator Coit:
Thank you for recognizing the vital importance of a strong seafood industry to the United Statesand our coastal fishing communities. As commercial fishermen, and residents of Kodiak, Alaska
we appreciate this opportunity to comment on NOAA’s National Seafood Strategy (Strategy).
Members of Alaska Whitefish Trawlers Association live and work in Kodiak and have a vested
interest in maintaining and growing our industry, as well as Kodiak’s working waterfront. Kodiak
is a major commercial fishing port at a national level, ranking 3rd in Nation for pounds landed, but
is also a small and remote Alaskan coastal community with limited population and resources. We
appreciate this opportunity to provide input into a national strategy that will support our industry,and serve as a framework to further strategic partnerships between federal agencies to better
provide what we need to be successful. The framework outlined in the Strategy provides a helpful
structure to think about what is necessary to maintain and grow our seafood industry.
Alaska Whitefish Trawlers Association (AWTA) is a Kodiak-based trade association representing
about half of the independently-owned trawlers operating in the Gulf of Alaska. Most AWTA
vessels are on the small ender of trawlers, averaging 76 feet, and most of our owners, skippers andcrew living in Kodiak year-round. Trawl is a high-volume fishery, and the groundfish landed by
AWTA members is generally minimally processed in Kodiak, and then sent overseas for additional
value-added processing. The finished products are then often imported back into the U.S. and soldto U.S. consumers.
First, we appreciate NOAA’s emphasis on the importance of supporting a thriving domestic U.S.
seafood economy, and on enhancing resilience in both the seafood sector and in our coastal fishingcommunities. AWTA recognizes that bringing value-added processing back to the U.S. will
increase our food security, and allow that value to stay in the U.S. rather than being reaped byoperations in other countries. Keeping seafood harvesting and production local reduces the needfor complex shipping, and could allow our harvesting and processing operations to respond more
quickly to unexpected circumstances (e.g., COVID, or the conflict in Ukraine). Finally, fisheries
in the North Pacific have long been recognized as some of the most sustainable fisheries in theworld. At that same time our location on the globe has put us at the leading edge for climatechange impacts, which includes impacts on our fisheries stocks (hurting some and helping others).
Impacts from climate change are felt throughout Alaska and in our fisheries, however, this does
not negate our strong and sustainable fisheries management system. We believe that theeffectiveness of our science and management system served to mitigate even worse negative
impacts resulting from changes in our fisheries. We greatly appreciate the introductory commentsin the Strategy document highlighting that wild seafood in the U.S. is responsibly harvested, andPublic comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

one of the best sources of essential nutrients. The Alaska Seafood Marketing Institute has worked
hard on Alaska’s wild and sustainable seafood brand, and their market research shows how thatcharacteristic distinguishes us from many foreign competitors. AWTA encourages NOAA tohighlight to the American public that U.S. seafood is healthy and sustainable, and that we should
all support our domestic seafood industry by choosing U.S. seafood over competitors.
The following comments are organized by goal as listed in the Strategy.
Goal 1: Sustain or increase sustainable U.S. wild capture production
Fisheries Science. Our Alaskan fisheries rely on good science, particularly the core fishery surveys
that underpin stock assessments and our science-based management system. Ideally these surveys
should be conducted at least annually because survey gap years can mask pivotal changes in fishstock conditions. For example, in the Gulf of Alaska Pacific cod surveys generally occur every
other year, and the lack of survey in the off-year led to shocking results in 2018 when the cod Total
Allowable Catch (TAC) was reduced by 80%. Granted, an annual survey would probably not haveaverted the cod crash, but it would have provided more notice to managers, industry andcommunities and allowed them to better prepare for the ensuing losses. AWTA encourages NOAA
to consider what is considered “core” and whether core surveys need to be increased, including
Northern Bering Sea and Gulf of Alaska surveys. AWTA also support expanding fisheries scienceand research to better understand impacts of rapidly changing ecosystem dynamics, however, we
strongly believe expansion of other fisheries science cannot come at the cost of core fisheries
surveys.
Fisheries Management. AWTA strongly supports maximizing fishing opportunities while
ensuring the sustainability of fisheries through efficient and effective management, and supportingthe commercial fishing industry and fishing communities to adapt and thrive in the face of achanging ocean economy. As noted above we live on Kodiak Island, which means we rely on
marine transportation and marine shipping every day, and we rely on commercial fishingbusinesses to support our families. The last several years have driven home the importance ofbeing able to quickly adapt and pivot in the face of extreme and rapid changes, over which we hadno control, including supply chains, domestic and international markets, and ocean conditions. We
need effective fisheries management that can respond quickly to changes, allowing maximum
sustainable harvest today while continuing to ensure fisheries for tomorrow, in order to allow ourfishing businesses and coastal fishing communities to thrive.
Goal 3: Foster access to domestic and global markets for the U.S. seafood industry
Communication and Promotion. As noted above we believe there is tremendous opportunity tosing the praises of U.S. seafood, both domestically and internationally. Unfortunately, there arestill too many instances of negative comments about U.S. fisheries and fisheries management in
the media and social media. As a neutral party without a vested interest in any particularly geartype or fishing business NOAA is in a unique position to keep telling the story of sustainable andnutritious U.S. seafood. The truth is that if domestic seafood consumers don’t buy U.S. seafood,then they are going to buy products from somewhere else that are probably much less sustainable.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

U.S. Market Development. U.S. consumers eat far less seafood than is recommended by the
USDA, this means there is a huge market opportunity for domestic consumption. There is also ahuge opportunity to grow consumer awareness about U.S. seafood. For example, many people arefamiliar with the following national campaigns: “Got Milk?,” “The Incredible Edible Egg,” “BeefIt’s What’s For Dinner,” but would be hard-pressed to come up with similar catchy slogans related
to U.S. seafood. Fortunately, we have a mechanism to help marketing and promotions through theSaltonstall-Kennedy (SK) grant program, which was created for marketing and promotion of U.S.
seafood. The SK program currently uses a small fraction (3% in the current fiscal year) of funds
available for seafood marketing grants, and we hope the program can receive higher allocations in
the future to help fund national awareness and promotion campaigns.
Fair Trade. Most of groundfish harvested by AWTA members enters international trade, andcompetes in global markets, and we appreciate the recognition and attention to seafood fair tradeissues in the Strategy. We recommend that NOAA find a way to partner with the U.S. Trade Office(USTR), which does not have staff dedicated to seafood (which it does for textiles and agricultural
products). I was part of the United Fishermen of Alaska group that met with U.S. Trade
Ambassador Tai in June 2022, and was impressed with her genuine interest in Alaska seafood, andbelieve her office would benefit greatly from subject matter experts from NOAA who could help
support trade issues related to U.S. seafood.
At a high level the U.S. seafood industry often lacks policy recognition and support that is often
afforded to agriculture and facilitated by the USDA. This is felt in trade where tariff barriers in
key export markets continue to grow, including China and Japan where Phase One agreements
should have increased purchases and opened markets, and while the U.S. continues to allow dutyfree import of Russian-harvested pollock and crab (often processed in China). We encourage
partnerships between NOAA and the USTR as appropriate to address these disconnects.
Goal 4: Strengthen the entire U.S. seafood sector
Seafood Infrastructure. We greatly appreciate the focus on modernizing the seafood industry
infrastructure, including fleets and processing plants. Most AWTA vessels are over 30 years old,and U.S. Coast Guard regulations often make it cost-prohibitive to replace these vessels. Other
countries support vessel modernization, for example through government subsidies or grants
thereby increasing safety and efficiency of the fleet. Over time the cost to build a new commercial
fishing vessel has increased substantially due to new U.S. Coast Guard regulations, placing new
vessels out of reach for many fishing operations. We urge NOAA to explore ways to support
upgrading the fishing fleet, either through new builds or renovation, as part of the Strategy.
Kodiak’s shore-based processing plants are also old, including the external building structure, thedock structures, and the processing equipment inside. Modernizing our processing facilities would
increase efficiency, and create opportunities to bring value-added processing back to the U.S.
Investing in our own seafood industry would greatly benefit our coastal communities and working
waterfronts. Improving our capacity to process seafood in the U.S. would increase local andPublic comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

national food security and eliminate our reliance on international supply chains. Increasing
processing in Kodiak would leverage its unique position as probably the only location to run
processing operations on 99% renewable energy, thanks to Kodiak Electric Association’s
investments in hydroelectric and wind power.
Workforce Development. AWTA members are experiencing more challenges with finding crew
members, both because less young people want to become commercial fishermen and because
many potential crew members lack the necessary skills and training to safely work on a fishingboat. Other countries have fisheries schools that could provide a model for workforce developmentin our industry, including BIM National Fisheries College in Greencastle, Ireland. We support
workforce development and training for future fishmen, as well as for the shore-based trades
necessary to keep our fleets operational, including refrigeration, welding, hydraulics, etc.
We understand that NOAA Fisheries will prepare a more detailed implementation plan withspecific actions, timelines, partnerships, and milestones, and we would like an opportunity toreview and comment on that plan when it becomes available.
Sincerely,

Rebecca Skinner, Executive Director
Alaska Whitefish Trawlers Association
Enclosure
December 2, 2022 Comments on Senator Murkowski’s Working Waterfronts Plan

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

December 2, 2022
Senator Murkowski
522 Hart Senate Office Building
Washington, DC 20510
Fax: (202)-224-5301

Via: Working_Waterfronts@Murkowski.Senate.Gov

Re: Comments on Working Waterfronts Framework
Dear Senator Murkowski:
Thank you for recognizing the vital importance of healthy working waterfronts, particularly incoastal communities such as Kodiak, and we appreciate this opportunity to comment on yourWorking Waterfronts Framework. Members of Alaska Whitefish Trawlers Association live andwork in Kodiak and have a vested interest in maintaining and growing working waterfronts in ourcommunity. While Kodiak is a major commercial fishing port at a national level, it is still a small
and remote coastal community with limited population and resources to self-fund major waterfront
infrastructure and improvements. Your framework provides a helpful structure to think about what
projects are necessary to maintain a healthy working waterfront, and the results you receive will
clarify where federal funding, and your support, can help.
Alaska Whitefish Trawlers Association (AWTA) is a Kodiak-based trade association comprising
trawl catcher-vessels that operate primarily in the Gulf of Alaska (GOA), with some additional
participation in Bering Sea (BS) and West Coast groundfish fisheries. Most AWTA vessels are
smaller trawl vessels averaging 76 feet, with owners, skippers, and crew who live in Kodiak. The
following comments reflect that perspective of commercial fishermen who live in a small Alaskancoastal community and who depend on a viable working waterfront.
Domestic Seafood Production and Marketing. A high priority for the U.S., and Alaska, should
be increasing domestic production of value-add seafood products. Currently, most groundfish
landed in Kodiak is minimally processed at shore-based plants before being shipped overseas for
additional processing, then imported back into the U.S. As a result, other countries are reaping thebenefits of processing our seafood into more valuable end-consumer products, and selling it backto us. The last few years have taught us that we should be manufacturing food in the U.S. toincrease food security, and ensure that sustainably harvested U.S. seafood is what ends up on theplate of American households (rather than Russian-caught seafood, for example). Kodiak has the
3rd highest commercial fishery landings by volume in the country, runs on 99% renewable energy,
and should be home to value-add processing plants for seafood. Federal assistance to modernize
or build value-add seafood processing plants could lead to higher ex-vessel price for fishermen,
increase U.S. food security, and create American made seafood products that could go into USDA
purchases and thereby increase domestic consumption of domestic seafood.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

In addition to increasing domestic seafood production we could benefit from major U.S. campaigns
to promote seafood consumption by American households. Most of us are familiar with national
ad campaigns for beef (“beef, it’s what’s for dinner”), pork (“the other white meat”), milk (“gotmilk?”), eggs, (“the incredible edible egg”), and of course chicken (think Chick-fil-A/KFC and thecompetitive chicken sandwich market). Can you think of one catchy slogan from a national ad
campaign for fish or seafood? U.S. consumers do eat some seafood, but most of it is imported
from other countries. The seafood industry could use help raising awareness and educating
consumers about the healthy and sustainable protein available through Alaskan harvest, andencouraging domestic seafood consumption in general. We hope the recently created American
Fisheries Advisory Committee will help with this, and appreciate any support you can give during
the appropriations process to ensure funding for key areas in support of marketing.
Fishing Vessel Modernization Program. Alaskan fishing fleets would benefit from federal
subsidies supporting modernization, including revamping existing vessels as well as building new
ones. In addition, retrofitting fish holds and installing RSW could bring significant quality
improvements. This is a multifaceted issue which touches on vessel loadline, classification, USCG
regulations, and Jones Act requirements, and federal assistance would greatly improve the safety,
efficiency, quality and global competitiveness of our domestic fishing fleets.
Workforce Development. While many high-level issues confront the commercial fishingindustry (barriers to entry, increasing costs, global factors like climate change, pollution andgeopolitical turmoil), there are more basic challenges that need to be addressed. Vessel owners
lament that young crew often do not have critical skills necessary to safely and effectively workon deck, and that we lack adequate training opportunities to prepare them. Historically, young
people often learned commercial fishing from their relatives as they grew up; that is much lesscommon today 1. Fewer young people from fishing families choose the same path as their parents,
and those without fishing relatives lack an obvious training pathway. We need programs that teachconcrete skills 2, and focused training on the basics would significantly benefit both young people
seeking to enter the industry, as well as existing commercial fishing operations that are hurting forcapable crew members. We appreciate your continued advocacy for federal support and funding
to provide young or inexperienced people with the skills necessary for commercial fishing
operation, including gear-work, navigation, communications, electronics, and basic mechanics.
In addition to training future commercial fishermen we are seeing a need for more skilled
tradesman who support the fishing industry, including electricians, welders, specialists inhydraulics, electronics and refrigeration, and even individuals certified to repack life rafts. This
last example is a real challenge in Kodiak today as the company certified to repack Viking life
rafts closed due to retirements, necessitating shipping life rafts off-island. Unfortunately, we areseeing more and more support businesses closing, losing key staff, or operating under reduced
hours, which negatively impacts our working waterfront. While it is not clear whether federal
support would fix this problem it is having an impact and we appreciate your continued attention.
1

At the current Alaska Board of Fish meeting residents of Bristol Bay testified that young people (under 16) cannot
get fishing experience if they do not relatives who own a permit or boat.
2
Perhaps a fisheries training school similar to what they have in Ireland, see the BIM National Fisheries College,
Greencastle, IrelandPublic comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Harbor Infrastructure. As noted in your framework Kodiak’s harbor and waterfront
infrastructure needs do not align well with priorities identified in existing major federal funding
streams. We are too small to qualify for big projects, too big to qualify for small projects; andwhile Kodiak is the top 3 port for volume of fish landed (and shipped out) we do not cleanly fit
the transportation hub paradigm either. The commercial fishing industry needs functional andwell-maintained harbors, docks and shipyards, as well as adequate space to avoid conflicting uses
during certain times of the year (usually summer). Please see the attached AWTA suggestions for
Kodiak City’s Long Range Transportation Plan. We appreciate your continued efforts to identify
and procure federal funding for these vital (but sometimes small) infrastructure needs.
Implement Program similar to Crop-Insurance for Fisheries. Alaskan commercial fishermen
have experienced a number of federal fishery disasters in the last 7 years and the federal fisherydisaster program takes too long to provide financial relief. We would like to see a process that isfaster and more responsive, and pre-funded. To augment the federal fisheries disaster program wealso support exploration of a program similar to crop insurance to help mitigate risk for commercial
fishing businesses, or whichever policy-holders have paid into it.
If you have any questions, or want to discuss any of these items further, please do not hesitate toreach out.
Thank you,

Rebecca Skinner, Executive Director
Alaska Whitefish Trawlers Association

Enclosure
AWTA Comments on Kodiak City Long Range Transportation Plan

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

April 13, 2022

Jackie Wander
Bristol Engineering
Mike Tvenge
Kodiak City Manager
710 Mill Bay Road, Room 114
Kodiak, Alaska 99615

Sent via e-mail: jwander@bristol-companies.com

Sent via e-mail: mtvenge@city.kodiak.ak.us

Re: Comments on City of Kodiak Long Range Transportation Plan
Dear Jackie:
I am submitting these comments to the City of Kodiak’s Long Range Transportation Plan (LRTP) on behalfof Alaska Whitefish Trawlers Association. I chose to submit comments in letter format because ourpriorities focus on marine infrastructure and do not fit well into the structure and content of the online
survey. I also attended the public outreach session on March 9, 2022, and appreciated the presentation andopportunity for discussion during that session.
Alaska Whitefish Trawlers Association (AWTA) is a Kodiak-based commercial fishing trade association
comprising trawl and halibut longline catcher-vessels. Our membership comprises predominately familyowned vessels that fish primarily in the Gulf of Alaska and around the Kodiak Archipelago. Our trawl
vessels are on the smaller end of Alaskan trawl vessels, with an average length of 85 feet. Even at a smaller
size the Kodiak trawl fleet contributes 60-75% of all fish across Kodiak’s docks each year, and consistently
keeps Kodiak ranked within the top five ports in the nation by volume of fish landed 1. Trawl fisheries areopen 12 months a year, and trawl deliveries keep the processing plants open and running nearly year-round,providing consistent employment for plant employees, and ensuring markets are available for othercommercial fishing gear types throughout the year.
As you know Kodiak is a remote Alaskan coastal community located on a rugged island in the Gulf of
Alaska, and we rely on marine transportation to bring to the island groceries, consumer goods, andautomobiles, as well as to ship out commercial fisheries harvest. Our marine infrastructure is vital to theongoing success of the commercial fishing industry, as well as providing access to supply chains.
I have already highlighted many of the following priorities at Port and Harbor Advisory Board (PHAB)
meetings over the last six years. I am aware of the Waterfront Master Planning process currently underway,
and plan to participate in that process as well. I am concurrently submitting comments to the LRTP process
to ensure these marine infrastructure priorities are documented and reflected in any final City plans.

11

Fisheries of United States 2019 Report, NOAA Fisheries, May 2021;
https://www.fisheries.noaa.gov/resource/document/fisheries-united-states-2019-reportPublic comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

In reviewing the LRTP I note that it encompasses marine infrastructure, but the plan itself identifies few
specific projects related to ports and harbors. I have therefore included large and small projects, some ofwhich may fall into a short-term category, in the interest of taking a comprehensive approach. My rationaleis that including these items on a priority list, regardless of relative project size and anticipated completion
timeline, could best help the City identify and acquire funding for project implementation.
1. Address Electrolysis in Harbors. Trawl vessels primarily use St. Paul Harbor on Near Island, and vesselowners report damage and corrosion of steel hulls from electrolysis in the harbor. This type of damage tothe hull occurs below the waterline, and can result in holes that can only be repaired by divers or if thevessel is hauled out. In addition to the safety issue caused by compromising the integrity of the hull thisdamage costs tens of thousands of dollars to repair, and can also result in lost fishing time for vessels. I
understand that St. Herman Harbor also has electrolysis issues. I have raised this issue on behalf of AWTA
at PHAB meetings and to the City Manager directly.
2. Ensure All Harbors Are Repaired or Replaced as Necessary. Parts of Kodiak’s harbors are falling apartand are unusable, and need to be replaced. As a major commercial fishing port that consistently ranking
within the top five ports in the nation by volume of fish landed Kodiak needs to have fully functional andusable harbor infrastructure. There is already a shortage of stalls for larger vessels, with some vessels stillon the waiting list for a permanent berth. Unusable parts of the harbor include fingers in St. Paul Harbor(on the small boat end closest to the harbor building) that are twisted and partially sinking, rendering them
unusable. The “newer” M and N floats on the large boat end do not visually appear to be as damaged,
however M and N floats are in constant use by the trawl fleet and should be prioritized for replacement
before they deteriorate and also become unusable. In general, it should be a priority to ensure an electrical
distribution system that does not produce electrolysis, working sources of fresh water on each finger, and a
program for regular float maintenance.
3. Ensure Pier II (City Dock) Is In Good Repair. Pier II is heavily used by multiple user groups, includingcommercial fishermen to repair gear, dockage for cruise ships, Alaska Marine Highway ferry, and NOAA
research vessels, as well as a shipping terminal for APL. If pilings are corroded or compromised theyshould be prioritized for repair, and a maintenance plan implemented to extend the life of replacement
pilings as much as possible. As a centrally located, high-use dock area, we need it to be in good and usablecondition.
4. Construct Additional Dockspace at Shipyard. Adding a dock at the Shipyard would provide working
space for vessels that need repairs and shore power, but do not need to be hauled out. Currently, if a boat
is not hauled out then all repair tools and materials have to be carted down the ramp and out to the vessel’s
stall. A new dock in the Shipyard would facilitate access to the vessel, and be in a protected area awayfrom swells and boat wakes from boats. Creating a more protected area at Pier II and Pier III would require
constructing a new breakwater. If a new dock is constructed in the Shipyard consideration could also begiven to adding a crane to facilitate moving equipment between shore and vessel.
5. Ensure Adequate Dock for New AMHS Ferry. Based on AMHS design specs the new ferry will belonger than the Tustumena and may not be able to fit at the current ferry dock without impeding either theadjacent fuel dock or the Trident dock (fish processor). All of these services, the ferry, fish processing andmarine fuel, are important to Kodiak’s economy and any conflicts with space should be clearly identified
and resolved sooner rather than later. The longer design of the new ferry provides better seaworthiness,and it may be a better long-term solution to relocate the dock rather than advocate for a shorter ferry.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

6. Ensure Adequate Parking Near Harbors. Commercial fishermen and support services need places topark near vessel stalls, both long-term (while out on fishing trips) and short-term (stocking or providing
services to the boat). Currently there is a shortage of parking at the second ramp in St. Paul Harbor, which
is used almost exclusively by fishermen and harbor users. In addition, the road to the Shipyard is ruttedand full of potholes, despite constant grading, and should be paved. Fishermen have also complained abouta shortage of parking around St. Herman Harbor, which tends to share parking space with other businesses
in the downtown area.
7. Ensure Adequate Space For Gear Work. Commercial fishermen need dockspace to repair and work on
their gear, and Pier II is heavily used by multiple gear types for this purpose. In recent years competinguses for Pier II have made the dock unavailable at times for commercial fishing gear work; those competinguses include APL shipping, cruise ships, and ferry docking (Kennicott). There are two potential solutions
to reduce the conflicts at Pier II: (1) create a long narrow paved area along the water in the Shipyard wherenets can be stretched out and worked on, and (2) repair or replace Oscar’s Dock (condemned area) so thatit can once again be used to repair salmon seine nets. Oscar’s Dock frequently used by salmon seiners in
the past, before the middle area was fenced off. It is conveniently located in St. Herman Harbor, and now
has a crane to facilitate transferring gear from vessel to shore.
If you have any questions about any of the items listed above please to not hesitate to contact me.
Thank you,

Rebecca Skinner, Executive Director
Alaska Whitefish Trawlers Association

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

NOAA Fisheries

March 9, 2023

Submitted via google form:
https://docs.google.com/forms/d/e/1FAIpQLSeLVWJT1CwGLtoZ93Xw9c-tMsgNfzxuhK1JnOELaYegjpQnA/viewform
Re: NOAA Fisheries Draft National Seafood Strategy
To whom it may concern:
Cape Cod Commercial Fishermen’s Alliance submits the following comments in response to the
February 14, 2023 Notice by NOAA Fisheries inviting the public to provide information andrecommendations concerning NOAA Fisheries Draft National Seafood Strategy.
Cape Cod Commercial Fishermen’s Alliance is a member-based nonprofit organization that works tobuild lasting solutions to protect our ecosystem and the future of our fisheries. Fishermen’s Alliance
represents 150 fishing businesses and more than 300 fishing families, making our organization theleading voice for commercial fishermen of Cape Cod. We represent a diverse group of commercial
fishermen, seafood processors, and shoreside support businesses who depend on access tohealthy fish stocks and the marine environment. While the species we target, the gear we use, andvessel sizes may differ, we all firmly believe in robust federal investments to ensure we continue tobe both a global leader in ocean sustainability and provide consumers with sustainable local
seafood.
We support a National Strategy that focuses on supporting the entire U.S. seafood sector,
increasing U.S. wild capture production, supporting sustainable aquaculture production, andfostering access to domestic and global markets for the U.S. seafood industry. While we support thefour goals of the Draft National Seafood Strategy, we would like to provide recommendations on
specific actions, and partnerships that will ensure a thriving domestic U.S seafood economy, andresilience of the seafood sector in response to a changing climate and other stressors. Below arecomments regarding each goal:
1. Goal 1: Sustain or increase sustainable U.S. wild capture production.
We support building and maintaining strong partnerships with fishermen, regional councils, andresearch partners to ensure that wild-caught seafood is sustainable and managed appropriately.
We recommend that funding be available to support fisheries science, and collaborative fisheries
research projects. Adaptive fisheries management is important in the face of climate change and toprotect and restore habitats important to our nation’s fisheries to ensure resilient and sustainable
coastal communities. Efforts should also be made to increase oceanographic sampling along ourcoast using fishing vessels as a platform for research. Existing data coverage often lacks spatial
and temporal resolution to characterize key oceanographic processes in our region. By working

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

closely with the fishing industry, we can collect improved spatial and temporal coverage, andprovide data products that directly benefit fishing operations, marine resource management,
coastal research, climate change mitigation and the Blue Economy.
2. Goal 2: Increase sustainable U.S. aquaculture production.

Expansion of aquaculture should only be done in a way that reflects the values of the local
communities. We agree that aquaculture growth should be regionally appropriate and would
recommend that growth be locally appropriate. We would recommend the following guidelines for
how aquaculture is permitted:
1) Require communication among fishermen, local communities, and aquaculture startup
companies, so they can openly discuss options, identify shared values for the ocean and working
waterfronts, and create respectful relationships.
2) Aquaculture should collaborate with local fishermen to select mutually agreeable species andlocations for their farms. Farms should be a location that does not take away important fishinggrounds (or other culturally important areas). The species grown should complement and notcompete with wild harvest. Commercial and recreational fishermen should be allowed to fisharound the net pens, benefiting from the wild fish aggregations. There are other forms ofassistance to be considered as well: co-marketing for domestic seafood, shared shoreside
infrastructure, economies of scale for processing and distribution.
3) Mandate technology and farm designs that ensure aquaculture creates low to noenvironmental impact. This could be copper mesh that does not need chemicals to stay clean,controlled feeding to minimize food waste, using feed that is primarily waste from fish processing
and plant oils, subsurface nets to avoid storm damage and escaped fish, wild broodstock or
sterile babies so escaped fish won’t impact the wild population, plenty of space and water
circulation to keep fish healthy without antibiotics, and farm designs that prevent protected
species interactions.
4) Model, Monitor and Management: Complete pre-permit modeling and pilot studies on farmdesign to ensure the proposed farm site can absorb effluent and function as designed. It is crucial
to measure success or failure and shut it down if it is not functioning successfully. In addition, it isimportant to continue to monitor for environmental impacts, even after transitioning from pilot toa full-scale farm. Finally, practice responsible management with a commitment to values and arespect for the local community.
3. Goal 3: Foster access to domestic and global markets for the U.S. Seafood industry
Efforts need to be made on a federal level to identify and develop U.S seafood markets that provide
more local, and abundant seafood onto plates at universities, school systems, hospitals, and foodbanks. Education to consumers should focus on an approach that shrinks the geographicaldistance from port to plate and encourages individuals to choose a wide variety of seafood fromtheir local ecosystems, thereby supporting a reduced carbon footprint. When consumers eat adiversity of local seafood, they increase market demand for other non-traditional species fishermen
harvest, thereby supporting local fishermen and their communities. In addition, climate change isaltering our ecosystems, and as waters warm, fishermen encounter new species that are
traditionally found elsewhere. Therefore, we should encourage federal and state management andseafood markets to adapt to a changing ecosystem. Finally, it is important to form a relationshipwith the fishermen in your area, and know where your seafood comes from, and where it wascaught. When you buy local, you support the entire seafood supply chain that includes fishermen on
the water, seafood processors and dealers, and those in support businesses. Domestic seafood
has a lower carbon footprint than imported seafood, and there should be efforts to support amarket-based system that would create incentives for the seafood sector to reduce their emissions.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

4. Goal 4: Strengthen the entire U.S. seafood sector.

In 2020, our nation and commercial fishermen faced unprecedented challenges in the face of the
COVID-19 pandemic such as closures of local businesses, government stay-at-home orders, andinternational market disruptions. Retail sales of fresh and frozen seafood spiked as individuals
cooked more at home. In addition, many consumers if they were able to, and lived near the coast,
were able to go to the fishing docks and buy species such as lobsters and crabs off the boats.
Seafood is a vital part of the Blue Economy, and purchasing local seafood is the best way to ensurethat the seafood on our plates is both fresh, ecologically sustainable, and a socially responsible
choice. Recently, there have been efforts in place to support a program for low and zero emissions
technology in the commercial fishing industry through the Energy Efficient Fisheries (EEF) programin Massachusetts. This program, can allow commercial fishermen to save on their fuel bill, reduce
emissions, and develop ways to lower their carbon footprint.
Another way to strengthen the seafood sector is to make sure local communities protect andsupport infrastructure like fishing docks and waterfront access, so coastal communities can adapt
to new species that may migrate into our waters and invest in increasing seafood wastewater
processing capacity. Federal money needs to be allocated to invest in new emerging fisheries thatallow fishermen to diversify their harvester portfolio and decrease fishing pressure on species inrebuilding or low stock status. Finally, we need to address the “graying of the fleet” and attract
young fishermen and seafood farmers to the sector by fully funding and expanding the Young
Fishermen’s Development program. Currently, farmers and ranchers are eligible to participate inhundreds of workforce development programs compared to the seafood industry. The Young
Fishermen’s Development Act (YFDA) allows funds to provide training, education, outreach, andtechnical assistance to the U.S. seafood sector. Priorities of the Young Fishermen’s Development
Act are seamanship, navigation, vessel and engine care, innovative conservation, and fishing gearengineering, sustainable fishing practices, good business practices, direct marketing, andfinancial/risk management including vessel, permit and quota purchasing. At the Fishermen’s
Alliance we place emphasis on recruitment, training, and retention through a program that iscomprehensive of a diversity of local fisheries participants could work in, as well as rigorous safety
training. Our program’s mission is to ensure that those individuals who attend the program stay
local and find a future for themselves in the industry.
In conclusion, the fishing sector faces unique challenges that include complex fisheries
management, gear restrictions and area closures, uncertain markets, changing ocean conditions,rising expenses, availability of permits and allocations, and a lack of understanding by the public.
Despite these challenges, there are many opportunities to improve and grow this vital sector of ournation’s economy. Demand for local seafood is high and there is an important realization fromCOVID-19, that depending more on locally produced and harvested seafood is an important aspectof food security and a vital part of ensuring a sustainable Blue Economy. Cape Cod Commercial
Fishermen’s Alliance greatly appreciates the opportunity to provide these comments to NOAA. We
respectfully request that you take these comments into full consideration.
Sincerely,
Aubrey Ellertson Church
Policy Manager
Cape Cod Commercial Fishermen’s AlliancePublic comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

March 15, 2023
To: NOAA/NMFS
From: Southern Offshore Fishing Association, National Association of Charterboat Operators, Greg
Abrams Seafood, Tarpon Dock Seafood, Hunts Oyster Bar, and Capt Bob Zales Charters, llc.
Email:
Re: Draft National Seafood Strategy
On behalf of the group of diverse Associations and Seafood and Restaurant businesses, I appreciate theopportunity to comment on your draft National Seafood Strategy. As your narrative indicates, Fresh
American Seafood is paramount to a healthy citizenry and the multitude of small family seafood catchers,
producers, and processors who provide substantial social and economic impacts to the many coastal
fishing communities and the working waterfronts of the United States.
We have several suggestions to be seriously considered for the National Seafood Strategy. First, andforemost, is to ensure that the 8 Regional Fishery Management Councils are populated with equal
members of commercial, charter for hire, and private recreational members who have real world on thewater experience. While the coastal state marine resource agencies all have a seat on each regional
council, careful consideration must be given to their representation of environmental, commercial andrecreational directions. As all know, most state resource agencies depend on the economic impact ofrecreational fisheries which routinely outweigh the commercial fishery impact. This has and willcontinue to skew the management decisions by these state agencies resulting in limiting the commercial
fisheries.
Balance of council members is not just an equal number of commercial, charter for hire, and private
recreational membership. Balance must consider a reasonable number of academic/environmental
members that are also balanced with the state marine resource agencies. A clear example of a regional
council out of balance is the Gulf of Mexico Fishery Management Council. Currently, out of 17 members
there are 2 members listed as commercial but in reality on 1 is a true commercial representative as theother is a corporate land manager selling access to recreational anglers. While each member takes an oathto manage fisheries for the best benefit of the nation, the Gulf Council representation clearly sides withthe recreational sector disregarding the needs and impacts to the commercial fisheries and fishingcommunities of the Gulf Coast. BALANCE is ESSENTIAL to proper fishery management for the benefitof all users and consumers.
The Strategy should provide for maintaining and increasing the working waterfronts of our country. Thiscountry was founded on working waterfronts and they should be embraced, enhanced, and available to all.
All fishers, commercial, charter for hire, private recreational, must have access to our marine resources.
Commercial fishers, producers, and processors must have a place to offload their catch, process it, and beable to produce their products for consumers to be able to buy quality fresh American Seafood.
Consumers must have access to retail markets for their own use and also to be able to enjoy a fresh
seafood lunch or dinner in one of the many seafood restaurants across the country. As the working
waterfronts are steered away from our historical seafood processors, we lose the ability to provide
sustainable seafood to all.
For hire charter and private recreational fishers must have a stable and secure working waterfront in orderto have access to our marine resources for their enjoyment and personal use. Our marine resources arePublic comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

enjoyed and used by multiple thousands of fishers and others which contribute greatly to the social andeconomic well being of local fishing communities and the country.
U.S. Seafood production provide good clean, environmentally safe, and productive workers who
contribute to the overall economy. Proper fishery management must include, along with solid science,
local fisher on the water knowledge. The combination of fisher input of their historical real world
experience with the solid science will help to sustainably manage our resources and help stakeholders
better understand management. The inclusion of real world on the water knowledge helps to confirm or
not the virtual science of the stock status of fisheries so they can have confidence in the proposedmanagement.
Consumers and markets depend on a sustainable market. Managers must include the economics ofmarket supply when considering management actions. When a fishery faces drastic reduction of product,
the market can be lost. Once the fresh seafood market is gone foreign, and questionable health, markets
move in, and the fresh market is lost. Sustainable fisheries are must for steady markets to provide fresh,
safe seafood to all.
A critical issue for the Strategy is how NOAA/NMFS handles fishery disasters. As all know the U.S.
Department of Agriculture handles crop and animal disasters extremely well. In their budget they provide
for upfront funds to be available when a disaster occurs. Typically farmers receive funds and equipment
very quickly, generally less than a couple months, after a disaster which helps them to expedite theirrecovery and to be able to again produce goods for consumers. This helps to provide social and economic
help to their communities and the nation. In contrast, the Department of Commerce does not include
funds in their budget meaning that when a fishery disaster occurs, a disaster declaration must be made andthe Secretary of Commerce must approve it, then Congress must make an emergency appropriations
request for funding, then the DOC determines where the funds will be used.
Historically and continued today, when a fishery disaster, such as Hurricane Ian, occurs it can take up to 4
years before any disaster funds reach the fishermen. This causes some to leave their fishery never toreturn and creates a void in American seafood production. In addition, consumers lose the ability to enjoy
fresh seafood and the trickle down impact causes seafood dealers, processors, restaurants, and othersupporting businesses to suffer negatively affecting their community. The DOC must modify theirfishery disaster process to better provide to those affected by the loss of their vessels, waterfront access,and other issues negatively affecting them.
The strategy should also include clear direction of on and offshore aquaculture operations. Due tonaturally occurring storms and other natural issues, many offshore locations for aquaculture are notappropriate. While some profess to be able to drop offshore cages to the bottom or provide othersafeguards to operations in the face of serious storms such as hurricanes, the reality is there is no safe
place. All you have to do is look at the recent hurricane Ian and the complete and total destruction it
caused to southwest Florida. The storm surge I not limited to high water on land, but also creates mushdamage to the seafloor as you can see from the multiple yards of bottom sand washed up on the city
lands. Storms powerful enough to topple offshore drilling platforms and destroy underwater pipelines
will certainly destroy any cage holding genetically altered fish. The locations of aquaculture operations
must be carefully considered before operations can begin.
This concludes our comments. Again, we appreciate this opportunity to comment and hope oursuggestions are seriously considered.
Thank you,

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Capt Bob Zales, IIPublic comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

March 31, 2023
Dr. Michael Rubino
Senior Advisor for Seafood Strategy
NOAA Fisheries
1315 East-West Highway
Silver Spring, MD 20910
Re: Request for Public Input on the NOAA Fisheries Draft National Seafood Strategy
Dear Dr. Rubino:We, the undersigned organizations, are writing to provide comments on the draft National Seafood
Strategy (‘the Strategy’) released by NOAA Fisheries in early 2023. We are supportive of the effort tocreate strategies around key challenges, including climate change, market disruption, and new ocean
uses, that NOAA Fisheries must address to fulfill its stewardship mission. Sustainably managed fisheries
provide valuable benefits to the nation, including an important source of seafood, livelihood, economic
support for coastal communities, and the opportunity for recreational and cultural practice.
We offer some recommendations for the agency as it finalizes the Strategy and begins developing animplementation plan. We recommend that NOAA Fisheries add greater consideration of climate change
in the Strategy and its goals, strengthen the commitment to sustainability, ensure that equity is being
considered both in the Strategy and the process of its development, and draw links to other strategies
and policies that are completed or in development.
1. Improve the consideration of climate change in the Strategy and its goals and include NOAA
Fisheries’ role in transitioning to climate-ready fishery management.
Climate change is one of the most serious threats to fish and fisheries, and it is already affecting the
productivity and distribution of fish stocks and altering fishing. Climate change will affect every part ofthe management process—from data collection and assessment to setting of management measures. It
will also have wide-ranging impacts on the seafood sector. Climate-driven changes to fish stocks andmarine ecosystems will require NOAA Fisheries adopt climate-ready management approaches that
improve resilience of fish stocks and fisheries, help fishermen adapt, and address the impacts of sea
level rise and storms on coastal infrastructure important to the seafood industry.
Under that Goal 1, the stated role of NOAA Fisheries with respect to climate is to “Support thecommercial fishing industry and fishing communities in their efforts to adapt to climate change andthrive in a changing ocean economy.” Supporting community adaptation efforts is valuable, and we aresupportive of the agency engaging more with communities to help them prepare and plan for climate
impacts. However, the language does not reflect the much broader responsibility of NOAA Fisheries and
its Council partners to maintain the health of trust resources in the context of climate change. This
stewardship responsibility will require that the agency improve and adapt its management to prepare
the system for climate change. Climate-ready management prioritizes sustainability, resilience, andequity to support healthy marine ecosystems and preserves the ocean’s long-term ability to provide
food and support businesses, recreation, and culture. Without substantive changes to the management
system, fishing community adaptations are likely to be insufficient to address the climate challenge infisheries. NOAA Fisheries can advance its climate-ready management by making climate a priority for1

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

policy development and action and by giving the Councils greater guidance and technical assistance as
they integrate climate considerations into fishery management plans and other processes.
We appreciate that the impact of climate has been substantially expanded in the introductory sectionsof the Strategy relative to the previous draft released in January 2022, but we think there are ways tofurther carry it through the goals and ultimately the actions of the Strategy. For example, climate should
be reflected in all the goals, not just Goal 1, which focuses on wild capture fisheries. Climate change has
clear impacts on aquaculture planning, siting, and operations, and we note that both fisheries andaquaculture were included in EO 14008. 1 For Goal 4, resilience to climate change should be part of theconsiderations around the blue economy and seafood infrastructure.
2. Recommit to sustainability as a core management goal, especially in recognition of recent
concerning trends in stock status.
The U.S. has among the largest fisheries in the world and has been a leader in sustainability. However,the percentage of stocks that are overfished has risen each year since 2017, and progress on overfishinghas stalled. From coast to coast, there are concerning examples where stock health has declined andwhere actions taken by managers run counter to those that would promote sustainable fishing.
Sustainable management under the Magnuson-Stevens Act remains a key component for the long-term
health of fish stocks, marine ecosystems, and the delivery of the benefits they offer. NOAA Fisheries
must recognize the existing sustainability challenges that fisheries are currently experiencing andaddress them in the Strategy. Fundamentally, the best way to provide stability and growth opportunities
to the wild capture seafood sector is through rebuilding and maintaining healthy, resilient fish
populations. But the Strategy is entirely silent on the lost fishing opportunities due to long-term failures
to rebuild stocks. Combined with the challenges facing fish stocks due to climate change, the Strategy
comprehensively fails to commit to robust, enhanced actions to restore and then keep stocks healthy.
In this context, it is notable that the goals around wild capture fisheries and aquaculture are framed interms of maintaining or increasing sustainable production. This is far different from the goal to“optimize sustainable production” that was included in the January 2022 draft of the Strategy and which
recognizes that fulfilling the agency’s statutory responsibilities may not always result in increased oreven sustained production. To achieve the vision in the Strategy, it is imperative that NOAA Fisheries
fully commits to sustainable management and uses sustainability as a benchmark with which to assess
its priorities and actions. Increases in production should not come at the cost of sustainability or
jeopardize stock and ecosystem health, and it may not be possible to increase production in many cases
given the multitude of challenges fisheries face, including climate change. In addition, the objective to“maximize fishing opportunities” in Goal 1 may not always be aligned with sustainable management. In
the implementation plan, the agency should consider tradeoffs and interactions among the various goals
and objectives of the Strategy.
3. Ensure that the agency engages underserved communities in the development of the plan andtheir needs and vision are reflected in the final Strategy and implementation plan.
Many communities, including underserved communities, are part of and engage with the seafood sector
in various ways, and the Strategy should reflect their diverse needs and visions for fisheries and seafood.
1

NOAA Fisheries, Recommendations for More Resilient Fisheries and Protected Resources Due to Climate Change,
86 Fed. Reg. 12410 (March 3, 2021).

2

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Implementation of Strategy, and initiatives taken as a result, should prioritize active engagement withaffected communities. This should include a concerted effort to engage with underserved communities
to build equity in the delivery of the benefits of a resilient seafood sector. The agency must also work
collaboratively and engage in meaningful consultation with Tribes.
In addition, the Strategy does not explicitly address equity and how it is a part of the goals and bulleted
objectives. For example, the draft mentions food sovereignty, subsistence fishing, and traditional Tribal
fishing rights, but there are no additional details provided for how the Strategy will address these topics,
which are often in conflict with “maximizing” fishing opportunity, or how they fit under the goals. As
another example, the Strategy uses the term “seafood communities,” but it does not define this term.
To achieve the vision for a thriving and resilient seafood sector, NOAA Fisheries must ensure that its
actions reflect equity and environmental justice principles and that underserved communities havemeaningful engagement throughout decision-making processes.
As NOAA Fisheries implements the Strategy, its actions should be inclusive and ensure that benefits that
result from implementation are equitably distributed. To do to this, the agency could consider adding
specific objectives related to equity and establishing metrics with which to assess performance. For
instance, Goal 1 is silent on the need to consider tradeoffs between direct catch and bycatch acrossfisheries; simply “maximizing” fishing opportunity could result in exacerbating equity issues between
Tribes, subsistence users, local communities, and large industrial fleets. At a minimum, the Strategy andimplementation plan should consider the equity implications of the different goals, such as how toensure aquaculture production does not disproportionately impact underserved communities, whether
the development of U.S. seafood markets may benefit some groups more than others, how to support
the sustained participation of dependent communities, how to help ensure equitable access to seafood,and how to increase representation in fishery management and make the process more inclusive.
4. Establish the link between the Strategy and other key NOAA Fisheries policy documents andensure these efforts are not implemented in isolation.
During the listening sessions, it was mentioned that the Seafood Strategy is part of a broader set ofstrategies being developed, including on climate change, equity and environmental justice, international
affairs (including IUU fishing), and protected resources and habitat. These separate strategies (forexample, the Seafood Strategy and the Equity and Environmental Justice Strategy) should be aligned andwork together. Fisheries are social-ecological systems, and management must be done in a way that
acknowledges the links between different parts of the system. For example, healthy habitats andecosystems and equitable and climate-ready management practices are important components for a
thriving seafood sector. It should also be clear how the Strategy interfaces with other important NOAA
Fisheries policies and strategies, such as the NOAA Fisheries Strategic Plan, the Climate Science Strategy
and the Ecosystem-Based Fishery Management (EBFM) Policy and Road Map.
Thank you for the opportunity to provide comments on the draft National Seafood Strategy and forconsideration of our recommendations.
Sincerely,
Meredith Moore
Director, Fish Conservation Program
Ocean Conservancy

Molly Masterton
Director, U.S. Fisheries
Natural Resources Defense Council
3

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Katie Cubina
Senior Vice President for Mission Programs
Mystic Aquarium

Carrie Lewis
President and CEO
Oregon Coast Aquarium

Nora Nickum
Senior Ocean Policy Manager
Seattle Aquarium

Alan Varsik
Director
Point Defiance Zoo & Aquarium

4

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

The following comment is submitted on behalf of the Aquatic Life Institute, a leadinginternational not-for-profit organization, dedicated to improving the lives of aquatic animals
exploited in the global food system. For the past 3 years, we have been supporting global andcountry-level governments (including the FAO, UK and Canada) as they introduced welfare
considerations for farmed and wild aquatic animals.
We appreciate the many efforts of NOAA to fulfill its mission to spur sustainable seafood
production and are grateful for the opportunity to share with you some recommendations onaquatic animal welfare that we hope your administration may find relevant. We believe that
improved aquatic animal welfare, which encompasses appropriate stocking density, responsible
feeding practices, and good fish health, can have auxiliary benefits of making the seafood
sector more resilient to the urgent threat of climate change.
The following are recommendations for Goals 1 - 4.
GOAL 1: Sustain or increase sustainable U.S. wild capture production
We’d like to point out that while fisheries management systems have improved, 90% of global
fisheries are still fully exploited, overexploited or depleted (FAO 2022). For mostly economic
reasons, current fishing practices are centered around maximizing the efficiency (‘catch per unit
effort’; CPUE) of commercial fishing operations and minimizing the time spent at sea required tofulfill the fishing vessel’s catch quota. This has to change for several reasons.
First, the process of capture in such CPUE-based operations inflicts significant stress, sufferingand mortality upon both target and non-target aquatic animals. This means that more aquatic
animals die as a result of the capture process than is necessary, which impacts marine
ecosystems and removes carbon storage actors from the sea.
Marine animals play a crucial role in carbon sequestration in the ocean, with UNEP introducing
the term "fish carbon" to recognize their potential in mitigating climate change and preserving
biodiversity. From whales providing necessary nutrients to phytoplankton, which absorb carbon,
to fish and other marine animals depositing stored carbon in fecal pellets on the ocean floor,
animals play a significant role in maintaining the ocean's capacity as a carbon sink.
The type of welfare issues experienced in capture fisheries includes exhaustion from trying toevade capture, injury through overcrowding in nets and exposure to rapid changes in bodytemperature and atmospheric pressure which in turn lead to thermal shock and barometrictrauma. Upon landing, they are further exposed to sunlight and air, and are then handled and‘processed’ in a cost-efficient manner that pays little heed to the animals’ welfare. Further,wild-caught individuals typically suffer a fate of death by asphyxiation (suffocation in air) or are
frozen to death in ice water (so-called ‘ice slurry’). To put the scale of this suffering into
perspective, an estimated two to three trillion aquatic animals are caught at sea on an annual
basis, 35 times more than the number of land animals killed for food.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Such inhumane practices would be unimaginable in almost all other food production sectors andparticularly, in terrestrial animal farming. Given the attention that these other sectors alreadyplace on the health and welfare of the animals they raise — including in the aquaculture sector— it is time for the same standard to be applied to their wild-caught counterparts.
We recommend NOAA to adopt an animal welfare-based approach (WBA) to capture fisheries.
The animal welfare-based approach (WBA) to fisheries management we propose iscentered around the following principles:
1. Refining the methods used to capture and retrieve aquatic animals;
2. Improving the ways in which captured animals are handled on-board;
3. Implementing effective stunning and slaughter of captured animals; and,4. Eliminating the indirect adverse welfare impacts on non-target species.
A WBA gives equal weighting to both the welfare of target animals and the welfare of otheranimals indirectly affected by fishing activities, such as those caught incidentally (so-called‘bycatch’) and those ensnared in abandoned fishing gear (so-called ‘ghost fishing'). Under
standard fisheries management regimes, such issues are typically disregarded or grouped
under ‘conservation categories’ that are rarely resolved. However, under an animal welfare
approach, the key ‘parameter’ is welfare. There is ample scientific consensus that aquatic
animals have the capacity to suffer in the same way as terrestrial animals. Given that thisrecognition is enshrined in law5 throughout the world, we have both a legal and moral obligation
to apply the same standards of welfare to wild-caught aquatic animals.
One example of humane capture fisheries best practices in the US comes from Bristol Bay
Native Corporation, which owns F/V Blue North, a longline vessel operating in the Northwest
Pacific for cod. This vessel was retrofitted with animal welfare in mind, including:●●●

Fish are individually hooked and retrieved within an hour.
Uses a 'Moon Pool' to set lines and haul catch one by one inside the vessel.
Onboard electrical stunning and once frozen fillet.

According to the company, the benefits associated with humane capture are the following:● Shorter fishing time reduces stress and injury to target species.
● Reduced likelihood of catching non-target species.
● ‘Moon Pool’ improves crew safety by minimizing exposure to the elements.
● Stunning + once frozen fillet commands a higher price per pound than traditional
non-humane harvest, once frozen or twice frozen fillet.
Second, the issue of abandoned, lost and otherwise discarded fishing gear (so-called ‘ghost
gear’) can lead to significant suffering of aquatic animals. Moreover, ghost gear often results inthe accumulation of marine debris on the sea bed and has been reported as the “deadliest formof plastic debris to marine life.” This is costly to the industry as well since an estimated 90
percent of species caught in ghost gear are of commercial value. We urge NOAA to prioritizePublic comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

the commercial adoption by industry of durable gear components that incorporate
biodegradable elements.
Third, commercial fishing is directly related to climate change through emissions from fishingvessels, direct disturbance to ocean sediments, and loss of carbon sequestration capacity due
to the removal of aquatic animals. Bottom trawling, a significant contributor to overfishing, is aparticularly harmful method that releases significant amounts of carbon that would otherwise be
stored in the seabed. It also causes ocean acidification and reduces the ocean’s ability to store
CO2. At the ecosystem level, it can displace entire benthic communities through habitat
destruction.
Already in other parts of the world, certain fishing vessels are being built as hybrid vessels. For
example, shipbuilding company Ulstein designed a factory trawler, ECOFIVE, which won the2022 Innovation Award at Nor-Fishing. This vessel was created to leave a far lower
environmental footprint, produce higher fish quality and provide a safer working environment.
The vessel has a hybrid fuel-efficient propulsion system with two propellers, combining batteries
with diesel-electric and diesel-mechanical propulsion. The vessel also built in an in-waterelectrical pump stunner (by Ace Aquatec) so that fish are pumped into the vessel while being
stunned along the way for humane slaughter. The fishing vessel is expected to be delivered at
the beginning of 2024. Similarly, NOAA should encourage research and the development of
more efficient fishing vessels.
GOAL 2: Increase sustainable U.S. aquaculture production
In order to support gradual, diverse, and regionally-appropriate growth of the domestic
aquaculture industry that depends on an efficient, strategic, and science-based regulatory
approach to consider and mitigate impacts on protected resources, essential fish habitat, andmarine ecosystems, we must first come to the realization that improved animal welfare practices
result in positive outcomes for all areas of interest being discussed in this strategy development.
Excess or insufficient feed in aquaculture leads to compromised water quality, aquatic pollution,
and attracts wildlife. Combined with inappropriately high stocking densities, this creates toxic
wastewater in and around fish farms. Left untreated, it can deplete surrounding waters ofoxygen, causing algal blooms / dead zones, and public health issues. Additionally, instances of
escape made possible by infrastructure failures during extreme weather-related events
potentially caused by the severe effects of climate change for example, only further ecosystem
destruction by instigating increased competition for resources between farmed organisms andwild populations. This disruption would displace native species, leading to deleterious
consequences related to regional biodiversity.
The majority of aquaculture is still heavily reliant on marine ingredients (fishmeal and fish oil) asa primary component of aquafeed. Reducing the amount of wild fish required for aquaculture
feed is directly linked to climate change. One capture method often utilized by the “reduction
fisheries” industry is bottom trawling, which produces a significant amount of carbon emissions,Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

as mentioned above. Aquaculture will be increasingly affected by climate change in many ways,
through increasing ocean acidity, dissolved oxygen, and temperature, as well as more intenseand unpredictable weather events. Decreased use of “reduction fisheries” for aquafeed would
also alleviate pressure on wild stocks, promote ecosystem health, and balance the multifacetedmarine trophic system. These “reduction fish” could also be redirected to direct humanconsumption for coastal communities in the United States and abroad that will face direct issuesof food security as the global population continues to grow.
Poor welfare practices result in disease outbreaks, as evidenced in many areas of global
aquaculture as well as terrestrial agriculture, are caused by compromised immune systems due
to poor health, nutrition, and rearing conditions. Weakened immune systems increase thepossibility of disease outbreaks which is problematic as pathogens and parasites can spreadoutside of the farm, damaging local fish populations and ecosystems. Antibiotics are frequently
used to prevent or treat bacterial infections, however, unregulated usage has caused major
concern for antimicrobial resistance. Poor welfare increases the need for antimicrobials to treat
viruses, parasites and pathogens. Antibiotic overuse, and ultimately antibiotic resistance, inaquaculture remains a significant concern in terms of animal welfare, environmental impacts,
and public health. However, it is one that can be addressed through the dissemination of
information amongst farmers, local policymakers, and international regulatory bodies regarding
the link between increased animal welfare and industry improvements. When aquatic animal
welfare is placed at the forefront of production practices, we encounter healthier animals.
Healthy animals display a decreased reliance on prophylactic antibiotics, and an increased
tolerance to farming stressors which enables an elevated resilience to disease. Adopting
positive animal welfare protocols such as ensuring optimal water quality, refraining fromexcessive stocking densities, and implementing humane stunning and slaughter methods canhelp curb the misuse of antibiotics in aquaculture.
The Aquatic Life Institute has been highly involved with the Food and Agriculture Organizationof the United Nations by contributing to their revision of the Guidelines for Sustainable
Aquaculture as well as the Shanghai Declaration (2021), a high-level global policy paper androad map to optimize the role that aquaculture can play in achieving the 2030 Agenda for
Sustainable Development. We highlighted the importance of animal welfare in aquaculture at
the Global Conference on Aquaculture Millennium + 20 (GCA +20). The GCA +20 is organized
every 10 years by the FAO, a major conference to establish a consensus among policy-makers
around the world on aquaculture development priorities. This year, a key output was thecreation of the Shanghai Declaration. Whereas the early draft included only one reference toaquatic animal welfare as it relates to biosecurity and disease prevention:“Promoting aquatic biosecurity protocols and management agreements, including
prevention of disease and integrated disease and pest management, and encourage
measures to improve fish health and welfare.”
The final draft added an entirely new clause on aquatic animal welfare based on our feedback:Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Final version: “Recognizing that developing aquaculture sustainably and equitably
requires a holistic approach that values both human and animal health and welfare andfurther recognizing that aquaculture activities should be conducted in a manner thatassures the health and welfare of farmed aquatic animals, by optimizing health throughminimizing stress, reducing aquatic animal disease risks and maintaining a healthy
culture environment at all phases of the production cycle.”
In the final draft, the Shanghai Declaration made it clear that aquaculture needs to be developedin a manner that is not detrimental to planetary, human and animal health:“At the same time, to feed an ever-growing human population, expected to reach almost
10 billion people by 2050, aquaculture development needs to continue its expansion
while becoming more sustainable. Recognizing that the capacity of aquaculture forfurther growth, and also the need to avoid that such growth comes at the cost ofdeteriorating ecosystem health, animal welfare standards, biodiversity loss, or
social inequalities, the aquaculture sector demands new, sustainable, andequitable development strategies. The private sector will remain the main actor inaquaculture production, and substantial public sector support and strong leadership will
also be necessary with input and guidance from government and civil society playing
essential roles in regulating aquaculture, and in supporting and promoting citizens’
views, participation and Benefits.”
In order for NOAA to ensure that “ the U.S. seafood continues to be produced sustainably”, asimilar approach prioritizing animal welfare must be explicitly considered in all strategies moving
forward.

GOAL 3: Foster access to domestic and global markets for the U.S. seafood industry
We urge NOAA to communicate about the importance of the following to the seafood industry
and become a global leader:
1. The need for aquatic animal welfare indicators & adequate training: Training in careful
capture, handling and slaughter techniques should be mandatory for all personnel
involved in fishing activities. Such training should cover how to consider the welfare of
the animal when selecting fishing gear, how to carefully remove hooks and how to limit
suffocation in air before slaughter. Training should also cover the consideration of
welfare for indirectly affected species (e.g.,turtle resuscitation). It should bedemonstrated how careful handling is also in the benefit of crew safety.
2. Monitoring, control and surveillance (MCS) to incorporate the treatment of animals: Oneof the biggest challenges to sustainable and humane capture fisheries is monitoring andenforcing fishing activities out at sea, including accurate record-keeping of catch data.
There must be an urgent and concerted effort for improved fisheries management, suchas mandating technology or other methods on board for continuous monitoring andenforcement. Such measures can help address concerns around animal and humanPublic comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

rights abuses on board as well as overfishing. This would also help combat illegal,
unregulated and unreported (IUU) fishing and limit bycatch. Recommendations tostrengthen MCS and improve animal welfare include:○ Electronically monitoring and recording injuries in captured animals in addition
to catch, gear and bycatch data at the time of processing (phase out the use ofmanual logbooks);○ Installing on-board cameras capable of live streaming (in addition to humanobservers);○ Enacting policies to mandate MCS in commercial fisheries to protect bothanimals and fishers; and,○ All governments and regional fisheries management organizations (RFMOs)
should cooperate closely in harmonizing data collection and sharing.
3. Transparency and traceability: The seafood supply chain is one of the most complex in
the world, rife with widespread cases of fraud and mislabelling. In order for fisheries tobe truly sustainable and to support efforts at improving animal welfare, we recommend
the following:○ Markets and consumers should demand transparency and traceability of allaquatic animal products, including data on humane capture and stunning. This
will allow them to make informed decisions in rejecting products derived throughinhumane practices.
○ Retailers should amend their sourcing policies to require, for example, supplierdata on animal welfare training for fishers, catch data, and robust electronicmonitoring onboard.
○ Independent audits should be carried out across the value chain to ensurecompliance with corporate responsible sourcing policies.

GOAL 4: Strengthen the entire U.S. seafood sector
We strongly recommend integrating aquatic animal welfare parameters into NOAA’s fisheries
and aquaculture development strategies. While aquatic animal welfare is not protected legally
under US law, as sentient beings they should be treated with respect similar to land-based
animals cultivated for food. This includes adopting animal welfare strategies in both aquaculture
and fisheries. For detailed welfare recommendations, please see here for aquaculture and here
for capture fisheries.
We would like to thank NOAA for the opportunity to comment. We hope our comment provides
insightful feedback and we look forward to showing how data-driven and science-based animal
welfare policy can facilitate the seafood sector's resilience in response to short- and long-termclimate-driven threats. Please contact giulia@ali.fish for more information.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Comments on NOAA Fisheries National Seafood Strategy, March 31, 2023
Shark Advocates International, a project of The Ocean Foundation, appreciates theopportunity to comment on the National Oceanic and Atmospheric Administration(NOAA) National Seafood Strategy. We support the objectives associated with
science-based sustainability and modernized supply chains. We are, however,concerned that the document:•

lacks mention of the importance of applying a precautionary approach infisheries management;•

paints an overly positive picture of the current U.S. marine fisheries situation with respect toresponsible fishing practices; and•fails to recognize significant existing inadequacies (with respect to habitat protection, rebuilding
plans, data collection, and illegal trade) that threaten not only species and ecosystems but U.S.
fisheries over the long-term.

The statement “Harvested responsibly, as it is in the United States, seafood is also an environmentallyfriendly way to produce a nutritious food” ignores significant problems in U.S. fisheries. For example:•

Shrimp trawl fisheries off Southwest Florida represent the most lethal threat to Endangered
smalltooth sawfish and yet are subject to extremely low observer coverage (1-2%);•

Biomass of New England thorny skates is at only 3.6% of the 2028 target and yet managers haverepeatedly rejected proposals to close areas (to protect the species from fisheries impacts); and•The common thresher shark is valued by both commercial and recreational fisheries along the U.S.
Atlantic coast but has never been subject to a population assessment.

Accordingly, under Goal 1, with respect to sustaining or increasing sustainable U.S. wild capture production,
we support the agency’s intention to ensure the:•••development of the scientific analyses necessary for fisheries management, as a priority;
sustainability of fisheries through effective and efficient management; andprotection and restoration of key fisheries habitats.

Under Goal 3, regarding market communications and promotion, we urge NOAA to:•provide the public with a more well-rounded picture of seafood sustainability by revising the
FishWatch website to cover risks and concerns about conservation status, rebuilding timeframes,and plan implementation for seriously overfished species (e.g., Atlantic shortfin mako sharks); and•enhance efforts to combat IUU fishing and related harmful fishing practices around the world byexpanding the identification of countries under the High Seas Driftnet Moratorium Protection Act.

Under Goal 4, regarding strengthening the U.S. seafood sector, we support work across federal agencies tomodernize U.S. seafood infrastructure, but we recommend that associated priorities include expanding therequirements and capacity needed to improve species-specific fisheries data collection and increase
observer coverage.
Amendments along these lines will help balance the strategy. We appreciate the consideration of our views.
c/o The Ocean Foundation · 1320 19th Street, NW, Fifth Floor · Washington, DC 20036

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

March 31, 2023
Ms. Janet Coit
Assistant Administrator
National Marine Fisheries Service
National Oceanographic and Atmospheric Administration
United States Department of Commerce
1315 East-West Highway
Silver Spring, MD 20910
Submitted Via Webform and Electronic Mail Submission:
nmfs.seafoodstrategy@noaa.gov

Dear Assistant Administrator Coit:
The National Fisheries Institute (“NFI”) welcomes the opportunity to submit comments
on NOAA’s draft National Seafood Strategy (“Strategy”) and its future Implementation
Plan (“Plan”).
NFI is the principal trade association for the nation’s commercial seafood supply chain,
and as such represents harvesters, processors, exporters, importers, aquaculture,
distributors, cold storage providers, retailers, and seafood restaurants. Collectively, thesecompanies supply American families and consumers around the world with tens of
millions of premium, sustainable seafood meals every year. According to NOAA, thesecompanies, as part of the nation’s commercial seafood industry, directly support 1.2
million American workers, and annually contribute $67.6 billion in value-added impacts
nationwide. 1
NFI appreciates the Strategy’s emphasis on the importance of a thriving domestic U.S.
seafood sector. Seafood is indeed “good for people,” “good for the economy,” and “goodfor the planet.”
Before addressing each of the Strategy’s goals, it is important to remember that seafood
is one of the most under-consumed foods in American diets. Nearly all Americans acrossall ages – 90 percent on average – have seafood intakes below recommended amounts.
NOAA Fisheries, Fisheries Economics of the United States 2019,” Silver Spring, Maryland: NOAA
Fisheries, 2022 https://media.fisheries.noaa.gov/2022-07/FEUS-2019-final-v3_0.pdf.

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Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

The 2020 Dietary Guidelines for Americans (“DGAs”), recommend that children andadults eat seafood 2-3 times weekly for a range of benefits, including heart and brain
health, strong bones, and improved muscle mass. Any Administration strategy involving
seafood must take account of the indispensable nutritional benefits that seafood – andsometimes only seafood – offers.
Goal 1:

Sustain or increase sustainable U.S. wild capture production via
fisheries science, and fisheries management.

Overall NMFS management of U.S. fisheries, and the Magnuson-Stevens FisheryConservation and Management Act (“MSA”) framework that undergirds that work, is
excellent. The MSA system applies fundamental national standards to specific fisheries,
in light of science and with due consideration of the views of essential stakeholders. The
MSA framework relies for its success on regional fishery management councils, soundscience, adaptive management, and public participation. The system works because itbalances regional autonomy with science, and emphasizes transparency and fairness forall stakeholders. The undeniable result? The vast majority of American fisheries are
sustainably fished.
Unfortunately, recent attempts to go around MSA to implement extraneous policy
measures threaten the successful path NMFS has carved out. For instance, rather thanrecognizing that seafood sustainability under this framework augments ocean
conservation efforts, some seek to wall off large swaths of the U.S. EEZ fromcommercial fishing. These proposals, especially when carried out without public input,
undercut confidence in U.S. fishery management, weakening NOAA’s position as a
global fishery management leader and sowing uncertainty in industry as to the reliabilityof access to domestic fisheries. With due respect, NFI submits that these proposals
would have less currency if the agency more effectively communicated the success of
U.S. fishery management to key U.S. and overseas industry, NGO, and government
players. NFI appreciates NOAA leadership in fishery management – and urges theagency to do more to advertise the manifest fruits of that leadership.
Goal 2:

Increase sustainable U.S. Aquaculture production via regulatory
efficiency and aquaculture science.

NFI has long supported increased domestic aquaculture production, and NOAA is right toemphasize practical steps to incentivize such production. More than half of the seafood
Americans eat each year is farmed. Given that aquaculture continues to be fastest
growing form of food production in the world, that percentage is poised to increase.
Farmed and wild-capture products are both essential if seafood is to play a role in feedinga growing global population. Yet the U.S. lags behind, ranking 16th globally inaquaculture production. Although multiple factors contribute to this performance, thenation’s complex and burdensome regulatory framework is a primary culprit.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

NFI therefore applauds NOAA’s stated goal to advance an efficient, predictable, timely,and science-based aquaculture regulatory framework that reduces red tape and increases
transparency and predictability. Such a framework is essential in order to increase
investor confidence and drive customer interest in the development of a mature U.S.
farmed seafood sector. In its Plan, NOAA should clearly establish how the agency will
work with other regulators, industry, and additional stakeholders to meet this objective.
Goal 3:

Foster access to domestic and global markets for the U.S. seafoodindustry via communication, promotion, market development,
and fair trade.

Seafood is the most globally traded protein. This fact creates opportunities, but it also
makes seafood vulnerable to trade policy challenges and trade facilitation disruptions.
The entire seafood value chain relies on global trade—this is just a fact. American
consumers and workers benefit from the diversity of seafood sources and supply chainsin order to meet growing customer demand for year-round supply of a multitude of
product forms.
Three specific objectives should be top of mind with respect to this goal.
First, the agency and the Administration as a whole must work to correct the loss ofcompetitive access to overseas markets for U.S. seafood exporters. Recent bilateralagreements with Korea and Japan excluded seafood, the ongoing bilateral dispute with
China has cost U.S. harvesters dearly in what used to be their largest overseas market,
and efforts to eliminate nontariff barriers in other markets either have stalled or arenonexistent.
Second, and as discussed above, NOAA Fisheries should more aggressively promote its
fishery management system and the sustainability outcomes thereof, not only to
Americans, but to other markets as well. The Plan should include specific actions for
NOAA Fisheries to help bolster confidence in U.S. seafood, especially by promoting its
FishWatch as the program for consumers, overseas buyers, and others to know that U.S.
seafood is sustainable.
Third, NFI supports the agency emphasis on addressing illegal, unreported, andunregulated (“IUU”) fishing. NFI and its member companies have a decades-long recordof support for actions that meaningfully address the challenge of illegal fishing. The
agency should focus on practical steps – such as devoting additional resources to agency
development of the biennial IUU fishing report – that will lead to reduced IUU harvests.
Expanding the agency’s seafood import monitoring program is not one of them. As NFI
has long argued, the program has not proven to be effective at combatting IUU, is not infact risk-based, and imposes costly regulatory burdens that exacerbate the food inflation
now harming lower- and middle-income American families.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Goal 4:

Strengthen the entire U.S. seafood sector via the Blu e Economy,
Seafood Infrastructure, and Workforce development

NFI certainly supports the goal of strengthening the seafood sector. The details of thisgoal, however, matter. In both the Strategy and Plan, NOAA must identify specificpolicies intended to strengthen U.S. seafood producers and the agency budgetarycommitments necessary to make such policies real.
In doing so, of course, the agency and the Administration also must “do no harm” to asector that in recent years has been buffeted by pandemic, lockdowns, inflation, andsupply chain ruptures. For instance, the United States cannot support wild capture
fisheries and develop a strong open ocean aquaculture industry while simultaneously
planting offshore wind farms that disrupt, or even block access to, fishing grounds. If theStrategy is to provide a genuine roadmap for “strengthening the entire U.S. seafood
sector via the Blue Economy,” then NOAA must agree to ensure that offshore winddevelopment hampers neither existing wild capture fisheries nor blocks access to federalwaters where aquaculture development is likely to occur.
It is also important to understand that the nation’s seafood sector includes more than justharvesters. The seafood supply chain includes processors, cold storage providers,
wholesalers, distributors, retailers, and seafood restaurants. These companies rely on amix of domestic and globally-sourced product to meet still-growing consumer demand
and to keep their workers busy. Indeed, according to NOAA data, over 500,000 U.S.
jobs rely on globally-sourced finfish and shellfish. Thus, in addition to ensuring a
reliable, transparent trading system, the Administration can support U.S. industry by, forinstance: improving U.S. port facilities; expanding interagency cooperation to reduce
regulatory overlap; and rolling back duplicative regulation. That is to say nothing ofsteps – such as assisting with vessel modernization – that do pertain to the harvest link in
the chain. These and steps like them will be critically important if the agency is to meetthis goal.
NFI applauds the work of NOAA and NMFS on this Strategy and looks forward to theupcoming Plan, and appreciates the opportunity to share these views.
Sincerely,

Lisa Wallenda Picard
President and CEO

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

April 24, 2023
Dr. Michael Rubino
NOAA Fisheries
1315 East West Hwy, Bldg. SSMC3
Silver Spring, MD 20910-3282
Dear Dr. Rubino:
Thank you for your recent presentation to the Mid-Atlantic Fishery Management Council regarding
NOAA’s Draft National Seafood Strategy. We appreciate that the strategy recognizes the role of the
U.S. seafood industry in meeting domestic nutritional needs, and we strongly support the agency’s
efforts to develop U.S. seafood markets and “put more U.S. seafood back on U.S. plates.”
As you move forward with development of an implementation plan, we encourage you to explore
opportunities to align the National Seafood Strategy with the Biden Administration’s National Strategy
on Hunger, Nutrition, and Health. The strategy, which calls for a whole-of-government approach toend hunger and increase healthy eating and physical activity by 2030, is organized around five pillars:
•
•
•
•
•

Improving food access and affordability
Integrating nutrition and health.
Empowering all consumers to make and have access to healthy choices.
Supporting physical activity for all.
Enhancing nutrition and food security research.

The Council believes that U.S. seafood should be an integral component of national efforts to address
hunger and nutrition. As you are aware, U.S. seafood is a highly nutritious and sustainable food sourcethat provides numerous health benefits. Unfortunately, consumption in the United States remains low,with only 1 in 5 Americans consuming the recommended amount of seafood each week. Additionally,
more than 70% of seafood consumed in the U.S. is imported from other countries, and about half of
our wild catch is exported to overseas markets.
There is a clear alignment between the goals of the National Seafood Strategy and the National
Strategy on Hunger, Nutrition, and Health. We recommend that NOAA work closely with its federal
partners, including the USDA and FDA, to develop specific, actionable strategies to increase thepresence of U.S. seafood in federal health and nutrition programs, increase consumption of U.S.
seafood, and promote awareness of the benefits of seafood consumption. The Council offers thefollowing suggestions for your consideration:•

Collaborate with the USDA to increase the use of U.S. seafood in federal nutrition assistanceprograms, including the National School Lunch ProgramPublic comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

•••

Strengthen interagency cooperation to simplify and streamline supply chains, thereby
increasing traceability and promoting a more direct relationship between harvesters andconsumers
Continue to develop messaging in a variety of formats to educate consumers on the healthbenefits of seafood, the sustainability of U.S. fisheries, how to access seafood affordably, how
to prepare and store seafood safely, etc.
Collaborate with industry and non-profit organizations to expand the utilization of U.S. seafood
via food assistance programs (e.g., food banks)

Thank you for your consideration of these comments. We welcome the opportunity to provide further
input on future implementation plans.

Sincerely,

Christopher M. Moore, Ph.D.
Executive Director

3/31/23, 9:27 AM

National Oceanic and Atmospheric Administration Mail - ntl seafood strategy comments
Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

ntl seafood strategy comments
Thu, Mar 30, 2023 at 7:20 PM

I represent the members of the Southern Offshore Fishing Association, the Gulf of Mexico Commercial Grouper
Fishermen, National Association of Charterboat Operators, the Voice of the For Hire Charter Boat Owners and Operators
across the country, and the Panama City Boatmen Association, For Hire Charter Boat Owners and Operators from Bay
County, FL.

I have sent comments previously but wish to add more here. We strongly feel that no National Seafood Strategy can be
successful without first ensuring fair and equal representation to have balance on all 8 regional councils. Membership on
the councils must include a balance of all sectors, commercial, for hire charter, and private recreational. These sectors
include the multitude of professional on the water fishers who understand their regions, their fisheries, and the needs toproperly manage them. Members selected for each sector must be active participants in their sector with experience toprovide input to the management of their species.

The MSA requires a fair and balanced membership on the councils, and this must be strictly adhered to. Currently, theGulf of Mexico has 1 true commercial member and 6 private recreational members, mostly of the same recreational
association. The total membership is 17 so anyone can clearly see this council is out of balance and the recent
management decisions clearly show the commercial sector in the GOM is being disadvantaged.

All sectors use our marine resources. All sectors provide benefits to the nation in their own way. Consumers in ourcountry depend on a properly managed resource for fresh American Seafood whether catching their own or purchasingfrom markets and restaurants. Much like farmers of the land, commercial fishermen farm the sea and fair and balanced
management is a must to be able to provide fresh American Seafood.

Fair and balanced council membership must be a priority in the National Seafood Strategy!!!

Thanks,Capt Bob Zales, IIFishery Management Consultant, SOFA
President, NACO
President, PCBA

Capt Bob Zales, II

www.fishpc.com
https://mail.google.com/mail/u/2/?ik=a594a012f0&view=pt&search=all&permmsgid=msg-f:1761848056634108574&simpl=msg-f:1761848056634108574

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3/31/23, 9:27 AM

National Oceanic and Atmospheric Administration Mail - Seafood strategy
Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Seafood strategy
Charlie Bergmann

Thu, Mar 30, 2023 at 7:58 PM

I think before any seafood strategy commences all regional fishery management councils must be balanced as requiredby the MSFCA and to pursue the making of state directors on the eight councils non-voting members.

https://mail.google.com/mail/u/2/?ik=a594a012f0&view=pt&search=all&permmsgid=msg-f:1761850501395527626&simpl=msg-f:1761850501395527626

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3/3/23, 12:22 PM

National Oceanic and Atmospheric Administration Mail - Input
Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Input
Fri, Mar 3, 2023 at 11:33 AM
Thank you for the chance to comment on your seafood strategy. I’ve been involved in the seafood industry for 40 years on
both sides of the hoist. I’ve seen the good and bad, the smart and stupid parts of the business and management. If you
want a thriving commercial fishing industry you have to open up access to the resource for the producers. We need tomake meeting the maximum sustainable yield a top priority. We need to make sure that access is spread fairly between
small, medium and large producers. In California we have to have minimum river flows for the salmon. They get the water
first. We need to de-list humpback whales using the best available Science—not political optics— and we need toacknowledge that the ground fishery is rebuilt and get it open to the open access fleet as there won’t be a salmon season
this year. This is the access that NOAA needs to quickly make happen. Once fisherman can fish abundant stocks at theright market times of the year the industry will thrive. Thanks,
Larry Collins, Senior Consultant
San Francisco Crab Boat Owners Association

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Groundfish
PublicForumcomments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.
4241 21st Avenue West, Suite 302
Seattle, WA 98199(206) 213-5270 • Fax (206) 213-5272
www.groundfishforum.org

March 30, 2023
Re: Comments on NOAA’s Dra9 Na:onal Seafood Strategy
Dear Assistant Administrator Coit,
Thank you for this opportunity to comment on NOAA’s Dra9 Na:onal Seafood Strategy (NSS).
Groundﬁsh Forum (GFF) is a Washington-based trade associa:on whose ﬁve member companies operate
17 trawl catcher-processor vessels in federally managed ﬁsheries of the Bering Sea, Aleu:an Islands(BSAI) and Gulf of Alaska (GOA). In 2022 our ﬂeet of vessels, collec:vely known as the Amendment 80(A80) sector and their 2,200 crew members sustainably harvested over 335,000 metric tons of various
ﬂaXish, Atka mackerel, Paciﬁc ocean perch, Paciﬁc cod and various rockﬁsh from these waters with an
es:mated value of $400M. This ﬁshing ac:vity creates year-round family wage jobs for our hard-working
crew members and their families and provide direct beneﬁts to 65 western Alaska communi:es under
the Community Development Quota (CDQ) program. In addi:on, our ﬁshery creates thousands ofmari:me support sector jobs in Alaska and Washington State in the ports where we operate. Thesemari:me support sector jobs represent a vast network of shipyards and repair facili:es in the Puget
Sound region, stevedores and labor unions to conduct oﬄoads in Alaska, fuel and provision suppliers,
mari:me vendors and ﬁshery observers.
Goal 1: Sustain or Increase Sustainable U.S. Wild Capture Produc:onFisheries Science: Robust and well-funded stock assessments and surveys con:nue to be the bedrock foreﬀec:ve ﬁsheries management in the BSAI and GOA. However, while exis:ng core surveys must
con:nue, NOAA must recognize that in the face of climate change, expanding surveys or increasing thefrequency of “core surveys” is an absolute necessity to eﬀec:vely monitor rapid environmental changes
in these regions. GFF fully supports expanding ﬁsheries science and research and accompanying budgets
to beger understand rapidly changing climate dynamics in ﬁsh and shellﬁsh popula:ons. NOAA must be
bold in its expansion of cri:cal surveys, ﬁsheries science, and research. Without an expansion of theseessen:al founda:onal ac:vi:es, sustaining our wild capture ﬁsheries is at risk.
Fisheries Management: We support NOAA’s goal to sustainably maximize ﬁshing opportunity andseafood produc:on and would speciﬁcally note that Bering Sea ﬂaXish stocks are generally underu:lized. Over the last ﬁve years, actual harvest of ﬂaXish allocated to the A80 sector is less than 50% of
allowable biological catch. NOAA stock assessments generally indicate that ﬂaXish are at lower risk to benega:vely impacted by climate change. If NOAA is truly seeking to increase wild capture of U.S. ﬁshstocks, making management decisions which allow for increased harvest of BSAI ﬂaXish stock is lowhanging fruit.
Habitat Conserva:on: GFF supports habitat conserva:on measures when backed by peer reviewed
science. It is important to note that management measures already established by the North Paciﬁc
Fishery Management Council and NOAA prohibit ﬁshing by the A80 sector within large swaths of the
BSAI; collec:vely these areas total hundreds of thousands of square miles.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Figure 1: Areas Closed to FlaXish Trawling in the Bering Sea and Aleu:an Islands.
Such permanent ﬁxed closure areas are likely to be less eﬀec:ve in the face of climate change as ﬁshstocks migrate and habitat needs for key species change. If NOAA is to be eﬀec:ve in building climate
resilient ﬁsheries, NOAA must reconsider its historic approach to habitat protec:ons and invest in
research to determine if there are beger ways to conserve habitat and ﬁsh popula:ons through dynamic
closures.
Goal 3: Foster Access to Domes:c and Global Markets for the U.S. Seafood Industry
Communica:ons and Promo:on: GFF strongly supports increasing domes:c awareness of seafoodsustainably harvested in U.S. ﬁsheries by U.S. vessels and crew. One area where addi:onal
communica:ons and promo:on is greatly needed is in combakng dis-informa:on regarding seafood
harvested in Alaska. Films such as “Seaspiracy” and websites which are dedicated to promo:ng misinforma:on about commercial ﬁshing nega:vely impact the public’s percep:on of Alaska seafood.
Addi:onal local and regional eﬀorts by NOAA are needed in Alaska to beger promote and educate thepublic regarding sustainable seafood harvests.
U.S. Market Development: Our sector sustainably produces approximately 680,000,000 seafood meals
annually for consumers across the globe. As such, GFF fully supports NOAA’s eﬀorts to put more U.S.
harvested seafood back on U.S. plates. NOAA and federal partner agencies should consider crea:ng
processes and programs to address barriers which prevent cost-eﬀec:ve secondary processing of U.S.
harvested ﬁsh on U.S. soil. Pilot programs, technology grants, and other means should be considered toPublic comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

promote U.S. secondary processing with a focus on developing U.S. harvested ﬁsh products which appeal
to U.S. consumer’s desires.
Fair Trade: GFF appreciates NOAA’s focus on IUU ﬁshing and related harmful ﬁshing prac:ces. However,this narrow view of trade is not suﬃciently broad for the NSS document and needs to be expanded.
Speciﬁcally, NOAA (though the Department of Commerce), needs to provide exper:se to the UnitedStates Trade Representa:ve (USTR) to address major concerns of domes:c producers of U.S. seafoods in
Alaska who con:nue to struggle against tariﬀ policies which are greatly harming U.S. seafood companies
and crew members. GFF is strongly opposed to the con:nued imposi:on of Sec:on 301 tariﬀs uponvarious soles and ﬂounders which are caught in U.S. waters by U.S. ﬂagged vessels. These tariﬀs have
had an extremely nega:ve impact upon the Alaska ﬂaXish sector, U.S. ﬁshing crews, Alaskan andWashington State communi:es where we operate, and U.S. consumers.
Goal 4: Strengthen the En:re U.S. Seafood Sector
Seafood Infrastructure: As noted in the previous sec:on, developing management strategies which
promote modernizing U.S. processing capability both on shore and at sea should be a top priority of
NOAA. Groundﬁsh Forum member companies have been a domes:c leader building new, state-of-theart catcher processors – since 2017 member companies within our sector have invested well over $250M
in new vessels. New vessels reduce the carbon footprint of our ﬁshery, provide for a safe working
plaXorm by incorpora:ng the most modern safety construc:on standards for our crews, and allow ourvessel to carry out addi:onal value-added processing which allows our ﬂeet to compete in a highly
compe::ve interna:onal marketplace. With the cost of an individual new A80 catcher processor
approaching $80 - 100M, NOAA must recognize that building new vessels requires ﬁshery management
measures which both promote regulatory stability and predictability.
We appreciate NOAA’s desire to keep our ﬁshing industry sector thriving through strategies that promoterobust and sound scien:ﬁc management of ﬁsh stocks and habitat; maximize domes:c marke:ng andconsump:on of U.S. harvested seafood through fair trade prac:ces; and ensure future growth andprosperity by adop:ng management policies which promote stability, and ra:onally balance compe:ng
needs.
Thank you for this opportunity to comment,

Chris Woodley
Execu:ve Director, Groundﬁsh ForumPublic comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

March 16, 2023

To whom it may concern, NOAA Office of Communications
By Email: nmfs.seafoodstrategy@noaa.gov
Re: Comments on Draft National Seafood Strategy
Thank you for the opportunity to review and comment on the Draft National Seafood
Strategy which, overall, is welcome and timely. I am writing in behalf of our family owned
and operated, vertically integrated seafood company, Lund’s Fisheries, established in Cape
May, New Jersey in 1954. Like many multi-generational fishing businesses in our community,
I represent the third generation and have been actively working at Lund’s Fisheries in sales,
production, and management roles since 1994.
Lund’s Fisheries currently employs 150 people annually, between our Cape May andBridgeton, New Jersey locations, and another 80-90 fishermen on our fleet of fishing vessels.
We also work with many independent fishermen who also rely upon us to purchase theirharvest and, together, develop domestic and export markets for local seafood products asthey become available.
National Strategy on Hunger
In September of 2022 President Biden announced a goal of ending hunger and increasing
healthy eating and physical activity by 2030 so fewer Americans experience diet-relateddiseases— while reducing related health disparities. To advance the President’s goal—andbuild on the federal government’s existing work to address hunger and diet-relateddiseases—this strategy identifies ambitious and achievable actions the Biden-Harris
Administration will pursue across five pillars:1) Improving food access and affordability2) Integrating nutrition and health3) Empowering all consumers to make and have access to healthy choices4) Supporting physical activity for all5) Enhancing nutrition and food security research
The Agency should see this initiative as naturally compatible with the Draft Seafood Strategy
and should integrate US domestic seafood production into to this process.

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Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Our comments, in bold italics, follow the outline of the draft strategy document

PurposeThe National Seafood Strategy, outlines our direction for supporting a thriving domestic U.S.
seafood economy and enhancing the resilience of the seafood sector in the face of climatechange and other stressors.
In our view, the seafood sector is naturally resilient and has been for at least 300 years; we
do not attribute climate change to be a significant challenge to the sector’s future
resiliency. In fact, the USDA Climate Change Resource Center identifies climate change as
cyclical in nature and not to be considered a “Stressor”:“Cyclical variations in the Earth’s climate occur at multiple time scales, from years to decades,
centuries, and millennia. Cycles at each scale are caused by a variety of physical mechanisms.
Climate over any given period is an expression of all of these nested mechanisms and cycles
operating together.”

Our vision is to ensure that:● U.S. seafood continues to be produced sustainably
A worthy goal however, by definition, every pound of U.S. seafood is sustainably managed
by the MSA. We have been engaged in this process for nearly 50 years.
●

The U.S. seafood sector contributes to the nation’s climate-ready food production andto meeting critical domestic nutritional needs

Climate-ready fisheries should also include developing new fishing opportunities on
emerging stocks in a warming Atlantic, however, this does not seem to be a current Agency
priority. It is also important to understand that U.S. fisheries can and do feed customers in
offshore markets, to aid in a resilient processing sector in the U.S.
●

U.S. seafood production increases to support jobs, the economy, and thecompetitiveness of the U.S. seafood sector

Another worthy goal, however, the U.S. government does not offer programs to help
existing businesses expand production capacity to help us compete with producers in otherparts of the world where, in many cases tariffs and value-added taxes are employed against
U.S. products to keep our products more expensive in important export markets.
●

Supply chains and infrastructure are modernized with more value-added activity in the
United States

See the comments immediately above.
●

Opportunities are expanded for a diverse and growing seafood workforce2

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

This is an important goal; however, our workforce continues to be diverse and with many
young people in our community attracted to the year-round jobs we provide in a resortoriented economy. We need people willing to work hard and we have been rewarded with
employees who have been with us for decades.

Strategy Drivers
NOAA Fisheries’ National Seafood Strategy supports the growing importance of seafood inmeeting global needs and recognizes the unprecedented challenges faced by the U.S. seafood
sector.
We appreciate this policy statement’s recognition that U.S. seafood suppliers are in a global
business, which should be understood and embraced by government and consumers alike.
Seafood is Good for People
Seafood is one of the best sources of nutrients essential for human health and well-being. It isalso critical to providing food to a growing global population.
We agree and appreciate the strength of this statement.
Seafood is Good for the Economy
The U.S. harvests about 10 billion pounds of seafood annually with a dockside value of $6.3
billion. Domestic seafood is also an economic engine that supports 1.2 million jobs andgenerates $165 billion in sales across the broader economy.
Our people work hard, nearly 365 days a year, to contribute to the value of our seafoodproducing sector; from boat to plate.
Seafood is Good for the Planet
Harvested responsibly, as it is in the United States, seafood is also an environmentally friendly
way to produce a nutritious food given its relatively low carbon footprint and efficient use ofresources, and is increasingly a critical part of food systems designed to reduce and mitigate theeffects of climate change.
We support this statement and would like the Agency to prioritize these facts in regularstatements to U.S. seafood consumers.

Strategy Framework
The National Seafood Strategy focuses on NOAA Fisheries’ work to sustainably manage
marine fisheries and produce seafood responsibly, based on sound science. It is one of a suiteof strategies that describes how we will support the nation’s fisheries and execute our mission
in the face of climate change, market disruptions, and new ocean uses.
State and Federal fisheries scientists are our closest allies and our boats and our plant
personnel continue to participate in cooperative fisheries research programs in theregion. Climate issues should not be used as a reason to interject additional
uncertainties in the quota allocation systems of the Councils and Commission.

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Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

As mentioned above, the domestic seafood industry has exhibited the ability to remain
resilient and react to market and environmental changes for many decades and I
predict we would remain so, even if we were believed to be on the verge of an ice age.

The National Seafood Strategy also allows NOAA Fisheries to address important national
issues such as the resilience of coastal fishing communities; the financial viability of theseafood industry; the effects and opportunities of international trade; and the importance of
seafood to nutrition, food security, food sovereignty, subsistence fishing, and traditional
Tribal fishing rights.
We support and appreciate these broadly-stated goals.
To implement the Seafood Strategy, NOAA Fisheries will partner with state and other federal
agencies, the National Sea Grant College Program, Tribes, non-government organizations,fishermen, seafood farmers, and other stakeholders to address the challenges facing theseafood sector, especially when resources are limited.
The importance of shoreside processors to fishing communities is missing from this list. We
regret that government resources are limited in support of the strategy’s goals andencourage the administration to establish a knowledgeable industry advisory group to guideits implementation.
GOAL 1: Sustain or increase sustainable U.S. wild capture production
Changes in ocean conditions and the resulting shifts in distribution and abundance of marine
resources, as well as the intensity of damaging storms are affecting access to and production ofseafood as well as subsistence and Tribal fishing. These factors, in addition to new ocean uses
and advances in sampling technologies and data modernization call for an evolution in scienceand management frameworks for a climate-ready seafood sector, including:● Fisheries Science. Provide the science and economic and social analyses necessary forfisheries management under changing ecosystem dynamics.
We strongly support this focus and point of emphasis.
● Fisheries Management. Maximize fishing opportunities and sustainable seafood
production while ensuring the sustainability of fisheries through effective and efficientmanagement. Support the commercial fishing industry and fishing communities in theirefforts to adapt to climate change and thrive in a changing ocean economy.
Streamlining access to emerging fisheries should be a federal priority but we have yet to see
this policy emerging…instead, its all ‘Chicken Little, the sky is falling in’, unfortunately.
● Habitat Conservation in Support of Fisheries. Protect and restore habitat important toour nation’s fisheries and support resilient coastal communities.

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Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Fisheries habitat is in excellent condition after 48 years of Federal management, gear
modifications and necessary changes in fishery practices implemented over that time.
Offshore wind development in our Atlantic region is the single largest threat to our ability tomaintain the condition of essential fisheries habitat and preserve its productivity potential forthe future.
GOAL 2: Increase sustainable U.S. aquaculture production
Seafood is a healthy and climate-friendly nutrition choice and demand is increasing.
Aquaculture is one of few ways to significantly increase domestic seafood production—it’s how
the majority of growth in demand has been met in the last 20 years. Supporting gradual,
diverse, and regionally-appropriate growth of the domestic industry will depend on an efficient,strategic, and science-based regulatory approach that considers and mitigates impacts onprotected resources, essential fish habitat, and marine ecosystems.
● 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.
Aquaculture is not a part of our core business although shellfish aquaculture has become an
important part of the Cape May County economy. Aquaculture production, however, cannot
be expected to, in any way, substitute for the volumes of seafood produced in the wild
harvest fisheries of the region.
GOAL 3: Foster access to domestic and global markets for the U.S. seafoodindustry
A thriving, well-regulated domestic seafood industry—capable of competing at home andabroad—will translate into greater global seafood supply and food security from sustainable
U.S. fisheries. It will also decrease our reliance on foreign fisheries that are at greater risk ofoverfishing, IUU fishing, and forced labor.
We agree, overall, with this goal and the point of emphasis highlighted below; however,many ‘foreign fisheries’ are well managed by the coastal states and it is important to avoid
blacklisting other nations under the banner of eliminating foreign overfishing, IUU fishing andforced labor. On the other hand, U.S. fishery importers need clear federal guidelines,
protocols, and documentation requirements, to help us to educate our trading partners andthereby assist us in avoiding illegal products in the U.S. fishery supply chain.
●Communication and Promotion. 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 anddevelop U.S. seafood markets and put more U.S. seafood back on U.S. plates

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Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

●

Fair Trade. Promote fair seafood trade by combating IUU fishing and related harmful
fishing practices around the world and by expanding access to foreign markets for U.S.
seafood.

GOAL 4: Strengthen the entire U.S. seafood sector
The COVID-19 market disruptions highlighted systemic challenges to the U.S. seafood industry
and the importance of supporting the entire seafood/fisheries value chain, including after
seafood hits the docks. Addressing these challenges will help the seafood industry to rebuild
more quickly and enable the industry to be more resilient and flexible in the face of potential
future crises and market shocks.
Our company’s strategic value-added investments allowed us to weather COVID-19
disruptions by supplying seafood products that consumers could bring home to eat. Our
company did not miss one day of work, either in our plants or on our boats, over the past
three years.
●

Seafood as a Vital Part of the Blue Economy. Support the U.S. commercial fishing,marine aquaculture, and seafood communities to adapt and thrive in a changing ocean
economy and given new competing uses.

Changing environment or not, we are and will remain resilient and we don’t expect muchfederal help in remaining so – private sector investments need to be recognized as the vehicle
to realize this goal.
●

Seafood Infrastructure. Work across federal agencies to modernize U.S. seafood
infrastructure (e.g., vessels, hatcheries, port and dock facilities, processing, storage,
working waterfronts) to strengthen and enhance opportunities for coastal seafoodcommunities and regional food economies.

Again, while a welcomed goal, we do not expect to see federal investment partnerships
emerging, to help us continue to make investments in our seafood processing infrastructure.
The private sector deserves recognition as the vehicle to facilitate these outcomes.
●

Workforce Development. Foster a growing and diverse seafood workforce and attract
young fishermen and seafood farmers to the sector.

We continue to accomplish these workplace goals, and provide good jobs in the community,
through our investments in equipment and people. Again, the private sector deserves more
recognition here, we do not expect federal programs to take the place of good business
investments and practices.
With best regards,

Wayne Reichle
Wayne Reichle, President; wreichle@lundsfish.com

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Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

April 3, 2023
Dr. Michael Rubino
Senior Advisor for Seafood Strategy
NOAA Fisheries Directorate
Email: michael.rubino@noaa.gov
RE:

Comments on the proposed National Seafood Strategy

Dear Michael:
The National Aquaculture Association1 supports the proposed National Seafood Strategy for its
focus on increasing seafood production by U.S. farmers and commercial fishermen. We request
action by the National Oceanic and Atmospheric Administration to organize and hold a nationalseafood summit predicated upon the Strategy and informed by the draft Strategic Plan for
Aquaculture Economic Development.
We believe that a national summit to stimulate farm-raised and wild-caught seafood production
investment and growth in the United States is needed. Canada, Chile, China, India, Indonesia,
Ireland, Norway or Vietnam, all of which are significant exporters of farm-raised and wildcaught seafood to the United States, have used national development initiatives to:••••

Encourage infrastructure development such as working waterfront, transportation, feed
production, cold storage and processing.
Expedite technology transfer and adoption to reduce costs, increase production, andreduce environmental effects.
Train an aquaculture and commercial fishing savvy workforce.
Encourage entrepreneurial development by:o educating bankers and investors as to the opportunities for aquaculture andcommercial fishing to create, sustain and strengthen rural economies, jobs andincome,o improving and expanding existing financing programs,o creating investment incentives including tax credits,

1

The National Aquaculture Association is a U.S. producer-based non-profit association founded in 1991 that
supports the establishment of governmental programs that further the common interest of our membership, both asindividual producers and as members of the aquaculture community. For over 32 years NAA has been the united
voice of the domestic aquaculture sector committed to the continued growth of our industry, working with state andfederal governments to create a business climate conducive to our success, and fostering cost-effective
environmental stewardship and sustainability.

PO Box 12759, Tallahassee, FL 32317
Tel: (850) 216-2400  Email: naa@thenaa.net
Website: http://thenaa.net/

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Rubino Letter
Page Two
April 3, 2023
o developing risk management tools; and,o creating incentives for states, provinces or regions that wish to step up andsupport commercial fishing and aquaculture.
The development of a national seafood summit should include private sector representatives,
who understand what is required to build aquaculture farms, catch fish and operate successful
ancillary businesses. A jointly led task force by the departments of Commerce and Agriculturecomposed of state and federal economic development representatives and fishing andaquaculture stakeholders should be an outcome of the summit to develop specificrecommendations for actions that federal and state governments should take, a time table forthose actions, and a series of metrics designed to measure program efficacy.
We suggest that to achieve the outcomes of the summit, an investment of federal resources
equivalent to 5% of the annual seafood trade deficit is required. As the summit objects are met
and the seafood trade deficit is reduced the need for government investment would decline.
We strongly encourage a summit partnership effort that can be facilitated by the National
Aquaculture Association and stand ready to meet with you or your staff to begin organizationand planning.
If you should have questions or require additional information, please do not hesitate to contactus.
Sincerely,

Sebastian Belle
PresidentPublic comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Comments on NOAA Draft National Seafood Strategy
Frank Mirarchi
XII Northeast Fishery Sector, Inc.
March 1, 2023

XII Northeast Fishery Sector, Inc. is a cooperative association established underprovisions of Amendment 16 to the Northeast Multispecies FMP in 2010. Its
membership represents 23 multispecies permits and 6 active vessels based in
Scituate, Mass. Our members share and support the vision statement provided in
the Strategy Document. Our vessels are family owned and operated and arecontinuing a tradition that spans generations.
Having withstood the burdens and sacrifices imposed by two decades ofregulations designed to rebuild overfished groundfish stocks, we find ourselvesfacing new challenges. Several of these, along with some proposed solutions or
mitigations are listed below:
1. Fisheries science. For fishery managers and regulators to have timely andrepresentative data it is imperative that we do more to incorporate fisherydependent data into stock assessments. Monitoring programs, both humanobservers and electronic systems, have evolved into assuring complianceand accuracy of counting regulatory discards with little attention to the
biological condition of catches. Apparently, the port observer program,which collects aging information at processing facilities, has also been
diminished leaving growing uncertainty over the age structure of catches as
well.
Our recommendation would be to train fishermen and compensate themfor providing lengths and biological samples, such as otoliths, from
representative catches. In addition, information on spawning condition
could provide a broader picture than is now available from biennial fisheryindependent surveys.
2. Management. Enrollment in a sector has become a necessity for fishermen
who depend on predictable access to the groundfish (multispecies) fishery.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

The costs of sector operation have increased substantially due to theadministrative burden of programs such as at sea monitoring. Ultimately,
these costs are imposed on the fishermen through membership fees.
Congress has agreed that costs for training and placing of at-sea monitors
on multispecies trips are reimbursable. It is our belief that costs for thisprogram imposed on sectors and ultimately borne by member vessels
should be treated similarly.
3. Seafood infrastructure. There is a serious disconnect between theavailability of groundfish stock and landed harvests. For example, for fishingyear 2022, as of 2/21/23, with 85% of the fishing year elapsed only one
stock (white hake) had been harvested at over 50% of the allocated ACL.
For fishing year 2021 (5/01/21 through 4/20/22) the fishery landed 18,700
metric tons out of an allocated 131,400 metric ton allocation. This is 14% of
the total allocation.
A large factor in this poor performance is a lack of processing capacity. The
industry lost a large part of capacity during the COVID business closures. As
the economy rebounded, domestic groundfish species lost market share toimported products. Since then limited capacity to process has depressed
ex-vessel prices and contributed to volatility adding an additional level of
uncertainty to vessel owners’ business planning.
The industry desperately needs to upgrade infrastructure, especially insmaller ports. Capital costs for ice making, cold storage and processing
machinery are presently beyond the reach of boat owners, and processors
in these regions. A program of grants or loans designed to enable rebuilding
is essential. Without investment in shoreside infrastructure, we willcontinue to lose opportunity for economic vitality and food security in thisfishery.
We urge you to consider the points listed here when developing a strategy
implementation plan for our nation’s fisheries.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Pacific Fishery Management Council
7700 NE Ambassador Place, Suite 101 Portland, OR 97220‐1384
Phone 503‐820‐2280 | Toll free 866‐806‐7204 | Fax 503‐820‐2299 | www.pcouncil.org
Marc Gorelnik, Chair | Merrick J. Burden, Executive Director

March 16, 2023
Re: National Oceanic and Atmospheric Administration Draft Seafood Strategy
To Whom It May Concern:
The Pacific Fishery Management Council (Pacific Council) appreciates the opportunity to provide
comments on the Draft National Seafood Strategy (Draft Strategy). Sustainable seafood production
for both commercial and recreational fisheries is the fundamental mission of the Pacific Council.
We support the vision of the Draft Strategy, which prioritizes sustainable seafood production,
climate-ready fisheries and communities, economic competitiveness, and opportunities for a
growing and diverse workforce. We also have some suggested changes. Successful
implementation of the Draft Strategy will be dependent on National Oceanic and Atmospheric
Administration Fisheries’ commitment to fund and execute regional implementation plans. We
offer the following comments on the Draft Strategy.
The Pacific Council is well positioned to contribute to the Draft Strategy goals of increasingsustainable wild capture production, fostering access to domestic and global markets, andstrengthening the seafood sector. Pacific Coast fisheries have experienced enormous challenges inrecent decades, such as overfished stocks, habitat degradation, climate change, market disruptions,and infrastructure declines. Although nearly all Federally managed stocks have been rebuilt, ourWest Coast fleets are in some cases prevented from achieving full utilization of several species,
due to catch constraints or other factors. Achieving Optimum Yield and increasing opportunities
for greater attainment of underutilized species represents excellent opportunities to address Goal
1 of the Draft Strategy, while also supporting Goals 3 and 4.
Increasing seafood production capacity would also increase the resilience of fishing-dependentcommunities. Revitalizing the seafood capacity and supply chain would support Goals 1, 3, and 4of the Draft Strategy.
We believe that the Draft Strategy could be more inclusive by not excluding the recreational sector.
We suggest the following changes:
 in the “Fisheries Management” bullet within Goal 1: “Support the recreational andcommercial fishing industries and fishing communities in their efforts to adapt to climatechange and thrive in a changing ocean economy.” In the “Blue Economy” bullet in Goal 4: “Support the U.S. recreational fishing,commercial fishing, marine aquaculture, and seafood communities to adapt and thrive ina changing ocean economy and given new competing uses.”Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Page 2

Under the “Strategy Drivers” heading, we recommend that the “Seafood is Good forPeople” bullet articulate recreational benefits and the “Seafood is Good for the Economy”
bullet incorporate the recreational fishing economics.

The Draft Strategy highlights the importance of protecting and restoring habitats important to ournation’s fisheries, which in turn supports resilient coastal communities. The Pacific Council isproud of our actions to protect and conserve habitats vital to healthy and sustainable fisheries. We
note that a vast majority of the benthic habitat within the Pacific Coast Exclusive Economic Zone
is protected, and that nearly all the historic range (both ocean and freshwater) of Pacific salmon isdesignated essential fish habitat (EFH). However, more actions to protect fisheries habitat,
especially in freshwater systems, should be a priority. These actions should include designating
EFH in watersheds that are likely to become accessible to Pacific salmon via fish passage
improvements, as well as ensuring more robust water quality standards in vital river systems suchas the California Central Valley and Klamath systems. The final Strategy should include
opportunities for NMFS to use its authorities to address these important habitat concerns. We notethat improving habitats and water quality standards also benefits food security, food sovereignty,
subsistence fishing, and traditional Tribal fishing rights, and supports resilient communities.
We would also like to emphasize the crucial role of scientific surveys and reliable stock
assessments in fisheries management and seafood production. Best available scientific informationis the foundation of sustainable fisheries management, and adequate funding is critical to support
the surveys and the science that goes into sustainable fisheries management.
The Draft Strategy highlights many benefits of sustainable seafood production, which is good forfood security and nutrition, for fishing-dependent communities, and for the U.S. economy. Goal 2of the Draft Strategy addresses sustainable aquaculture production, which could play a role inseafood production. However, we strongly suggest that the most efficient and effective path toincreasing seafood production is to capitalize on existing wild capture opportunities and utilize
existing infrastructure.
Thank you for considering these comments, and please contact me with any questions or further
discussion.
Sincerely,

Marc Gorelnik
Chairman
KFG:rdd
Cc:

Pacific Council Members
Sarah Shoffler
Michael Rubino

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

March 27, 2023
To:

Ms. Janet CoitNOAA Assistant Administrator for Fisheries
1315 East-west Highway, 14th Floor
Silver Spring, MA 20910
via email: nmfs.seafoodstrategy@noaa.gov

From: Rick Marks
Robertson, Monagle & Eastaugh
LLC Email:
RE: Comments on the Draft National Seafood Strategy
Thank you for the opportunity to comment on the Draft National Seafood Strategy. These
comments are informed by the needs of many of our Firm’s clients across six Regional Fishery
Management Council regions.
GOAL 1: Sustain or increase U.S. wild capture production
Achieving this goal is contingent on two key aspects, fisheries science and management.
Obviously the first informs the second, and both of which allow us to achieve and maintain
optimum yield from each fishery.
On improving fisheries science – the downward trend in the number of days-at-sea for the
NOAA “White Boat” fleet is untenable. Contractual and unmanned survey work will not fill thegap. The impacts of offshore wind activity on long term surveys will only compound the
problems. In addition to this, we are seeing a general reduction in cooperative research efforts insome regions which exacerbates data poor problems and further alienates the agency from someof its core constituents.
This is a fairly simple problem to fix, it is just not an easy one. The lack of data increases
scientific uncertainty which leads to larger precautionary buffers, less fishing activity andultimately, reduced wild capture production over time. The exact opposite of GOAL 1.
Ironically, the 2006 amendments to the Magnuson-Stevens Act (MSA) increased the reliance on
science to address fine scale ACL and AM requirements, among other things, but we have notseen a concomitant increase in the capacity of the overall system to adequately meet these newdata requirements. For example, the lack of a timely, accurate and precise red snapper survey in
the South Atlantic region has kept the fishery closed for many years and just the type of fixable
problem that undermines achieving GOAL 1.
To resolve this situation NOAA and Commerce must clearly prioritize and aggressively pursue
these issues in the policy and budgetary processes or we will see no improvement and the agency
will fail to achieve GOAL 1.
In addition to fisheries science, protected species science also impacts the agency’s ability toachieve GOAL 1. The lack of data and lag time related to protected species stock assessments,
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Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

declarations of optimum sustainable population (OSP) levels, and uncertainty aroundinteraction/stranding data are hugely impactful to wild capture fisheries performance.
There are numerous examples where the agency has struggled with conservation decisions anduse of questionable data to limit fishing activity. Here are a just a few examples: the AK trawl
industry continues to suffer from restrictions designed to recover the Western Steller sea lion
DPS despite the agency never having proven its forage-based hypothesis upon which therestrictions were originally based; and the lack of any survey for anecdotally-reported abundant
neritic stage sea turtles in the Gulf of Mexico (relying solely on nesting success rates) did notstop the agency from time/area closures and reductions on the number of hooks used on longline
vessels.
The agency’s inability over many years to declare CA sea lions at OSP substantially delayed
management actions and negatively impacted other marine resources in the region. Morerecently, record numbers of strandings by large whales in the Mid-Atlantic region, some in areas
concurrent with offshore wind survey activity, has not been thoroughly addressed (~ 60% of
whales still have no assigned direct or proximal cause of death; this includes for species otherthan humpbacks that are not undergoing a declared UME) which may well have long term
impacts on wild fisheries production. As wind energy development expands on the West Coast
this same scenario has the potential to create havoc in that region’s fisheries.
I served on four MMPA Take Reduction Teams (TRT’s) and one common theme from theseexperiences is the TRT’s more often than not operate in extremely data poor situations. We are
required to hold the industry to a very high level of accountability but we often do so withextremely limited information. This is a most unfortunate situation and the agency should
prioritize increasing the amount of protected species-related data so there is less reliance on the
precautionary approach which ultimately undermines GOAL 1.
The bottom line here is that while industry generally respects the need for conservation action
there is a belief the agency should also put a similar level of effort toward gathering the proper
data to make certain any restrictions are fully justified, quantifiable, and adaptive over time.
On improving fisheries management – perhaps one of the most important elements here is for theagency to revisit the fact that the American consumer’s access to healthy affordable domestic
seafood comes through commercial fishing and the actions of the Regional Fishery Management
Council system. In some regions, such as the Mid-Atlantic, South Atlantic, and Gulf of Mexico,
those councils are not properly balanced and subsequent decisions on allocations, alternative
management measures, and overharvest by the recreational sector come at cost to commercial
fishermen and consumers alike.
For example, one could easily argue that an unbalanced RFMC choosing to leave thousands ofpounds of available but unharvested mahi mahi in the ocean just to enhance the pleasure ofrecreational fishermen (in a fishery that is not typically catch & release…) which then leaves
U.S. consumers to eat imported mahi is not in the best interest of this Nation’s food supply andfood security, in achieving optimum yield, in reducing our seafood trade deficit, and towardachieving GOAL 1.

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Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

To NOAA’s credit the most recent 2022 Report to Congress on the Regional Councils actuallycalls for increasing the membership for commercial fishing stakeholders in all three of theaforementioned regions. While I understand NOAA must respect nominations by governors theagency does have leeway under Section 302 regarding qualifications and choices that can bemade from every slate of nominees. The agency must act now to rebalance these RFMCs if weare to start on the path toward achieving GOAL 1.
Finally, the agency must also strictly adhere to the fact that implementation of the Modernizing
Recreational Fisheries Act by some of these currently unbalanced RFMCs must be consistent
with all requirements of the Magnuson-Stevens Act. I am hopeful the agency will review all
related RFMC actions in this proper context and reject those that undermine MSA integrity.
GOAL 3: Foster access to domestic and global markets for the U.S. seafood industry; andGOAL 4: Strengthen the entire U.S. seafood sector
Commerce (and NOAA) has obvious challenges when it comes to balancing the dual authorities
that require both regulations for proper management and supporting/promoting the economy,
sustainable fisheries and achieving optimum yield. Generally speaking, NOAA is viewed as an
advocate for commercial fisheries in the federal system much in the way the Department ofAgriculture is for American farmers. In recent years there is a growing perception in the industry
that the agency’s primary focus has shifted toward increased regulation and protectionism andaway from promotion/jobs/economy/food production/food security and of strengthening thecommercial seafood sector.
Take this Draft Strategy by example – it did not come from NOAA but rather was the result ofan Administration directive to the agency. Hopefully, this Strategy and NOAA’s focus on the“Blue Economy” are opportunities for the agency to change course and increase their efforts insupport of GOAL 3 & 4.
To be clear, the agency has done some very helpful work with industry regarding international
trade issues. Additionally, the Seafood Watch initiative has been constructive. I believe theindustry would favor more such work, much more, perhaps with an expanded scope beyond thesmaller boat-to-plate operations to include a broader segment of the commercial fishing andseafood sector. But for this to have any substantive effects it has to be positive, persistent andsystemic.
Here is just one example to illustrate the point. Today (March 27, 2023) I logged onto the NOAA
website. There is no mention of commercial fisheries or U.S. seafood production, no evidence
whatsoever. Here, a member of the public can learn that it is national “Seal & Sea Lion Week”,
and that a sanctuary is being proposed by the Administration in the Pacific Remote Islands, but
nothing else related to American seafood production. You actually have to go to the NOAA
Fisheries page before you see a single story about seafood in a small Philadelphia community.
Reversing this trend requires philosophical change that has to start with NOAA leadership.
When NOAA actively defends its successful management programs by default it supports the
U.S. commercial fishing and seafood sector. Such actions can help to prevent harmful legislationfrom passing that undermines the Strategy. But when NOAA defers, bad things happen. For
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Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

example, in February 2020 the Department of Commerce openly opposed legislation banning thecommercial use of shark fins in the U.S. NOAA rightfully and forcefully defended its sustainable
shark fishery and the legislation did not pass.
However, NOAA leadership failed to lead on the issue after 2020 and this same unnecessary andharmful legislation passed Congress in 2022. This was a loss both for NOAA’s sustainablefisheries management program and the U.S. commercial shark fishery which at one point was the
8th largest in the world. Wherever appropriate and as the responsible federal management agency
NOAA must truthfully communicate the impacts of these issues that may undermine the U.S.
industry. The Forage Fish Conservation Act is yet another recent example of potential fisheries
legislation that if not stopped, would do more harm to U.S. seafood production than it will tohelp the environment.
NOAA also has leadership opportunities to work across agencies to help promote seafood that
may not be so easily achieved by the industry operating alone. Using outreach and coordination
with industry to add U.S. seafood products to national healthy eating initiatives and USDA foodprograms should all be a part of a broadly focused NOAA strategy to support U.S. seafood
production wherever possible.
On the topic of cross agency support initiatives consistent with the Draft Strategy-- for many
years the U.S. squid industry on the East and West Coasts, with the full support of the PFMC &MAFMC, have requested and failed to get NOAA’s help to engage the USFWS to address the
deficiencies in Interior’s definition of “shellfish”, and to stop the FWS from treating domestic
squid the same as Lacey Act/ESA/CITIES-listed species under the Import/Export License
requirements (at 50 CFR 14). The FWS authority over MSA managed species is unnecessarily
harming domestic seafood production. Adequately resolving this situation would immediately
strengthen the U.S. squid industry on both coasts.
Lastly, fishery disaster assistance is another area where NOAA’s role is critical and where theagency can help the U.S. seafood sector. The passage of national fishery disaster reform
legislation in late 2022 provides opportunities for improving the process in terms of speed andefficiency. I encourage NOAA to implement helpful changes as soon as possible. Furthermore, I
have seen examples where State fishery disaster “spend plans” provide a disproportionate shareof the funds to address state budget needs rather than going to the impacted industry
stakeholders. To the degree NOAA recommends adjustments to spend plans I hope the agency
will do all it can to ensure the appropriate level of assistance goes to those industry constituents
most impacted and as quickly as possible.
Thank you for the opportunity to comment on the Draft National Seafood Strategy.
Respectfully submitted,
Rick Marks, Partner
Robertson, Monagle & Eastaugh, LLC

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Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Sea Watch International, Ltd.
8978 Glebe Park Drive  Easton, MD 21601
Sales: 410-820-7848  800-732-2526
Fax: 410-822-1266

March 30, 2023
Dr. Michael Rubino, Senior Advisor for Seafood Strategy
NOAA Fisheries
1315 East-West Highway
Silver Spring, MD 20910
Dear Dr. Rubino;
Sea Watch International, Ltd. is a vertically-integrated harvester and processor of surf clams andocean quahogs from US Federal waters offshore of the mid-Atlantic and New England. We are aleading supplier of clam meat, clam juice in frozen, canned and value-added products forindustrial, foodservice and retail markets. We also own Look’s Gourmet Foods, a Maine-based
cannery that has a presence in 5,500 retail locations nationwide through the Bar Harbor brand.
We have invested heavily in science to support stock assessments and improve operational
efficiency through our involvement with the Science Center for Marine Fisheries. As a result of
our efforts, we partnered with other companies in this sector to gain Marine Stewardship Council
certification for the US surf clam and ocean quahog fishery.
We offer the following comments toward issues that we encounter that should be considered incrafting the National Seafood Strategy.
National Standard 1 of the Magnuson-Stevens Fishery Conservation and Management Act statesthat “Conservation and management measures shall prevent overfishing while achieving, on acontinuing basis, the optimum yield (OY) from each fishery for the United States fishingindustry.” It is clearly abundant that the United States is a hallmark to the World in identifying
overfishing and implementing measures to correct overfishing so that stocks can be economicallyrebuilt. Along with other examples i, a feature the fishery in which we operate is that surf clams
and ocean quahogs are an underutilized ii (p. 3) US fishery. In 2022, quota utilization for surf
clams and ocean quahogs was iii 43.5% and 44.4% respectively and neither fishery has reachedfull quota utilization since 2003 iv (p. 17). Underfishing represents the inability for a fishery toachieve OY. Therefore, underfishing should be elevated to the same status as overfishing v andPublic comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

just like overfishing, efforts should be initiated to identify root causes and develop tangible plans
to maximize US fishery resources.
US fisheries are being impacted by climate change. Our business has experienced this first-handas the geographic footprint of surf clam populations has moves northwest and offshore over the
past few decades. We helped fund the science that continues to understand and quantify theextent of these range shifts vi. These same range shifts are occurring with other fisheries meansthat Essential Fish Habitat (EFH) is also dynamic. However, the habitat protection measures thatare designed to protect EFH tend to remain static polygons on a map protecting EFH for speciesof concern that are no longer meaningfully in these areas. Habitat protection needs a change inthe “set it and forget it” default for establishing habitat closures, where species designed to beprotected have moved out due to climate change. An even greater threat to optimizing US
seafood production are initiatives such as the establishment of Marine Protected Areas underlarge policy initiatives such as “30 by 30.” We believe that the regional fisheries management
councils provide the proper forum to collaboratively establish Marine Protected Areas
underpinned by scientific objectives.
We refer to comments on the impact of offshore wind to US Seafood in comments submitted
separately by the Responsible Offshore Development Alliance (RODA). We add that offshore
wind poses threats to future economic contribution by US seafood, approaches mitigation to the
US fishing sector as an afterthought, threatens to stock assessments by permanency of structuresthat will forever impact mobile bottom tended gear. Using estimates from the USDA, EPA andDOE vii, the American Biogas Council incorporated recent industry data to conclude that a fullydeveloped infrastructure of land-based renewable natural gas (RNG) in the United States could
power 7.5 million homes viii. This is a significant, underdeveloped source of domestic renewal
energy that would divert food and agricultural wastes that will be inevitably generated anddisposed of by less than otherwise optimal means.
We believe there is an opportunity to increase the prevalence of US seafood in federal
commodity programs. During the COVID-19 pandemic, we were approached with a handful ofopportunities to develop products for clams and other seafood and aquaculture products. We
found that seafood did not fit well in USDA Section 32 commodity purchase programs. We
support the creation of criteria that allow seafood products to be considered on their own
economic merits, rather than those created to accommodate terrestrial agricultural commodities.
As an alternative, a program within the US Department of Commerce dedicated to special
purchase programs for seafood commodities for nutrition and emergency feeding programs may
be a better solution.
We feel like the original intent of the The Saltonstall-Kennedy (S-K) Act of 1954 (15 U.S.C.
§713c-3) has been systematically and dramatically diluted providing less funds to thecommercial Fishing Industry, Academic Research of domestic fisheries and the Marketing anddevelopment of Domestic Fisheries. These funds could be much more efficiently spent by private
industries and non-governmental entities than dumping money into the general budget of the
National Marine Fisheries and NOAA. According to the Congressional Research Service,R46335 ix, in 2018 the USDA transferred $154.7 million dollars, which is only 30% of the duties
collected from imports of seafood to the Department of Commerce, of which $10.7 million

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

dollars made it to the S-K program which has to pay for grants, operating expenses and other SK programs. Can you imagine the infrastructure development and healthy sustainable domestic
seafood products that could be made available to the citizens of this still great country of ours, if
only the funds were used as intended?
Thank you for the opportunity to help craft our National Seafood Strategy. We can and must do
better to support the domestic and international competitiveness of US commercial fishing.
Sincerely.

Guy B. Simmons
Joseph J. Myers
Senior Vice President, Sales and Marketing Senior Director, Innovation & Sustainability

https://www.savingseafood.org/science/noaa-report-spotlights-underfishing/https://www.congress.gov/116/meeting/house/111092/witnesses/HMTG-116-II00-Wstate-HilbornR20201117.pdf
iii
https://www.greateratlantic.fisheries.noaa.gov/ro/fso/reports/h/clam/FYALL_REPORTS//2022-1222_clam_coast_qm.html
iv
https://static1.squarespace.com/static/511cdc7fe4b00307a2628ac6/t/633df2ef89cdc26dfcb7b390/16650044174
79/SCOQ_SpeciesSeaprationRqmt_PHD.pdf
vhttps://www.fisheries.noaa.gov/national/sustainable-fisheries/status-stocks-2021vi
https://www.accesswire.com/viewarticle.aspx?id=709373
vii
https://www.usda.gov/oce/reports/energy/Biogas_Opportunities_Roadmap_8-1-14.pdf
viii
https://americanbiogascouncil.org/wp-content/uploads/2019/05/ABC-Handout-2019apr-vP3-1.pdf
ix
https://sgp.fas.org/crs/misc/R46335.pdf
iii

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Southern Shrimp Alliance
P.O. Box 1577 Tarpon Springs, FL 34688
955 E. MLK Dr. Suite D Tarpon Springs, FL 34689
727-934-5090 Fax 727-934-5362

March 24, 2023
TO:

Janet Coit, Assistant Administrator for Fisheries, NOAA
Michael Rubino, Senior Advisor for Seafood Strategy, NOAAFROM: John Williams, ExecuHve Director, Southern Shrimp AllianceRE:

NOAA Fisheries DraK NaHonal Seafood Strategy

The Southern Shrimp Alliance (SSA) appreciates the opportunity to present these comments on
the NOAA Fisheries DraK NaHonal Seafood Strategy. SSA also appreciated the opportunity toreceive and provide inputs on a presentaHon of this Strategy by Mr. Rubino at the March 16,2023, meeHng of the Gulf of Mexico Fishery Management Council’s Shrimp Advisory Panel on
which several SSA representaHves sit, including me. I note that some of the comments made atthat Shrimp AP meeHng by SSA representaHves are further elaborated in these comments.
General Comments
Shrimp is the most popular seafood consumed in the U.S. Urner Barry reports that in 2020, U.S.
shrimp consumpHon rose to 5.0 pounds per capita, a 25 percent increase over the previous ﬁve
years, and in 2021 and 2022, rose sHll further to record highs at 5.8 pounds and 5.7 pounds,
respecHvely 1. According to NOAA’s Fisheries of the United States, total U.S. seafood (ﬁsh andshellﬁsh) consumpHon per capita in 2020 was 19.0 pounds 2. From these ﬁgures, we canconclude that shrimp accounts for more than 30 percent of all seafood consumed in the U.S.
According to NOAA's foreign fishery trade and commercial landings databases, the total U.S.
supply of shrimp to the U.S. market in 2021 was nearly 2.2 billion pounds, of which only 8.7
percent (188.7 million pounds) was landed by the U.S. Gulf and South AtlanHc shrimp ﬁsheries,_______________

1
2h"ps://www.urnerbarry.com/PDF/Consul8ng/shrimp_inventory_fcst.pdf
h"ps://www.ﬁsheries.noaa.gov/resource/document/ﬁsheries-united-states-2020

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

while 91.3% (1.98 billion pounds) were imported. 3, 4 From these ﬁgures, we can conclude thatapproximately 27.4 percent (602 million pounds) of all seafood consumed annually in the U.S. isimported shrimp.
While precise esHmates can be elusive, numerous federal and non-proﬁt studies indicate that asubstanHal porHon of shrimp imports consumed in the U.S. is produced in IUU ﬁsheries andusing forced or child labor in ﬁsheries, processing faciliHes, the producHon of feed used byshrimp farms, and in the operaHons of those farms as well.
Further, the results of FDA’s tesHng of farm-raised shrimp imports from naHons that are thelargest suppliers of shrimp imports to the U.S. conﬁrm that a signiﬁcant percentage of such
shrimp is contaminated with residues of FDA-banned anHbioHcs used on those farms to preventor treat disease outbreaks, increase stocking densiHes, and increase growth rates. The humanhealth threats associated with those anHbioHc residues in shrimp imports are both on theindividual level – such as in the case of aplasHc anemia – and on the global human populaHon
level – as in the case of contribuHng to anH-microbial resistance – something that many world
health experts have idenHﬁed as the greatest threat to human health in the coming decades.
We must also point out that in addiHon to being abhorrent abuses of human rights, threats tohuman health, and violaHons of ﬁshery conservaHon objecHves, these serious and illegal
deﬁciencies in the standards and pracHces by which some signiﬁcant percentage of shrimp
imports consumed in the U.S. is produced provide those foreign shrimp producers – whether inwild capture ﬁsheries, in processing faciliHes, or on shrimp farms – with a substanHal
compeHHve advantage in the U.S. market over shrimp produced in our domesHc shrimp
ﬁsheries.
As is well documented by NOAA’s own staHsHcs, ex vessel prices for U.S caught shrimp, U.S.
shrimp landings, U.S. shrimp ﬁshing eﬀort, and the number of acHve vessels in the U.S. shrimp
ﬂeet have all fallen to record lows in recent years since the massive and conHnued growth in
U.S. shrimp imports over the past two decades that was fueled by the development and rapid
expansion of shrimp farming in the major shrimp exporHng naHons.
This reality has today reached existenHal proporHons for the domesHc shrimp industry. Recent
surges in shrimp imports have ﬂooded the U.S. market and overwhelmed U.S. inventories to thepoint that shrimp processors can no longer purchase shrimp from U.S. shrimp ﬁshermen. As a
direct result, a substanHal number of U.S. shrimp vessels are currently unable to ﬁsh at all andremain Hed to the dock. Those that go ﬁshing have found that they cannot sell their shrimp at a
proﬁt, if at all. Many believe that we are on the precipice of the collapse of this iconic Americanﬁshery – once the most valuable in the enHre U.S. and today sHll the most valuable in the Gulf
of Mexico.
________________
3
4h"ps://www.ﬁsheries.noaa.gov/na8onal/sustainable-ﬁsheries/foreign-ﬁshery-trade-datah"ps://www.ﬁsheries.noaa.gov/foss/f?p=215:200:32165188631007:Mail::::2

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Consequently, no U.S. ﬁshery has a more signiﬁcant stake in NOAA’s NaHonal Seafood Strategy
than the domesHc shrimp industry. For these reasons, SSA strongly supports the clear focus of
this NaHonal Strategy on protecHng and advancing U.S. seafood producHon, including shrimp,
the most sustainable and safe seafood in the world.
SSA membership comprises shrimp ﬁshermen, processors, and the associated shoresideenterprises and ﬁshery-dependent communiHes throughout the Gulf and South AtlanHc
regions. Working on their behalf since its founding 20 years ago, SSA has shared many of thesame purposes and prioriHes - along with the goals and the strategies to achieve them - as are
reﬂected in this NOAA NaHonal Strategy. We strongly support this overall Strategy and lookforward to working with NOAA to implement it. However, we must stress that there are several
very important objecHves and acHons outside of NOAA’s scope that other federal agencies andCongress must pursue to address the U.S. shrimp industry’s current and long-term needs, andwe plan to conHnue our work with those other agencies and Congress as well. We certainly
encourage NOAA to do the same.
GOAL 1: Sustain or increase sustainable U.S. wild capture produc<on
On its face, this Goal states a fundamental shrimp industry priority, and it sets forth speciﬁcscience, management, and habitat protecHon objecHves and strategies for ﬁshery sustainability
that are shared by the shrimp industry - not just in words but in acHons.
SSA regularly partners with NOAA and non-federal scienHsts to generate the best scienHﬁc
informaHon available and parHcipates extensively in the federal ﬁshery management process
through the Regional Councils, the Advisory Panels, and the agency’s rulemaking process tosustainably manage our shrimp stocks, to minimize our bycatch to the extent pracHcable, and toprotect sensiHve marine habitats.
SSA looks forward to conHnuing its partnerships and collaboraHons with NOAA and its partner
agencies in implemenHng this Goal through the following prioriHes, among others:-

EssenHal to the eﬀecHve assessment of shrimp stocks and the management of theﬁshery to minimize bycatch and protect sensiHve habitats is the collecHon and analysisof data that provides precise measures of shrimp ﬁshing eﬀort. The agency mustcomplete its work with the Gulf Council and shrimp industry to implement a new
system.

-As noted in the Strategy itself, “new ocean uses” compeHng with the shrimp industry forspace present a new challenge to the Goal to “sustain or increase sustainable U.S. wild
capture produc9on” of shrimp, as well as to the goals of “Maximizing ﬁshing
opportuni9es and sustainable seafood produc9on…”. Therefore, NOAA must conHnue
developing and applying spaHal suitability modeling in collaboraHon with the shrimp
industry and, as appropriate, with its partner agencies to deconﬂict such new ocean uses
as oﬀshore aquaculture and oﬀshore wind energy development with the shrimp
industry. We note that the availability of precise measures of shrimp ﬁshing eﬀort arealso an essenHal element of this modeling.
3

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

GOAL 2: Increase sustainable U.S. aquaculture produc<onOnce again, SSA shares the perspecHve reﬂected in this stated Goal of the Strategy:“Suppor9ng gradual, diverse, and regionally-appropriate growth of the domes9c
industry will depend on an eﬃcient, strategic, and science-based regulatory approachthat considers and mi9gates impacts on protected resources, essen9al ﬁsh habitat, andmarine ecosystems.” (emphasis added)
SSA has engaged extensively to ensure that future oﬀshore aquaculture development follows
that necessary science-based approach. As noted above, SSA has collaborated with NOAA’s
NaHonal Centers for Coastal Ocean Sciences (NCCOS) in its spaHal suitability modeling and thedevelopment of its Aquaculture Opportunity Areas (AOA) Atlas for the Gulf of Mexico. SSA is
also providing extensive inputs addressing ecosystem and shrimp industry impacts to NOAA’s
ongoing development of a ProgrammaHc Environmental Impact States (PEIS) for AOAs in the
Gulf. 5 And, while serving as a Steering Commikee Member, it brought the shrimp industry’s
perspecHves and experHse to the Meridian InsHtute’s noteworthy workshop addressing thefuture of U.S. marine aquaculture.6
SSA again looks forward to conHnuing its partnerships and collaboraHons with NOAA and its
partner agencies in implemenHng this Goal through the following shrimp industry priority:-

The agency’s implementaHon of this Goal must prioriHze the sustainability of thisindustry to no less of a degree than it prioriHzes the sustainability of wild captureﬁsheries – with respect to potenHal ecosystem and habitat impacts and with respect todeconﬂicHng oﬀshore aquaculture operaHons with the ﬁshing industry both in the ocean
environment and in the seafood marketplace.

GOAL 3: Foster access to domes<c and global markets for the U.S. seafood industry
Of the goals of this Strategy to which the domesHc shrimp industry most closely relates intoday’s circumstances of a completely import-dominated U.S. market are the following:“A thriving, well-regulated domes9c seafood industry—capable of compe9ng at home
and abroad—will translate into greater global seafood supply and food security fromsustainable U.S. ﬁsheries. It will also decrease our reliance on foreign ﬁsheries that are at
greater risk of overﬁshing, IUU ﬁshing, and forced labor.” (emphasis added)“Promote fair seafood trade by comba9ng IUU ﬁshing and related harmful ﬁshingprac9ces around the world…..”
5h"ps://www.shrimpalliance.com/wp-content/uploads/2023/03/SSA-Comments-AOA-PEIS-no8ce-of-intent-721-22-.pdf
6h"ps://www.dropbox.com/s/niiuoivqzvruxl0/U.S.%20Marine%20Aquaculture%20Workshop%20Synthesis_Spring%202022.pdf?dl=0

4

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Since its founding, SSA has fought to combat unfair and illegal trade through the imposiHon ofanH-dumping duHes now in place for shrimp imports from China, India, Thailand, and Vietnam
and by working with Congress and federal agencies to develop, strengthen, and implement
policies and programs to prevent the importaHon of seafood produced in IUU ﬁsheries or withthe use of forced or child labor, with the use of illegal anHbioHcs, or imported through any
fraudulent means such as product mischaracterizaHon and mislabeling. Together with its
commitment to achieving the highest level of sustainability for any shrimp ﬁsheries in theworld, SSA’s extraordinary investment in combanng unfair and illegal seafood trade literally
deﬁnes the organizaHon.
Which brings us to the Strategy’s addiHonal and pivotal stated goal to “put more U.S. seafood
back on U.S. plates.” This, along with the focus of the enHre Strategy on increasing U.S. seafood
producHon and strengthening the resilience of the domesHc seafood-producing sector in partby taking acHons that level the playing ﬁeld with imports, could not resonate more with thedomesHc shrimp industry. The agency has it absolutely right in this Strategy.
That said, the non-proﬁt Seafood NutriHon Partnership (SNP) has advanced an iniHaHve thatwould establish a NaHonal Seafood Council and provide that Council with $25 million ofCongressional appropriaHons each year for ﬁve years for a naHonal seafood markeHng campaign(Eat Seafood, America) to promote seafood consumpHon in the U.S. 7
As described by SNP on their website and in many posts, the campaign will promote an increasein U.S. seafood consumpHon by promoHng - the human health beneﬁts of eaHng seafood - thesustainability of seafood, especially as compared to other meat proteins (beef, pork, chicken) and the many US jobs an increase in U.S. seafood consumpHon would create. The unfortunate
problem is, however, this markeHng campaign and the $125 million in taxpayer funds would be
used to promote U.S. consumpHon of both domesHc seafood producHon AND seafood imports.
For convenience here, using the oKen-cited staHsHc that roughly 90 percent of seafood
consumed in the U.S. is imported, that means, eﬀecHvely, that the campaign might use $112.5
million of U.S. taxpayer dollars to promote the U.S. consumpHon of seafood imports over those
ﬁve years, assuming their expenditures were proporHonal to that 90 percent ﬁgure. Contrary to
SNP’s claims, seafood imports are oKen neither sustainable nor healthy, and they oKen
compete unfairly—if not illegally—against U.S. ﬁsheries and U.S. jobs in many ways we havereferenced in these comments and elsewhere (e.g., IUU ﬁshing, forced labor, productmisrepresentaHon/fraud, substandard conservaHon standards, etc.).
If we consider just the InternaHonal Trade Commission's 2021 Report indicaHng thatapproximately 11 percent of U.S. seafood imports were derived from IUU ﬁshing in 2019, thatwould mean that the SNP campaign might proporHonately end up spending $12.4 million of
taxpayer funds over those ﬁve years on promoHng the consumpHon in the U.S. of seafood
derived from IUU ﬁshing. 8____________________
7
8h"ps://www.seafoodnutri8on.org/eat-seafood-america/h"ps://www.usitc.gov/press_room/news_release/2021/er0318ll1740.htm

5Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Given the extensive and much appreciated commitment and investment by NOAA in combanng
IUU ﬁshing, forced and child labor in the seafood supply chain, and all other forms of illegal
seafood imports, we expect that NOAA and the AdministraHon broadly would never support
spending U.S. taxpayer dollars on promoHng the U.S. consumpHon of seafood imports.
Indeed, we must recognize the extraordinary scope of authoriHes and programs to prevent
illegal seafood imports that NOAA’s Oﬃce of InternaHonal Aﬀairs, Trade, and Commerce isdevoted to implemenHng and enforcing in collaboraHon with other Federal agency partners,
such as the Seafood Import Monitoring Program (SIMP), the High Seas DriKnet Fishing
Moratorium ProtecHon Act, the Marine Mammal ProtecHon Act, among others.
Indeed, given all of the deﬁciencies in the standards and pracHces associated with seafood
imports idenHﬁed to date, the clearly arHculated purposes and goals and strategies of thisNOAA NaHonal Seafood Strategy to promote and increase U.S. wild and aquaculture producHon,
to “decrease our reliance on foreign ﬁsheries that are at greater risk of overﬁshing, IUU ﬁshing,
and forced labor,” and “to put more U.S. seafood back on U.S. plates” should ensure that NOAA
would never support or parHcipate in any acHvity such as the SNP campaign that would
promote the U.S. consumpHon of seafood imports.
Indeed, promoHng the U.S. consumpHon of seafood imports known to include seafood derived
from IUU ﬁsheries or produced using forced and child labor would be the anHthesis ofcombanng those illegal and abhorrent pracHces. Such support or parHcipaHon in the SNP
campaign would be strikingly inconsistent with NOAA’s NaHonal Seafood Strategy and the very
purpose and mission of its own Oﬃce of InternaHonal Aﬀairs, Trade, and Commerce. It would
represent a serious disservice to U.S. seafood consumers and their health, and a betrayal of thedomesHc wild capture and aquaculture producHon industries.
But wait….
The SNP website indicates that “The Eat Seafood, America! campaign is a collabora9ve eﬀort ofthe members of the Seafood4Health Ac9on Coali9on”. It then lists the members of thisCoali9on, which includes “NOAA Fisheries”. 9
Further, as reported by Cliﬀ White in his November 3, 2022, Seafood Source arHcle addressing
the departure from NOAA Fisheries of Deputy Assistant Administrator Paul Doremus:
While working in partnership with the Na9onal Seafood Council Task Force over the past
two years, Doremus played a key role in advoca9ng for federal funding for the Na9onal
Seafood Council, an industry-led eﬀort suppor9ng the Seafood Nutri9on Partnership(SNP) with its eﬀorts to promote seafood as a healthy food source, leveraging
recommenda9ons from NOAA’s Marine Fisheries Advisory Council.” (emphasis added) 10__________________
9h"ps://www.seafoodnutri8on.org/eat-seafood-america/h"ps://www.seafoodsource.com/news/premium/supply-trade/paul-doremus-leaving-noaa-joining-trident-notexpected-to-jeopardize-seafood-marke8ng-board-push10

6

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Indeed, while akending the 2022 Seafood Expo North America conference in Boston, SSA’s
representaHve heard ﬁrst-hand Mr. Doremus’s public expressions of strong support for the
SNP’s campaign to promote U.S. seafood consumpHon, including seafood imports,
notwithstanding the fact that at the very same conference, more senior NOAA oﬃcials spoke
extensively about the agency’s commitment to and investments in combanng IUU ﬁshing, theuse of forced and child labor, and the substandard conservaHon pracHces associated withseafood import supply chains.
SHll further, in that November 3, 2022, arHcle Mr. White quotes SNP’s President Linda Cornish as
follows:“Current NOAA Fisheries Assistant Administrator Janet Coit is a backer of the ini9a9ve,
Cornish said.”
Clearly, NOAA needs to reassess its policies and prioriHes. SSA calls on NOAA to rescind its
statements of support for spending federal taxpayer dollars on promoHng the U.S. consumpHonof seafood imports and support for proposed legislaHon and appropriaHons that would havethat result. SSA further calls on NOAA to cease and desist from any further parHcipaHon in the
SNP campaign so long as it conHnues to promote the U.S. consumpHon of seafood imports.
NOAA cannot adopt this NaHonal Seafood Strategy and at the same Hme support the objecHvesof or parHcipate in that campaign.
SSA notes that SNP and its campaign parHcipants sHll have the opportunity to reconsider andrevise its prioriHes to promote only the U.S. consumpHon of U.S. seafood produced in U.S. wild
capture ﬁsheries and U.S. aquaculture operaHons. Hopefully, with NOAA’s encouragement, they
will do so.
GOAL 4: Strengthen the en<re U.S. seafood sector
The U.S. shrimp market is ﬂooded with imported shrimp to the extent that it threatens the
future existence of the domesHc shrimp ﬁsheries. U.S. inventories are overwhelmed withshrimp imports. While the massive and conHnued growth in shrimp imports, especially farmraised, has a long history, today the oversupply of cheap farm-raised shrimp imports that haveoverwhelmed U.S. shrimp inventories are, in signiﬁcant part, a consequence of COVID-19
disrupHons. As referenced earlier in these comments, the domesHc shrimp industry also faces“new compe9ng uses” on both the ﬁshing grounds and in the working waterfronts, including
oﬀshore aquaculture and oﬀshore wind energy development. And, like many U.S. ﬁshingindustries, the U.S. shrimp industry is also experiencing an aging workforce and must akract
young ﬁshermen.
SSA strongly supports the goals and objecHves to strengthen the U.S. seafood sector andstrategies to achieve them set forth in this Goal of the NaHonal Strategy and looks forward toworking with NOAA to implement them.

7

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

March 15, 2023
Re: Comments on NOAA’s National Seafood Strategy
Dear NOAA Fisheries,
United Fishermen of Alaska (UFA) is the statewide commercial fishing trade association
representing 37 commercial fishing organizations participating in fisheries throughout the state
and the federal fisheries off Alaska’s coast. UFA recognizes the importance of a robust domestic
seafood industry in protecting and strengthening our Nation’s food security, and we value theopportunity to weigh in on a seafood strategy for America.
We appreciate NOAA’s efforts to support a thriving domestic U.S. seafood economy, and toenhance resilience in the seafood sector and our coastal communities. NOAA’s National Seafood
Strategy (Strategy) provides a high-level framework and our comments highlight and expand on
the specific components that we believe are the most important for our industry. When NOAA
develops an implementation plan we request additional opportunity to comment on that moredetailed plan.
UFA appreciates introductory comments in the Strategy document highlighting that wild seafoodin the U.S. is responsibly harvested, and one of the best sources of essential nutrients. In Alaska
we are incredibly proud of our sustainably managed commercial fisheries, and believe thatcharacteristic distinguishes us from many foreign competitors. We encourage NOAA to continue
pushing this message out to the American public to encourage more domestic consumption of U.S.
seafood.
Goal 1: Sustain or increase sustainable U.S. wild capture production
Fisheries Science. This goal speaks to the importance of fisheries science, and UFA wholeheartedly
agrees. Core fishery surveys provide necessary information that underpins our entire science-based
management system. Existing core surveys must continue, and NOAA should consider expanding
what is considered core (for example, adding regular surveys in the Northern Bering Sea orincreasing surveys in the Gulf of Alaska to occur annually). UFA also recognizes the need for
expanding fisheries science and research to better understand the impacts of rapidly changing
ecosystem dynamics. However, this expansion cannot come at the cost of core fisheries surveys.
Fisheries Management. This goal speaks to the importance of maximizing fishing opportunities
while ensuring the sustainability of fisheries through efficient and effective management, andsupporting the commercial fishing industry and fishing communities to adapt and thrive in the face
UFA Comments on NOAA’s National Seafood Strategy - Page 1 of 3

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

of a changing ocean economy. As noted above, the Alaska seafood brand is built on a reputation
for sustainability, and commercial fishing is the economic backbone of many of our Alaskan coastal
communities. However, conditions are changing rapidly around us, including our supply chains,
domestic and international markets, and ocean conditions. UFA strongly supports effective
fisheries management that can respond to these changes, ensure sustainable fisheries for tomorrow
while maximizing commercial harvest today, and allow our fishing businesses and coastal fishingcommunities to thrive.
Goal 2: Increase sustainable U.S. aquaculture production
Marine Aquaculture Management and Regulatory Efficiency. UFA recognizes the value ofmariculture and aquaculture, but strongly advocates that each state retain the ability to choose whichtypes of aquaculture activities are appropriate for themselves by including opt-out provisions.
Goal 3: Foster access to domestic and global markets for the U.S. seafood industry
Communication and Promotion and U.S. Market Development. UFA strongly supports increasing
domestic awareness about the sustainability, availability, and excellent nutrition of U.S. seafood.
Most of us are familiar with national campaigns promoting awareness of other foods (“Got Milk?”,“The Incredible Edible Egg”, “Where’s The Beef?”), and there is tremendous opportunity to do thesame for U.S. seafood. NOAA has a mechanism to help through the Saltonstall-Kennedy (SK)
grant program, which was created to market and promote U.S. seafood. This program is fundedthrough fees collected on seafood imports, and in FY2023 the SK program is slated to receive about
3% of the collected fees. UFA believes there is room to grow the SK grant program and supports
allocating a higher percentage of the collected fees for industry grants targeted at marketing andpromoting U.S. seafood.
Fair Trade. Most of Alaska’s seafood competes in global markets, and UFA appreciates theattention to fair trade issues and recommends NOAA partner with the U.S. Trade Office. UFA
representatives met with U.S. Trade Ambassador Tai in June 2022 and noted the following key
trade challenges facing the Alaska seafood industry.
1. The U.S. Trade Office does not have dedicated staff for seafood, as it does for textiles
and agricultural products. UFA recommends ensuring the Trade Office has thenecessary expertise, awareness, and bandwidth to appropriately support U.S. seafood
trade.
2. The U.S. seafood industry lacks U.S. trade policy support often afforded to farmers andmanufacturers. For example, foreign seafood often enters the U.S. entirely duty-free,
while seafood harvested in the U.S. and processed overseas is subject to high tariffs
when entering U.S. markets.
3. Tariff barriers in key export markets continue to grow, including China and Japan where
Phase One agreements should have increased purchases and opened markets. At thesame time the U.S. continues to allow duty-free import of Russian-harvested pollock
and crab.
4. Failure to address low-hanging fruit like removing Section 301 Tariffs on Alaskan
flatfish; all other Alaskan seafood products were removed from the Section 301 lists andremoving the last five flatfish product codes is truly low-hanging fruit.
Goal 4: Strengthen the entire U.S. seafood sector
Seafood Infrastructure. Alaska has aging fishing fleets and processing facilities and our seafoodindustry would greatly benefit from investments to modernize our infrastructure. Modernizing and
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replacing commercial fishing vessels would increase efficiency and safety on the water, while
modernizing processing facilities would increase efficiency while creating opportunities for morevalue-add processing in the U.S. Bringing more seafood processing back to the U.S., rather thancontinuing to ship product overseas, is a tremendous opportunity for U.S. seafood. Updating
seafood industry infrastructure will benefit our coastal fishing communities, and increase local andnational food security by eliminating the need to ship product overseas.
Workforce Development. UFA has long supported workforce development and training for theseafood industry, and trades necessary to support our fleets and infrastructure (e.g., refrigeration,
welding, hydraulics, etc.) There is also growing concern that fewer young people are opting tobecome fishermen, and we support initiatives that will raise awareness and attract young people to
the U.S. seafood sector to strengthen our nation’s food security. In addition, rapidly changing
fishery conditions have spawned an unprecedented number of fishery disasters in Alaska in recent
years. This has highlighted the need for much faster disaster relief to fishermen and communities,
and challenges with quickly identifying and accessing other mitigation measures when they areneeded for fishing businesses and individual fishermen (e.g., SBA EIDL program, or job retraining
resources).
We understand NOAA Fisheries will prepare an implementation plan that contains specific actions,timelines, partnerships, and milestones, and we request an opportunity to review and comment onthat plan when it becomes available.
Thank you,

Matt Alward
President

Tracy Welch
Executive Director

MEMBER ORGANIZATIONS
Alaska Bering Sea Crabbers • Alaska Longline Fishermen’s Association • Alaska Scallop Association • Alaska Trollers Association
Alaska Whitefish Trawlers Association • Area M Seiners Association • At-sea Processors Association • Bristol Bay Fishermen’s Association
Bristol Bay Regional Seafood Development Association • Bristol Bay Reserve • Cape Barnabas, Inc. • Concerned Area “M” Fishermen
Cook Inlet Aquaculture Association • Cordova District Fishermen United • Douglas Island Pink and Chum • Freezer Longline Coalition • Fishing Vessel
Owners Assn Groundfish Forum • Kenai Peninsula Fishermen’s Association • Kodiak Crab Alliance Cooperative • Kodiak Regional Aquaculture
Association • Kodiak Seiners Association • North Pacific Fisheries Association • Northern Southeast Regional Aquaculture Association • Northwest
Setnetters Association • Petersburg Vessel Owners Association • Prince William Sound Aquaculture Corporation • Purse Seine Vessel Owner
Association • Seafood Producers Cooperative • Southeast Alaska Herring Conservation Alliance • Southeast Alaska Fisherman's Alliance • Southeast
Alaska Regional Dive Fisheries Association • Southeast Alaska Seiners
Southern Southeast Regional Aquaculture Association • United Catcher Boats • United Southeast Alaska Gillnetters
Valdez Fisheries Development Association

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West Coast Seafood Processors Association
P.O. Box 1127
Astoria, OR 97103(503) 227-5076

March 31, 2023
NOAA Fisheries
1315 East-West Highway
Silver Spring, MD 20910
Submitted online via – NOAA Fisheries Draft National Seafood Strategy
RE: Draft National Seafood Strategy – WCSPA Comments
To Whom It May Concern:
On behalf of the West Coast Seafood Processors Association (WCSPA), I submit the following
comments on NOAA’s Draft National Seafood Strategy. WCSPA represents shoreside seafood
processing companies and related businesses located in California, Oregon, Washington, andAlaska. Our member companies also have plants and seafood distribution facilities in Texas, Hawaii,
Nevada, Utah, Arizona, and Florida. WCSPA members process the majority of Pacific hake (whiting)and non-whiting groundfish (rockfish, sole, sablefish) landed on the U.S. West Coast, in addition to
Dungeness crab, pink shrimp, salmon, albacore tuna, and other important commercial species.
WCSPA processing companies range from “mom and pop” operations to some of the largest
seafood companies in the United States, employing thousands of workers in harvesting, processing,transporting, and distributing seafood across the country and throughout the world. We are
essential workers, we are food producers, and we contribute greatly to our Nation’s food security.
WCSPA appreciates the opportunity to submit comments on NOAA’s Draft National Seafood
Strategy. In addition to the comments provided below, WCSPA signed a letter written by the
Responsible Offshore Development Alliance (RODA) and submitted as part of the record ofcomments on the Draft National Seafood Strategy. The comments and recommendations provided
herein are intended to supplement the comments submitted in the RODA letter and offer
perspectives more unique to U.S. seafood processors.
General Comments
U.S. wild capture commercial fisheries are managed to ensure sustainability and adhere to all
National Standards set forth in the Magnuson-Stevens Fisheries Conservation and Management Act(MSA). Fisheries management follows strict laws for sustaining stocks, conserving biodiversity(protecting habitat, marine mammals, and endangered species), and protecting the Nation’s living
marine resources. Moreover, robust U.S. laws mandate that fisheries and seafood production
follow workplace safety and protection rules, that seafood is safe for consumers to eat, and thatassociated environmental impacts are minimized and mitigated (such as with clean water).
Companies utilize internal controls and audits, backed by third-party verification, to maintainproduct traceability and integrity of their supply chains. For all of these reasons, successfully
implementing the National Seafood Strategy will require NOAA Fisheries to explicitly

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acknowledge the outstanding merits of the U.S. fishing and seafood industry and defend ourindustry against unwarranted threats.
Fishermen and seafood processors not only face changing environments, global supply chain
vulnerabilities, and potential loss of access to fisheries, but they must also contend with increasing
regulatory costs and burdens that threaten their viability and competitiveness with other nations.
NOAA Fisheries should include action items to address and counter these threats and stressors
when implementing the National Seafood Strategy.
We support NOAA’s vision outlined in the Draft Seafood Strategy and NOAA’s intent to enhance theresilience of the seafood sector in the face of climate change and other stressors. The fishingindustry is on the front lines of the climate change crisis, and U.S. reliance on imported seafood hascome at a climate cost. However, it is clear that the most significant threat the fishing and seafoodindustry faces is offshore wind development and its potential to produce devastating impacts on
fisheries, fishing communities, and fisheries ecosystems. We feel strongly that NOAA must more
explicitly identify and address the threat of offshore wind development to the fishing/seafoodindustry in its National Seafood Strategy.
The Draft Seafood Strategy is incorrect when it suggests that offshore wind will “potentially result in
conflicts.” Offshore wind, and other potential new ocean uses, will result in significant conflicts for
the U.S. seafood industry. NOAA’s Seafood Strategy must acknowledge this reality and establish
clear action items to protect the U.S. fishing/seafood industry and strengthen our ability to provide
nutritious food for the Nation. The Seafood Strategy should also strive to ensure that our sciencedriven fisheries management process is not compromised. We acknowledge and appreciate thework being conducted by NOAA’s National Centers for Coastal Ocean Science (NCCOS) in developinga spatial modeling tool that can help in identifying areas on the outer continental shelf potentiallysuitable for offshore renewable energy developments. However, in determining suitable sea spacefor offshore wind development, areas which are important to our commercial, recreational, tribaland subsistence fisheries should be deemed unsuitable for offshore wind development. NOAA
Fisheries should adopt and advance this position in the National Seafood Strategy.
Moreover, given some recent, significant marine mammal mortality events on the East Coast, we
remain extremely concerned that the impacts of offshore wind development on protected species
could become a major problem on the West Coast. Any negative impacts to West Coast humpback
distinct population segments (DPSs) will wreak havoc on West Coast fisheries. By way of example, in
May of 2022, NOAA sent a letter to the Bureau of Offshore Energy Management (BOEM) expressing
concerns about offshore wind siting on the East Coast and recommending that offshore wind sites
should be moved further offshore to protect migratory North Atlantic Right Whales, one of themost endangered large cetaceans and the focus of coastwide conservation efforts. To ourknowledge, BOEM never responded to NOAA’s letter.
Under Federal law, every ocean stakeholder group must work to protect conserve and protect
marine mammals, in some cases losing economic opportunities to do so, yet BOEM appears to havefree reign to build wind fields despite no clear understanding of the impacts of survey andconstruction activities on the marine environment. Once these large areas of our oceans areindustrialized and developed for offshore wind, it will be too late to remedy the damage.

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Concerns about the impacts of offshore wind development must be addressed as NOAA’s toppriority, and certainly to ensure any possibility of advancing the goals and objectives laid out in the
Draft Seafood Strategy.
Comments on the Seafood Strategy Framework
Goal 1: Sustain or Increase Sustainable U.S. Wild Capture Production
Fisheries Science. Federal fisheries surveys and resulting long-running datasets are integral to ourunderstanding of the marine environment (including impacts of climate change) and the foundation
for stock assessments which are the cornerstones of our fisheries management processes.
Disruptions to those surveys, or long-running datasets, result in less certainty for stock assessments
and other tools utilized in setting harvest guidelines for our fisheries. We strongly support NOAA’s
formal recognition of fisheries science as a top priority, given the need to increase and expand
surveys in a changing climate while facing increasing costs to do so.
NOAA’s National Seafood Strategy should identify and require specific commitments and actions
the Agency will undertake to better deliver this core function, including steps to ensure that
Federal fisheries surveys are conducted regularly and sustained. NOAA should explicitly include acommitment in the Seafood Strategy to increase scientific surveys to meet growing needs forecosystem and climate resilience.
Fisheries science must be a cornerstone of the National Seafood Strategy, and actions must be
identified to ensure its longevity and integrity. We are extremely concerned that the siting andlocation of offshore wind projects will interfere with NOAA’s scientific and research surveys, one of
the most critical elements of our fisheries management system. BOEM has not conducted any sortof Environmental Impact Statement (EIS) to examine the impacts of offshore wind development on
the West Coast marine environment, our critical upwelling ecosystems, and the migration of fishand marine mammals. The U.S. fishing and seafood industry is counting on NOAA to protect theenvironment as well as our access to healthy marine resources for U.S. consumers throughout theoffshore wind development process.
Fisheries Management. In the Seafood Strategy, we urge NOAA Fisheries to state how the Agency
will provide resources to support efforts to uphold the National Standards in the MSA, defend useof the best available science, and assist Regional Fishery Management Councils in the developmentof more flexible management actions to adapt to changing conditions.
The role of NOAA and impacts on industry and the marine environment from offshore winddevelopment are major concerns for the fishing/seafood industry on both coasts. NOAA is the lead
Agency for managing marine resources, and the impacts of offshore wind activities on thoseresources and on the stakeholders that depend on them are not well understood. Difficult as it may
be under the current regulatory and political framework, NOAA must firmly inject science andcommon sense into the currently-rushed approach to offshore wind energy development.

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Goal 2: Increase Sustainable U.S. Aquaculture Production
WCSPA recommends that the National Seafood Strategy: 1) clarify how NOAA will work with other
Agencies, the seafood industry, and other stakeholders to identify aquaculture’s impacts on marine
life and habitats and how negative impacts will be avoided; 2) address challenges created by new
ocean space allocation issues and changing environmental conditions; and 3) identify the impacts ofaquaculture development on existing seafood markets and include measures to proactively address
any conflicting interests of market sectors.
Goal 3: Foster Access to Domestic and Global Markets for the U.S. Seafood Industry
West Coast seafood producers face extraordinary challenges in the domestic and global
marketplace, including – among other things – tremendous trade uncertainty in recent years, thestrength of the dollar against most foreign currencies, and competition from low-cost seafood
producers from nations that are not subject to environmental safeguards and labor protections like
U.S. fisheries. In addition, joining these challenges is the sharp uphill battle recently created by the
COVID-19 global pandemic, including the near worldwide shutdown of the foodservice industry,
which generally accounts for a majority of seafood consumption, on top of the logistical difficulties
we currently face throughout the global supply chain.
Communication and Promotion. NOAA is well-positioned as an authoritative source of sciencebased and factual public outreach about the availability, sustainability, and nutritional value of
seafood harvested in the United States. The Seafood Strategy should include specific actions for
NOAA and NMFS to take to accomplish this goal, including investing in public outreach to bolster
consumer confidence in U.S. seafood and communicating the 2020-2025 U.S. Department ofAgriculture (USDA) Dietary Guidelines for Americans that support eating more seafood.
In the Seafood Strategy, NOAA should increase public and inter-Agency outreach on seafood’srole in meeting U.S. dietary needs. Towards this end, the Seafood Strategy should clearly articulate
how NOAA will improve upon existing government market support programs. NOAA should actively
partner with the USDA to provide more effective and timely support for its domestic foodmarketing and seafood purchase programs.
U.S. Market Development. As noted above, NOAA’s National Seafood Strategy must articulate
how NOAA will work effectively with the USDA and the seafood industry to communicate theoutstanding merits of seafood to U.S. consumers so domestic markets will further develop andprovide vital outlets for seafood producers. Toward this end, more seafood should be included in
the USDA’s National School Lunch Program (NSLP). The Seafood Strategy should also incorporate
regular input from domestic seafood producers so NOAA can better understand the domestic
market and related access challenges.
Fair Trade. While the volume of U.S. seafood produced from waters the West Coast and PacificNorthwest are large, it is a relatively small part of a global supply chain that encompasses large
volumes of competing wild and farmed species, many of which see comparatively small production
costs due to less stringent management and production efforts. The success of America’s fisheries
and seafood production systems, therefore, depends on the success of U.S. trade officials in
facilitating fair global seafood market access.

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Similar to the National Seafood Strategy, NOAA Fisheries should advance a National Trade Policy
for the seafood industry, through which NOAA Fisheries could work with the International Trade
Administration (ITA) and the Office of the United States Trade Representative (USTR) in designingand implementing a targeted plan for pursuing free and fair trade.
Illegal, Unreported and Unregulated (IUU) fishing degrades marine ecosystems, and forced labor isan affront to human decency. These practices in any part of global seafood production hurt
American producers by undercutting U.S.-harvested seafood in U.S. and global markets. Our
companies are held to high sustainability and other standards. Those standards should be more
broadly applied to fisheries around the world in ways that directly target bad actors and do not
impose undue burdens on lawful U.S. seafood trade.
WCSPA supports the National Seafood Strategy objective to combat IUU fishing. The Strategy
should include items that make full use of current authorities and programs to fight IUU fishing andexploitative labor practices worldwide, and in particular to leverage the cross-sector collaborationand governmental coordination functions called for in the Maritime SAFE Act. Current authorities
also allow agencies to address cases of domestic seafood fraud, and the Plan should ensure these
foreign IUU fishing and fraud enforcement programs are fully resourced. WCSPA recognizes thatNOAA Fisheries faces pressure to do more domestically to combat foreign IUU fishing, such as
expanding the Seafood Import Monitoring Program (SIMP). If the National Seafood Strategy
addresses SIMP, WCSPA strongly recommends that it remain focused on only a few of the highestrisk categories. Given its administrative complexity, high costs, risks to lawful seafood trade, andlack of effectiveness in identifying IUU fish, we strongly oppose expanding SIMP.
Goal 4: Strengthen the Entire U.S. Seafood Sector
WCSPA supports this goal and emphasizes the need to integrate the National Seafood Strategy
with the Federal government’s strategy for enhancing food security and creating resilient foodsupply chains.
Seafood as a Vital Part of the Blue Economy. NOAA’s Seafood Strategy must explain, in detail, how
NOAA will invest in and help fishing and seafood-dependent communities “thrive” as competinguses for ocean space increase and erode access to sustainable fisheries. Specifically, the Seafood
Strategy must explain how NOAA will bolster fishing community support and promote access tosustainable fishing, based on fully articulated values of seafood-based economies, while other
Federal Agencies like BOEM seek to develop offshore industries with little to no assessment andconsideration of impacts to fisheries and marine ecosystems.
The Seafood Strategy should state that before actions are taken to displace fisheries from ocean
space, NOAA and other agencies managing the action (i.e., BOEM) must proactively identify the fullrange of economic impacts (e.g., losses to jobs, income, reinvestment, tax revenue, etc.) andcommit to avoid and mitigate those impacts.
In addition, the Seafood Strategy should state how NOAA can help drive government investment toBlue Economy communities in the form of technologies, infrastructure, and market access, thereby
increasing their long-term ability to compete in seafood markets.

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Seafood Infrastructure. WCSPA supports the objective of modernizing U.S. seafood infrastructureand supply chain components to advance the resilience of fishing and seafood communities andregional food economies. In the Seafood Strategy, NOAA should identify every opportunity tobetter understand the U.S. seafood supply chain – from harvest to consumer – and work with thefishing/seafood industry to identify infrastructure needs at the local level. NOAA can then best
understand how to use its authorities and/or work with states and partner agencies to increasetechnical assistance and direct grant programs for vessel modernization and recapitalization, port
facilities, processing and storage facilities, and programs for modernizing seafood storage andshipment.
To support resilient coastal communities, WCSPA urges NOAA to include specific items in the
Seafood Strategy advancing partnerships with coastal communities to improve resilience andfortification for coasts and coastal infrastructure. In addition, we recommend NOAA focus on theinfrastructure capacity and modernization needs of seafood-dependent communities, particularly
those in rural locations. We recommend close consultation with local fishermen, seafood
processors, and community leadership to identify priority community resilience and infrastructure
projects.
Workforce Development. WCSPA strongly supports this objective. The best way to attractcommercial fishermen and seafood producers is to clearly facilitate economic success and further
signal to the national economy that domestic seafood is a national priority.
The Seafood Strategy should state how NOAA Fisheries will help minimize industry cost, burden,
risk, and uncertainty – and how it will help ensure that seafood jobs are in demand, pay well, andattract investments. It should explain how NOAA will work collaboratively with other agencies,
educators, and seafood employers to expand workforce development, training, and extension
programs, which are needed to instill valuable and unique fishing and seafood processing skillsets.
Toward this end, we recommend NOAA Fisheries work with the USDA to enhance supply chainsfor seafood production. By way of example, the USDA Rural Development administers a Meat andPoultry Processing Expansion Program (MPPEP) to provide grants to help eligible processors expand
their capacity. USDA Rural Development designed the MPPEP to encourage competition andsustainable growth in the U.S. meat processing sector, and to help improve supply chain resiliency.
A similar grant program for seafood processors would help strengthen the entire U.S. seafood
sector and enhance opportunities for coastal seafood communities and regional food economies.
As lack of workforce continues to be one of the major issues plaguing the seafood processing
industry, automated fish processing machinery is needed to supplement lack of hand filleters while
increasing throughput, but often requires multimillion dollar investments that are often
unattainable. Funds to support seafood processors could be used to offset significant capital
expenditures on cutting edge fish processing machinery.

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Thank you for the opportunity to provide comments on the Draft National Seafood Strategy.
Ultimately, it remains incumbent on NOAA Fisheries to lead and effectively partner with many otheragencies to implement this Strategy through an interagency approach, with NOAA Fisheries at thehelm. We look forward to the opportunity to work with NOAA Fisheries to implement the National
Seafood Strategy.
Sincerely,

Lori Steele
Executive Director

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March 29, 2023

Ms. Janet Coit, Assistant Administrator
NOAA Fisheries Directorate
1315 East-West Highway, 14th Floor
Silver Spring, MD 20910
Re: National Seafood Strategy
Dear Ms. Coit:
I am pleased to have the opportunity to comment on the National Marine Fisheries Services’
National Seafood Strategy on behalf of the California Wetfish Producers Association (CWPA).
CWPA represents California’s coastal pelagic species fishing industry whose harvests include
sardine, anchovy, mackerels and market squid and who produces more than half of the volumeof all seafood landed in the State. Our members form the backbone of California’s fishingeconomy, an essential asset to the State overall, as well as to communities such asMonterey/Moss Landing, Ventura, Port Hueneme and San Pedro/Terminal Island, where we
support both fishing infrastructure and significant regional employment. Thank you fordeveloping a strategy consistent with your continuing recognition of the seafood industry’s
contributions to food security, coastal communities’ economies and identities, and our Nation’s
interests. We are optimistic that you will use this strategy to further strengthen and stabilize theindustry’s position in the U.S. and international food supply networks and economies.
We fully support the strategy’s first goal of sustaining or increasing production from sustainable
U.S. wild-capture fisheries. We appreciate the focus on science as the basis for achieving thisobjective and the recognition of the challenges as we adapt to changing climate and ocean
conditions. Unanticipated ocean conditions have recently occurred and will continue to occur.

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California Wetfish Producer’s Association
Comments on the National Seafood Strategy

These changes will alter fish stocks and their distribution in both predictable and unpredictable ways.
Keeping pace of these changes is necessary for both constraining fishing opportunities as stocks
contract or move from an area and expanding fishing opportunities as stocks expand or enter new
areas. Survey data are critical to understanding the implications of these ocean changes anddeveloping appropriate responses. We strongly encourage NMFS to prioritize fishery surveys in its
implementation plan to improve its ability to effectively respond to changes.
NMFS has come to rely extensively on modeling for assessing fish stocks, habitat, and the ecosystem.
We face ocean condition changes beyond those previously seen. Extension of model results beyond
conditions previously observed is always challenging. To achieve the best results and make the bestuse of the modeling capacity developed at NMFS, current and comprehensive data for model
development, validation, and update are needed. Without maintaining (or even improving on) existingdata streams accurate modeling of the dynamic environment is not possible. To that end, NMFS efforts
to achieve efficiencies in its fishery surveys, such as exploring consolidation of the West Coast coastal
pelagic species and whiting surveys, are laudable. So too is its recognition that any consolidation of
those surveys must maintain the integrity of both. We are optimistic that NMFS staff will develop
survey methodologies that realize efficiencies without sacrificing the integrity of data. We believe
achieving the stated goal of maximizing fishing opportunities and seafood production while ensuring
sustainability requires, first and foremost, the best available data to support our understanding of themarine environment. We strongly encourage NMFS to prioritize collection of survey data as it develops
its implementation plan.
We strongly support the goal of fostering U.S. seafood’s access to domestic and global markets. We
are also encouraged by NMFS recognition of the need to promote fair trade of seafood and additional
access to international markets. Efforts to achieve this goal should include working to streamline trade
regulations (including coordination with partner agencies to streamline their regulations) to minimize
unintended and unnecessary burdens to seafood reaching both domestic and international markets.
We also support NMFS’s goal of strengthening the entire seafood sector. To achieve this objective, it
is critical that NMFS defend both its sustainable management of U.S. fisheries and the fisheries
themselves against competing actions. We ask that NMFS use its scientific knowledge of fisheries andmodeling capabilities to ensure that the estimates of the impacts of potential competing actions areaccurate and fully considered in policymaking processes. Initiatives of other agencies, such as a rapid
move to develop offshore wind power and administration wide initiatives to meet target set asides,
pose great risk to existing sustainable fisheries. Fairly weighing the tradeoffs of different actions
requires an understanding of both direct impacts (such as direct conflicts that prevent fishing in areas
being developed or set aside) and indirect impacts (such as the impacts on habitat that might occur
from changes in upwelling that are far from the areas being developed). Generalized analyses withbroad-based conclusions are not sufficient for this purpose. These considerations require specificanalyses of proposed actions. NMFS staff are best equipped and able to complete these analyses. A
complete analysis of tradeoffs that involve seafood sectors also requires consideration of the need for2

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California Wetfish Producer’s Association
Comments on the National Seafood Strategy

substitute food sources that may have greater environmental and climate impacts than wild capture
seafood.
NMFS should encourage a more gradual series of actions over large scale actions when an action is
novel or its impacts are less certain. Pacing of actions in this manner can allow for better understandingof impacts and balancing of interests, which should yield overall greater public benefit from actions.
Longer term analyses of realized effects from actions taken are needed to assess whether projections
were accurate and appropriately plan future actions. A commitment to both the analysis of potential
impacts of proposed actions and studies of realized impacts should be a part of the implementation
plan.
NMFS should strongly defend fisheries from encroachment that cannot be fully justified on its merits
and should also ensure that losses of investment to displaced fishery participants are fullycompensated. Policy changes that displace fishery participants who have made sound investments
based on the existing regulatory environment may at times be defensible, but having thoseparticipants bear the losses from that displacement is not. NMFS implementation plan should include
defending and advocating for fishermen to prevent undue displacement and minimize andcompensate for losses from displacement that advance the overall public good.
We strongly encourage NMFS to work closely with partners in federal, state, local, and tribal
governments, as well as industry to effectively implement its strategy. Sharing of information andcoordination of efforts across agencies and governments with industry input is the best way to ensurethat seafood has its rightful place in the country’s food supply and economy.
We look forward to NMFS implementing its strategy to expand their understanding and theappreciation of the benefits of seafood as a nutritious and environmentally friendly food source.
Thank you for the opportunity to comment.
Best regards,
Mark Fina

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March 31, 2023
Ms. Janet Coit
Assistant Administrator for Fisheries
NOAA Fisheries
1315 East West Highway
Silver Spring, MD 20910
Dear Asst. Administrator Coit,
Thank you for this opportunity to provide feedback on NOAA Fisheries’ Draft National Seafood
Strategy. Don’t Cage Our Oceans endorses the comments of our member organization, North
American Marine Alliance (NAMA), and would like to provide additional comments. First, wewelcome an open conversation on how NOAA Fisheries can support national seafood systems
in a way that benefits people and the planet. Coastal communities, local seaweed and shellfish
aquaculture producers, and fishing families should be active designers of these systems, andthe economic proceeds of catching and growing seafood should go back to those who live andwork in the affected communities.

A Deeper Dive into GOAL 2 of the Draft National Seafood Strategy
Goal 2 of the draft National Seafood Strategy, entitled, “Increase sustainable U.S. aquaculture
production,” would not normally be a cause for concern when taken at face value. However, ourcoalition members and allies in coastal communities have witnessed time and time again thatthe agency is operating with a very loose interpretation of the word “sustainable.” Offshore
finfish aquaculture has been proven worldwide to be harmful to the ocean ecosystem, and tocoastal communities and their economies. The practice, more akin to floating factory farms,
exhibits many of the same characteristics of its land-based cousins: massive fecal pollution andexcess nutrient discharge, parasitic disease incubation and spread, toxic chemical dosing andoveruse of antibiotics, and extremely high carbon-intensive feed inputs.
Research & Development in this field generally focuses on minor, mitigative measures, yet
contrary to industry statements, the underlying broken factory farming model of using the ocean
as a receiving body for agricultural waste remains the same. The industry mantra that “thesolution to pollution is dilution” may have been a wishful hypothesis in the 18th Century, but it iscontrary to modern scientific understanding in the fields of oceanography, biology, andmicrobiology, and undermines the precautionary principle. The entire offshore finfish farming

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industry relies upon key decision makers to subscribe to this false mantra for it to succeed in
obtaining permits.

For the federal government to endorse and fund offshore finfish farming at the expense ofexisting small businesses and coastal residents runs contrary to NOAA’s mission and does adisservice to all Americans. Furthermore, NOAA does not have the legal authority to regulateaquaculture, as ruled by the U.S. Fifth Circuit Court of Appeals.1 Offshore fish farming on a large
scale will only benefit massive corporations who are far from needing any extra economic
support. This makes NOAA’s multi-million dollar effort to fund these agribusiness-backed
interests even more shocking; indeed, from 2017-2022, NOAA spent $36.3 million directly
backing offshore aquaculture interests via the Sea Grant program, S-K grant program, and SBIR
grants. NOAA’s Aquaculture Opportunity Area (AOA) Atlas is already attracting the interest offoreign aquaculture companies.

Seafood should not replicate the failures of land-based agribusiness practices
NOAA’s strategy makes several broad-stroke claims about seafood being good for people, theplanet, and the economy, but this is only true under certain scenarios. Mismanaging our marine
resources and deferring to industry’s judgment regarding the best ways to privately exploit our
publicly-held waters means that we, as a nation, will collectively fail on delivering any of thesestated goals. With industrial-scale offshore fish farming, we would actively harm public health,the environment, and our coastal economies.
We saw a similar trajectory when the so-called “green revolution” in agriculture favored large
agribusinesses with destructive business models. The result was consolidated access tomarkets, land, and supplies. This shifted our country away from community-based and regional
food systems. Our seafood system must avoid those same mistakes. Truly sustainableaquaculture should focus on seaweed and shellfish aquaculture that is community-driven andsupported, and land-based recirculating aquaculture systems that focus on growing low-impact
and more affordable finfish, such as tilapia and catfish. Supporting these forms of aquaculture
would be better for the planet and actually feed the people, and must be coupled with an
economy that supports a living wage for everyone in the supply chain, not just record profits atthe top.

NOAA’s AOA process so far has valued profit over people
Currently, the strategy fails to acknowledge that NOAA’s stated goals regarding the promotion
and development of offshore aquaculture run counter to and directly conflict with the very
principles that the agency purports to uplift. People are not being heard. In the recent comments
and listening sessions on the proposed Aquaculture Opportunity Areas, the overwhelming
majority of comments were in opposition to offshore fish farms. In the Gulf of Mexico andSouthern California AOA proposals, only 4.9% and 7.9% of respondents, respectively, actually
supported the agency’s proposals. Unsurprisingly, these comments came almost exclusively
from those who stand to profit from offshore aquaculture. NOAA has a responsibility to listen to
1

See Gulf Fishermens Ass’n v. Nat’l Marine Fisheries Serv., N. 19-30006, 2020 WL 4433100, (5th Cir. 3
August 2020).

2

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

and incorporate feedback from the public as it determines its policies with regard to aquaculture
in federal waters. Currently, the American public is not supportive of finfish aquaculture. If
stakeholders’ input were actually being considered, this public opposition should have halted the
AOA proposals dead in their tracks. Instead, the voices of a small but vocal coalition of privateinterests – including some of the largest agriculture, pharmaceutical, and food service
corporations in the nation – have much greater weight in NOAA’s strategies and decision
making processes. When independent fishermen and coastal communities are unable tomeaningfully engage in the management of their fishery or coastal resources, companies withthe most resources are empowered to heavily skew decision-making in their favor. The successand monetary profits of corporate fish farm proposals directly rely upon other existing
stakeholders to lose out. Coastal economies and marine ecosystems will suffer in order forthese profits to be made.
We appreciate the opportunity to provide feedback to this seafood strategy. There are many
people in fishing and coastal communities who are excited and determined to ensure ourseafood is sustainable - both environmentally and economically - and we hope that theirnumerous voices are heard over offshore fish farming conglomerates, agribusiness andpharmaceutical companies. There is still time to turn this ship around.
Sincerely,
James Mitchell
Legislative Director
Don’t Cage our Oceans

3Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

March 30, 2023
Janet Coit
Assistant Administrator
NOAA Fisheries
1315 East-West Highway
Silver Spring, Maryland 20910
Re: NOAA Fisheries Draft National Seafood Strategy
Dear Ms. Coit:
Thank you for the opportunity to provide Environmental Defense Fund’s perspective on NOAA Fisheries'(Agency) National Seafood Strategy (Strategy) and share our recommendations for a robust and resilient
seafood sector in the United States. Seafood is a critical fixture of coastal communities across the U.S.,
providing commercial fishing and seafood processing jobs, opportunities for recreation on the water,
and cultural connectivity through food and natural resource stewardship. In the face of impacts fromclimate change, stressors on supply chains, and increasing global demand for seafood, it is imperativethat the Agency is intentional in its actions to ensure a thriving seafood economy while ensuring theconservation and sustainable use of the ocean and its vast resources.
We share the Agency’s vision for a sustainable, climate-ready, and inclusive U.S. seafood sector. The
challenges facing the seafood industry mentioned in the Strategy—impacts from climate change,
disrupted markets in the aftermath of the coronavirus pandemic, new conflicts for ocean space, andlabor shortages—are significant. These challenges, however, also offer opportunities to increase thesector’s resilience and economic prosperity. We appreciate that the Agency continues to be forwardthinking and adaptive to meet these challenges and ensure the long-term wellbeing of coastal
communities, American economies, and our ocean resources. Accordingly, please accept the following
comments on the Strategy. We welcome the opportunity to discuss our recommendations further andwork with you on furthering a sustainable and resilient U.S. seafood sector.
Goal 1: Sustain or Increase Sustainable U.S. Wild Capture Production
We agree that climate-informed and adaptive fishery management are imperative to ensure thesustainability of U.S. fisheries in the face of impacts from climate change. We encourage the Agency toprovide resources and guidance to the regional fishery management councils on actions they can take toensure climate information is integrated into fishery management and to encourage cross-regional
collaboration to share knowledge and solutions.
We support the Strategy’s statement that advances in data modernization and an evolution in
management and science frameworks are critical to ensuring a climate-ready seafood sector. Modern
data that allows managers and scientists to track catch and current ocean conditions, as well as predict

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possible future scenarios, enables resilient management of ocean resources and uses. Therefore, we
encourage the Agency to further expand the use of electronic technologies and modernize the agency’s
data management, storage, and governance policies and infrastructure to improve fishery independentand dependent data collection and use in management.
Warming waters and changing ocean conditions have impacts on the abundance and productivity ofcertain fish stocks. Combined with geographical shifts in stock distribution, securing access to fisheryresources for future generations relies on precautionary management that ends and prevents
overfishing and ensures fishery sustainability. The recent collapse of Alaskan snow crab and Bristol Bay
red king crab provide relevant examples. With this consideration, we encourage the Agency to provide
additional clarity in how the Agency’s plans to implement its’ first goal to sustain or increase wild caught
fishery yields in the face of worsening stock abundance, productivity, and geographical location. EDF, in
collaboration with the University of California, Santa Barbara (UCSB) recently published a paper withrecommendations for climate-informed harvest control rules that the Agency may find helpful as it
clarifies this goal in the implementation plan1.
We also urge the Agency to thoroughly investigate increasing marine use to meet its objective forconserving vital fishing habitat. The rise in offshore wind, marine protected areas, and possibility ofoffshore aquaculture necessitate that the Agency engage early and often with relevant stakeholders,
including fishermen, as well as improve and employ science-based marine spatial planning to minimize
conflicts.
Goal 2: Increase Sustainable U.S. Aquaculture Production
EDF sees the rising demand for responsibly sourced seafood and agrees that sustainable aquaculture canbe an important part of increasing U.S. seafood production if deployed in a manner based in science andthat reduces possible negative consequences on the marine environment and those that depend on it.
Marine aquaculture siting and operations must be informed by community needs, regionallyappropriate, and thoroughly examined to ensure there is sufficient information on potential risks tocoastal communities, local and regional ecosystems, and to mitigate scenarios due to new risks offarming the open ocean environment.
We encourage the Agency to clarify the metrics they are considering using to “accelerate progress” on aregulatory framework that would ensure there is sufficient data and analysis to make informed decisions
with aquaculture stakeholders and relevant communities. To encourage inclusivity and equity in theaquaculture supply chain, we recommend that the Agency provide outreach in multiple languages andwith the advice or support of social scientists to local communities and workers to ensure they areincluded in the development process as well as in the outcomes, such as potential benefits, of expanded
aquaculture production.
Goal 3: Foster Access to Domestic and Global Markets for the U.S. Seafood Industry
We appreciate and agree that more sustainable, U.S. seafood is key for global seafood supply and foodsecurity. When done responsibly, increasing domestic supply can ensure the seafood Americans eat is
responsibly sourced. Seafood must be a part of the long-term strategy for U.S. food security andresilience of coastal communities while we reduce emissions and prioritize eating local, nutrient-rich
food. Any communication and promotion strategy should not only highlight the sustainability of wildcaught fish in U.S. waters, but also increase education and visibility for U.S. aquaculture—educating
1 https://onlinelibrary.wiley.com/doi/10.1111/faf.12724

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

consumers on responsible aquaculture practices and how far the industry has come in recent decades
through scientific advances and technology.
Given that most seafood consumed in the United States is imported from other countries, key benefits
from strengthening our domestic seafood industry include increased local food supplies in coastal
communities and built-up local economies, but also the potential to reduce greenhouse gas emissions
from transit. We appreciate the goal of “U.S. seafood on U.S. plates,” and suggest clarity on how thisinterplays with increasing global markets and exports. We encourage the Agency to identify metrics for
how increasing seafood supply, especially through expanding U.S. aquaculture, can benefit U.S.
communities, especially those who have been historically underserved and may not currently be able toaccess or afford quality, domestic seafood commodities.
Goal 4: Strengthen the Entire U.S. Seafood Sector
We appreciate the focus on strengthening the U.S. seafood supply chain, especially as it relates toseafood processing. Current methods of exporting seafood to be processed in foreign countries only toreimport it are not just exporting jobs but increasing the carbon footprint of our domestic seafood. We
encourage a more robust plan that will strengthen the infrastructure necessary for seafood processingin the United States to localize jobs and decrease impacts on our environment.
Strengthening the seafood sector also means ensuring it has a future of sustainability-minded fishermen
and aquaculture practitioners. Especially as fleets are aging, we encourage the Agency to invest inpractices that recruit and retain diverse fishermen and aquaculture farmers to expand access to goodpaying jobs and create a new generation of stewards for our natural resources. This also includes
creating knowledge sharing networks for seafood farmers to share best practices and learn how to growsustainable and profitable farms. Focusing on a new generation of the seafood workforce provides anopportunity to insert equity and environmental justice principles at every step—we encourage theAgency to integrate the principles, goals, and metrics from the Agency’s Equity and Environmental
Justice strategy into the expansion of the Seafood Strategy.
EDF agrees that there is an opportunity to grow the U.S. seafood industry and that the United States can
set best practices in an era of economic and environmental upheaval. We appreciate the Agency’s focus
on opportunities that the seafood industry can provide to support local communities, the U.S. economy,
and global food systems. We encourage further development on metrics that can evaluate the economicand equitable benefits of seafood production to local communities as well as practices that center
minimizing harm to the surrounding environment. We welcome the opportunity to further discuss ourrecommendations, the Strategy, and additional opportunities to develop a sustainable, inclusive, andequitable seafood industry.
Sincerely,

Reggie Paros
Acting Lead, U.S. Fisheries & Oceans
Environmental Defense Fund

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Re: Draft National Seafood Strategy
To Whom It May Concern,Thank you for the opportunity to comment on NOAA’s Draft National Seafood Strategy. I am agraduate student in an environmental masters program at the University of Colorado in Boulder.
I received my bachelors of science in forestry and natural resource management from the
University of Minnesota and I’m currently working on a project looking at sustainable
governance through one of my courses.
I would like to raise concerns regarding the Draft National Seafood Strategy:
1. Goal 1 of the Strategy assumes there’s an existing baseline knowledge around the current
state of US fisheries and does not account for ecosystem health.
2. Goal 4 discusses a need to modernize seafood infrastructure without discussing the side
effects of the infrastructure itself and their impacts on our climate.
In summary, the language in Goal 1 needs to address the current lack of information regarding
ecosystem overfishing before suggesting sustaining or increasing wild fish capture. Goal 4 needs
to address the intersectionality between seafood infrastructure, bycatch, and the environmental
impacts of the infrastructure itself. Please see below for additional details and pertinent literature.
Sincerely,
Sydney Dynek
University of Colorado Boulder Masters Candidate

MAIN COMMENT TEXT
Point 1
Historically fisheries in the US have analyzed fish stocks as isolated populations rather thanlooking at their place in the broader ecosystem. When this broader lens is taken, 2 out of the 8large marine fisheries in the US exhibit indications of ecosystem overfishing (Link, 2021). While
the subheadings of this goal call for an increase in fisheries science, fisheries management, andhabitat conservation in support of fisheries, none of these methods speak to reducing current wild
capture if they find the fisheries are in fact being overfished. This is problematic as it leaves thefisheries in question more at risk for overfishing or collapse before the extent of the degradationis realized.
Thinking about human well-being, overfishing of specific fish populations has resulted incultural shifts leading people to consume more predator fish. After it’s released by humans andnatural sources, the neurotoxin methylmercury accumulates in the ocean, and the due to thePublic comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

nature of the trophic structure, these predator fish have increasingly high concentrations of thisneurotoxin (Schartup, 2019). An over exposure to this toxin can cause long term neurocognitive
deficits in humans, a health consideration that was not accounted for when these long-term
international fishery policies were developed. Without consideration of the impacts of shifting
human consumption of fish species to account for overfishing of other species, this health impact
could be experienced by an unnecessarily large number of people.
Additionally, the description of Goal 4 speaks to Tribal community and subsistence fisher people
needs but does not include consultation or collaboration with them at any part in this process.
There are several case studies of fisheries in Canada that have started to work towards more
empowering coexistence of knowledge forms using the Two-Eyed Seeing methodology toaddress this need (Reid et al., 2021).

Point 2Different fish harvesting technologies result in different amounts of bycatch of unintended fish
species, resulting in different ecological and climate impacts (McKuin et al., 2021). Lost fishingnets alone account for approximately 0.6 Mt of primary plastic pollution in our oceans (Boucher,2017). If new infrastructure is brought into the system without action taken to mitigate andremediate from the previous ecological harms of the previous infrastructure, this exercise will
merely serve to increase ocean pollutants instead of affecting positive change.

BIBLIOGRAPHYBoucher, Julien, and Damien Friot. 2017. “Primary Microplastics in the Oceans: A Global
Evaluation of Sources.” IUCN.
DOI : 10.2305/IUCN.CH.2017.01.en
Link, J. S. (2021). Evidence of ecosystem overfishing in US large marine ecosystems. ICES
Journal of Marine Science, 78(9), 3176-3201.
McKuin, B., Watson, J. T., Stohs, S., & Campbell, J. E. (2021). Rethinking sustainability inseafood: Synergies and trade-offs between fisheries and climate change. Elem Sci Anth, 9(1),00081.
Reid, A. J., Eckert, L. E., Lane, J. F., Young, N., Hinch, S. G., Darimont, C. T., ... & Marshall,
A. (2021). “Two‐Eyed Seeing”: An Indigenous framework to transform fisheries research andmanagement. Fish and Fisheries, 22(2), 243-261.
Schartup, A. T., Thackray, C. P., Qureshi, A., Dassuncao, C., Gillespie, K., Hanke, A., &Sunderland, E. M. (2019). Climate change and overfishing increase neurotoxicant in marine
predators. Nature, 572(7771), 648-650.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Central Wharf, Boston, MA 02110‐3399
617‐973‐5200 www.neaq.org

March 16, 2023
NOAA Fisheries
RE: Anderson Cabot Center for Ocean Life Comments on the NOAA Fisheries Draft National
Seafood Strategy
Dear NOAA Fisheries:
Thank you for the opportunity to provide comments and recommendations on the NOAA
Fisheries Draft National Seafood Strategy.
The New England Aquarium (Aquarium) is one of the preeminent aquariums in the UnitedStates and a global leader in ocean exploration and marine conservation. In addition to our
exhibit halls, which educate over a million visitors a year on marine and aquatic ecosystems andtheir inhabitants, the Aquarium is also a leading ocean conservation organization with researchscientists and experts working around the globe for the preservation and sustainable use ofocean resources.
As active stakeholders with institutional expertise on a range of ocean science andmanagement issues, including fisheries and aquaculture, we offer the following comments andrecommendations. If you have any questions or require further clarification, please do nothesitate to contact us.
Sincerely,
Matt Thompson
Michelle Cho
Lena Weiss

Anderson Cabot Center for Ocean Life Comments on
NOAA Fisheries Draft National Seafood Strategy

Page 1 of 2

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

General Comments
It is unclear what time period that the National Seafood Strategy will cover. Is this a one, five‐ or ten‐year strategy? When will it be renewed or revised?

Comments on Specific Sections of the Document
Page

SectionComment

2

GOAL 1

Suggest changing Goal 1. In the draft, it is to “Sustain or increase U.S. wild
capture production”. Under the Magnuson–Stevens Fishery Conservationand Management Act, however, U.S. fisheries production is alreadymanaged at Maximum Sustainable Yield (MSY), therefore this goal should
more appropriately focus on promoting underutilized species or recovering
fisheries stocks that have been overfished or are experiencing overfishing, as
well as improving fishery and fishing gear efficiency while continuing tominimize bycatch.

2

GOAL 1

Suggest the focus of the Fisheries Science section also include tools tominimize potential effects of fishing on the environment, including
protected resources, essential fish habitat, and marine ecosystems.

3

GOAL 1‐2

Suggest Goals 1 & 2 also include a bullet to focus on quantifying the trade‐
offs between different responsible ocean uses, such as between seafood
production (wild and farmed) and offshore wind, and enable informed
decision‐making regarding spatial use.

3

GOAL 2

Suggest Goal 2 include a focus on alternative feed ingredients to supplement
fishmeal and fish oil, including novel feed ingredients (microalgae, insect,and single‐cell proteins).

3

GOAL 3

Suggest Goal 3 include a bullet point on diversifying American seafood
preferences towards seafood sources that may have a lower environmental
footprint and that could be farmed at scale in U.S. waters, such as promoting
consumption of farmed seaweeds or shellfish.

3

GOAL 3

Suggest GOAL 3 include a bullet on encouraging improvement in global
fishing practices to achieve comparability on regulation and environmental
performance with U.S. seafood production.

4

GOAL 4

Suggest Goal 4 include a bullet supporting blue technology and innovative
solutions that can boost U.S. seafood production and help address
sustainability challenges.

Anderson Cabot Center for Ocean Life Comments on
NOAA Fisheries Draft National Seafood Strategy

Page 2 of 2

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

March 13, 2023
Ms. Janet Coit, Assistant Administrator
National Marine Fisheries Service
1315 East-West Highway, Room 14636
Silver Spring, MD 20610
Dear Director Coit:
The Net Gains Alliance (NGA) is a non-partisan, independent initiative that works to improve thecollection, management, and use of data and information to enhance the benefits obtained fromsustainable management of fisheries and marine ecosystems. Since our launch in 2017, we’ve
funded over $1m in projects to promote fisheries data modernization, issued multiple reports
and recommendations, and continuously engage a community of more than 1,000 fishermen,
advocates, academics, ocean innovators, managers, and agency staff in conversations andprogramming around digital transformation in the fisheries sector. NGA believes that data
management by NOAA Fisheries should be executed in a systematic, coordinated, modern, andtransparent manner to ensure the highest and best current and future use of all data.
We generally support the goals and strategies contained in the draft National Seafood Strategy.
Much of NGA’s work over the past five years has emphasized the value of data modernization
for core fisheries science and management in support of our vision for a data-driven future, suchas simplifying electronic catch reporting to enable better in-season management and creating
unique trip identifiers to link multiple records. We are seeing the agency invest in these areas
and we expect that work will support Goal 1 of the Strategy. In these comments, we focus on
additional areas where data modernization is needed to advance the Strategy, and theinterconnected portfolio of NOAA and NMFS goals.
Working toward and achieving these goals and strategies will require timely, data-informed
actions by NOAA Fisheries staff and partners throughout the seafood supply and value chains,
including both wild-caught fish and aquacultured products. Modern, interoperable data systems
will benefit science, management, and business operations and will require a robust datasystem that incorporates the following attributes:●●●

Interoperability, including increased findability and reusability of datasets across programsilosTransparency, including revision of data confidentiality restrictions on data access
Procurement and programs based on data and performance standards, not hardware orsoftware requirements, to allow technologies to keep pace with innovation

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Further, integration of the multiple aspects of fisheries science and management, businesses
and supply chains, and economic and social justice issues will require NOAA Fisheries tocommit to improvements and investments in staffing in the following areas:
1. Improve data resolution
In order to support the commercial fishing industry and fishing communities in “their efforts toadapt to climate change and thrive in a changing ocean economy … given new competing uses”(Goals 1 & 4), NMFS needs to know much more about who is fishing and where, and the socialand economic characteristics of those communities and locations. As we’ve seen in efforts toprovide disaster relief to fishing communities, it can be difficult to identify captains, crew, andbusiness owners, much less their demographics and economic dependencies or those of thebroader, connected coastal communities. More and better data are needed to inform workforce
development and seafood infrastructure investments, understand skills gaps and support
equitable outcomes across places and communities.
2. Invest in – and share – human dimensions data
Human dimensions data has emerged as a top priority in NOAA Fisheries’ Next Generation
Data Acquisition Plan process, indicating a broad consensus that NOAA Fisheries should invest
in infrastructure and expertise to support this work. The Strategy rightly recognizes under Goal 4that strengthening the U.S. seafood sector depends on supporting resilient communities,
infrastructure, and employment. A successful National Seafood Strategy should also connect tothe goals set out in NOAA Fisheries’ 2022 Equity and Environmental Justice strategy.
Improved economic and social science data will support more effective decision-making in theface of a changing climate. Seafood policies can be better tailored to specific contexts if local,
regional, and national economic data are robust. High quality “asset class” data is also indemand by investors, insurers, and third-party certification programs, such as the Marine andAquaculture Stewardship Councils and the Task Force on Nature Related Financial Disclosures.
To be competitive and well-positioned for the future, tomorrow’s U.S. domestic seafoodbusinesses will need to demonstrate they meet safety, sustainability, and social impact
standards. NOAA should be a data partner in helping businesses do so.
3. Rethinking data sharing, within and outside NOAA Fisheries
One of the most common complaints NGA hears from stakeholders is the difficulty accessing
their own data from NOAA Fisheries and the limited ability to integrate NOAA reporting data withthird-party software. Fisheries and aquaculture businesses should be able to prepare a reportand submit it to all necessary recipients - buyers, exporters, sustainability certifiers, andgovernment agencies - and that report should become a verified record for all partners. Thatwould mean an importer can double check the location of a catch (or farm, in the case of
aquaculture) by viewing the certified landing receipt, rather than calling the captain or businessowner. To do this, NOAA Fisheries needs to rethink its data sharing and interoperability policies,
setting up more role-based access permissions and allowing cross checking between outside
vendor systems and regulatory reporting systems.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

To find success with the Strategy and more broadly, the agency needs to prioritize investing inthese upgrades through staffing, training, and data infrastructure. The overlapping
responsibilities of multiple government agencies overseeing these issues and the potential forenvironmental, economic, and social impacts on vulnerable coastal communities renders thework complex and difficult. However, investing in modernized data systems and protocols now
will bolster the entire effort and assists in identifying and managing the local, regional, andnational impacts of human induced climate change, a crowding ocean space with diverse
participants, and a rapidly expanding aquaculture sector.
We congratulate you and your team for this important, timely work and stand ready to leverage
our expertise and position as a respected and neutral convener to assist NOAA Fisheries in
implementing this effort.
Sincerely,

on behalf of the Net Gains Alliance Leadership Team:
George Chmael II
George Lapointe
Katie Latanich
Jill Stevenson
Kate Wing

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

March 31, 2023
NOAA Fisheries
Re: NOAA Fisheries Dra/ Na0onal Seafood Strategy
Submi&ed online via - NOAA Fisheries Dra8 Na9onal Seafood Strategy
I am submi7ng the following comments on behalf of the Oregon Trawl Commission (OTC) on the
NOAA Fisheries DraD NaEonal Seafood Strategy (DraD Strategy). OTC is an industry-funded state
government agency, established in 1963 by the Oregon state legislaEve assembly to support the
Oregon trawl industry and promote its economic viability. Our industry parEcipates in the statemanaged Oregon pink shrimp ﬁshery as well as the federally managed boQom trawl groundﬁsh andthe shorebased paciﬁc whiEng ﬁshery. All three of our ﬁsheries have been cerEﬁed against the
rigorous seafood sustainability standards of the Marine Stewardship Council (MSC).
Commercial ﬁsheries play an important role in the U.S. economy, generaEng substanEal
employment and economic value for a mulEtude of businesses, including ﬁshing operaEons,
processing plants, retailers, restaurants, to name a few. Wild ﬁsheries have great potenEal tosupport marine conservaEon iniEaEves and tourism acEviEes, providing important ecological andeconomic beneﬁts to our coastal communiEes. In the context of food security and nutriEon, if
managed sustainably, wild ﬁsheries is the only source of renewable food. In the face of thechanging climate and its increasing impacts to food and agricultural producEon around the globe, itis essenEal we start thinking of the U.S. ﬁsheries and the domesEc ﬁshing/seafood industry as anaEonal resource of strategic importance. We applaud NOAA Fisheries (the Agency) for theireﬀorts that seek to make US seafood a thriving and a more compeEEve industry in the US andglobal markets. We support the development of the NaEonal Seafood Strategy and oﬀer ourrecommendaEons below, speciﬁcally to Goal 1, Goal 3, and Goal 4, as outlined in the DraD Strategy.
We appreciate and fully support comments submiQed by the Responsible Oﬀshore Development
Alliance (RODA) on this topic.

GOAL 1: Sustain or increase sustainable U.S. wild capture produc:on

We are pleased to see that the Agency recognizes the importance of sustaining or increasingsustainable wild catch. While not every ﬁshery can support increased landings, some do like theWest Coast Groundﬁsh ﬁshery, which once achieved, will present a tremendous opportunity forthe industry and consumers.
As we are entering the era of rapid ocean industrializaEon with numerous new compeEng uses ofthe ocean, we are concerned that some of those large-scale developments, speciﬁcally oﬀshore
wind energy, can impact the aQainability of this goal, throwing the long-term viability of thedomesEc seafood industry into quesEon.
Fisheries sciencePublic comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Through its surveys, NOAA Fisheries assesses the status of nearly half a million ﬁshery stocks, 200
marine mammals and over a hundred threatened and endangered species.1 For ﬁsheries, the value
and importance of this data cannot be overstated. For example, the boQom trawl groundﬁshsurvey, which is done collaboraEvely with the west coast ﬁshing industry, fosters a beQer
understanding of the ﬁshery’s dynamics with its 90+ species, helping inform management
decisions and ensuring the ﬁshery is sustainable for this and future generaEons, among otherthings. The data obtained from this survey supports stock assessments - an informaEon that is
criEcally important for se7ng harvest guidelines. In addiEon, this informaEon provides thefoundaEon for the MSC assessments of the status of the ﬁshery resources. Without thisinformaEon, our industry is risking losing the MSC cerEﬁcaEon for its 18 individually cerEﬁed
groundﬁsh species, as it already happened in early 2022 for paciﬁc cod in the west coast
groundﬁsh ﬁshery complex.2
With the rise of compeEng ocean use from oﬀshore wind energy farms, our industry is highly
concerned for the future of the boQom trawl groundﬁsh and acousEc hake surveys on the west
coast as well as with NOAA’s ability to eﬀecEvely miEgate for negaEve impacts from oﬀshore winddevelopment to ﬁshery surveys. As NOAA’s website states, “Oﬀshore wind development canadversely aﬀect NOAA Fisheries’ surveys by precluding access to sampling areas, impac9ng
sta9s9cal design, altering habitats, and interfering with survey opera9ons.” 3 We completely agreewith the RODA’s comments that “Oﬀshore wind, and other poten9al new ocean uses, will result in
conﬂicts for the U.S. ﬁshing industry.”
Fisheries management
NOAA Fisheries can strengthen the industry’s resiliency by exploring alternaEve management
soluEons that help minimize regulatory ﬁnancial burdens to ﬁshery parEcipants. One great
example is the Electronic Monitoring Program in the west coast groundﬁsh ﬁshery. We appreciate
the Agency’s commitment to development of a cost-eﬀecEve alternaEve to human observers forat-sea monitoring while minimizing the cost to the industry and ensuring the integrity ofmonitoring.

GOAL 3: Foster access to domes:c and global markets for the U.S. seafood industry

With the rise of cheap imported seafoods, oDen backed by large markeEng campaigns, US
consumers have turned away from many domesEc seafood products which are oDen sold at ahigher price point. ODen, we are simply not able to compete on price with foreign compeEEon in
our own market because many (if not most) imported seafood products come from countries withless stringent laws and regulaEons if they are enforced at all. Furthermore, some of the major
naEons-suppliers of seafood for American consumers, including China, have implicated themselvesin serious labor violaEons from human rights abuse to forced labor.4 In addiEon, it has been
1 www.ﬁsheries.noaa.gov/feature-story/eﬀorts-mi7gate-impacts-oﬀshore-wind-energy-development-noaa-ﬁsheries-

surveys#:~:text=Oﬀshore%20wind%20development%20can%20adversely,and%20interfering%20with%20survey%20opera7ons.

2www.cert.msc.org/FileLoader/FileLinkDownload.asmx/GetFile?encryptedKey=MKIMbbJ5W7uDGXq6Bwg2BaF75a5XxpxQ3WjxEqOy

iQrZ91GbX8+iZWZﬀ+E2xOdf

3 www.ﬁsheries.noaa.gov/feature-story/eﬀorts-mi7gate-impacts-oﬀshore-wind-energy-development-noaa-ﬁsheries-

surveys#:~:text=Oﬀshore%20wind%20development%20can%20adversely,and%20interfering%20with%20survey%20opera7ons.

4 www.china.usembassy-china.org.cn/report-to-congress-human-traﬃcking-in-the-seafood-supply-chain/Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

established that labor violaEons can oDen be linked to Illegal, Unreported, Unregulated (IUU)
ﬁshing.5 With all of that in mind, it is reasonable to assume that the lack of the level playing ﬁeld
for sustainable U.S. seafood is, perhaps, due to the fact that it may be compeEng with products
produced with free labor and/or harvested in IUU ﬁsheries, both of which would undoubtedly help
keep their costs excepEonally low. Increasing presence of cheap imported seafood is creaEng asigniﬁcant ﬁnancial pressure on the domesEc seafood industry. Lower prices mean there is lessincenEve to innovate and provide premium seafood oﬀerings, resulEng in decreased margins andopportuniEes for domesEc producers.
For the Oregon trawl ﬁsheries, this goal is highly important. While we produce some of the mostsustainable seafood products, eﬀecEvely accessing domesEc and internaEonal markets for our
products remains to be a challenge, requiring commitment of substanEal resources our industry
does not have.
PrioriEze educaEon
NOAA Fisheries should prioriEze educaEon of both consumers and buyers about sustainable U.S.
seafood, and what makes it a superior product as it relates to (a) sustainability, (b) food safety, (c)product quality and (d) labor pracEces. It is important that the American consumer understands
the value domesEc seafood products bring to their dining table, and how it beneﬁts their healthand health of our beloved oceans and ﬁshing communiEes. The Agency should work with theindustry and other stakeholders (e.g. Sea Grant) to develop the framework, messaging anddetermine modes of disseminaEon of informaEon.
Establish NaEonal Seafood Council
In 2020, NOAA’s Marine Fisheries Advisory CommiQee (MAFAC) produced a report with therecommendaEons to establish a NaEonal Seafood Council authorized under the Fish and Seafood
PromoEon Act of 1986.6 We support the recommendaEons made in their report and ask the
Agency to establish the NaEonal Seafood Council for the beneﬁt of the domesEc ﬁshing/seafoodindustry. The mission of the Council should include goals of (a) increasing awareness for domesEc
seafood with US consumer and (b) increasing demand for U.S. seafood in the domesEc and global
markets. The fact that so many Americans choose imported seafood of likely inferior quality andpossibly produced with unethical pracEces underscores the importance of consumer educaEonand building greater awareness for healthy sustainable seafood produced in the U.S.. Both goals
are also supported by the most recent USDA dietary guidelines which reveal that Americans of allages need to eat more seafood to meet their nutriEonal needs.7

To support those goals, the Council should employ non-branded markeEng and promoEon
campaigns as well as engage in research acEviEes, among other. As MAFAC’s report states suchCouncil can be established in the same way as other commodity boards operaEng under theoversight of the U.S. Department of Agriculture (USDA). NOAA Fisheries should work closely with
USDA to leverage their experEse in dealing with commodity boards which can be an eﬀecEve toolin elevaEng consumer awareness and providing much-needed sales boost to commodity industries.
5 www.nature.com/ar7cles/s41467-022-28916-2

6 www.media.ﬁsheries.noaa.gov/dam-migra7on/mafac_report_establishing_a_na7onal_seafood_council.pdf

7

www.dietaryguidelines.gov/sites/default/ﬁles/2021-03/Dietary_Guidelines_for_Americans-2020-2025.pdf

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Think “Got milk?” campaign with numerous celebriEes rocking a milk mustache in the 90s, which
helped the American dairy industry “re-brand” itself with the American consumer and, more
importantly, helped increase the sales of milk in subsequent years.8

GOAL 4: Strengthen the en:re U.S. seafood sector

The Agency should explore opEons to expand funding opportuniEes for the domesEcﬁshing/seafood industry and their projects.
Saltonstall-Kennedy (SK) grant
A highly compeEEve grant, SK is a primary funding source available for the industry with roughly$10 million distributed among 40 projects each year.9 NOAA Fisheries should advocate for the needto boost the funding available under this grant both in terms of the total amount allocated to the
grant and the maximum amount allowed per grant recipient, which is currently capped at$300,000 per applicant. While this amount is generous, there is no guarantee an applicant would
be able to secure funds more than once, in which case, $300,000 is hardly enough for projects
involving markeEng and promoEon acEviEes.
Developing other grant opportuniEes
NOAA Fisheries should pursue greater collaboraEon with USDA on quesEons of expanding exisEng
funding opportuniEes currently available for land-based food and agricultural products to also
include wild capture seafood. Because seafood is not under the purview of USDA, it may beprioriEzed not as much as other products under the USDA’s jurisdicEon for USDA funding
opportuniEes. NOAA Fisheries should advocate with USDA to recognize seafood as an importantcomponent of the U.S. food system and allow it the same beneﬁts other food and agricultural
products enjoy.

To conclude, we believe within this iniEaEve, NOAA Fisheries has a unique opportunity to help U.S.
ﬁshing/seafood industry re-posiEon itself in the domesEc and global markets as the best choiceseafood and help it realize its full economic potenEal. Not only the US produces the mostsustainable seafood in the world, it does so against the stringent product quality and food safety
standards and requirements, making U.S. seafood the most sustainable and safest choice.
Thank you for your consideraEon of our comments on this important topic. Please feel free tocontact me with any quesEons at yelena@ortrawl.org.
Sincerely,

Yelena Nowak
ExecuEve Director, Oregon Trawl Commission
8 www.civileats.com/2022/03/01/as-a-na7onal-seafood-council-takes-shape-whose-interests-will-it-serve/
9 www.ﬁsheries.noaa.gov/grant/saltonstall-kennedy-grant-compe77on

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

NOAA Fisheries
1315 East-West Highway
Silver Spring, MD 20910
Re: Finless Food’s Response to NOAA’s National Seafood Strategy
To whom it may concern,
Finless Foods appreciates the opportunity to offer comments on NOAA’s National Seafood
Strategy. Finless Foods is a plant-based and cell-cultured seafood company with a mission tocreate a future for seafood where the ocean thrives. We use groundbreaking technology to
revolutionize the way the world sources seafood.
We believe that cell-cultured seafood (seafood produced by culturing animal cells in vitro)should be an integral component when shaping priorities for sustainable seafood, ocean health,and climate-resilient food systems and supply chains. We need an “all of the above” approach toensure we are meeting consumer demands for healthy sustainable seafood. Research anddevelopment are underway by Finless Foods and other cell-cultured seafood companies to create
this additional sustainable seafood option. But in order for us to make an effective impact, thefederal government must also promote cell-cultured seafood. This is why we at Finless Foods
believe that cell-cultured seafood should be included alongside sustainable wild-caught andfarmed seafood in NOAA’s National Seafood Strategy, to support a thriving domestic U.S.
seafood economy and enhance the resilience of the seafood sector in the face of climate change
and other stressors.
One of the three Draft National Seafood Strategy drivers states that Seafood is critical toproviding food to a growing global population. We couldn’t agree more. While attending the
Seafood Expo North America in Boston, Massachusetts on March 12, Finless had a chance tolisten to the NOAA Leadership Update in which Janet Coit stated that wild capture seafood has
plateaued, and that NOAA would be investing more into aquaculture innovation. While we agree
that additional funds should be invested in aquaculture, we also believe that cell-cultured seafood
production has the ability to become a significant and diversified source of sustainable seafood
for the growing global population. For this reason, we strongly recommend that NOAA include
cell-cultured seafood production into the Draft National Seafood Strategy to ensure a more
resilient, secure, and sustainable seafood production system.
Finless Foods also sees as a strategic path forward for cell-cultured seafood, in conjunction with
its wild-caught and aquaculture counterparts, in Draft National Seafood Strategy Goal 3: Foster
access to domestic and global markets for the U.S. seafood industry, to achieve its threeobjectives:

PO Box 99020, Emeryville, CA 94662

www.finlessfoods.com

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

•

•

•

Communication and Promotion: Cell-cultured seafood production is another method tosustainably and nationally source seafood products that are comparable in taste, texture,and nutrition to the wild-caught and aquaculture counterparts. Therefore, Finless Foods
recommends including cell-cultured seafood in the communication and promotion
strategies for seafood, such as the National Seafood Council.
U.S. Market Development: With the need to increase national seafood production
within the U.S.in support of resilient, sustainable, and secure food systems, Finless Foods
recommends investing in the expansion of cell-cultured seafood production as a strategic
path forward. Currently, the top cell-cultured seafood companies in the world are U.S.
founded, funded, and based. These companies are currently undergoing a rigorous premarket safety approval process with the U.S. FDA. Finless Foods recommends supportand investment into cell-cultured seafood production to further U.S. seafood market
expansion and development.
Fair Trade: Finless Food’s cell-cultured seafood production starts and ends in the U.S.,
and will undergo rigorous traceability, transparency, and labeling requirements. As such,
U.S. cell-cultured seafood would not further contribute to IUU fishing and harmful
fishing practices and more easily lends itself to strengthened traceability andtransparency.

The cell-cultured food industry is poised to not only diversify seafood supply chains, but also toprovide sustainable alternatives to meet growing global demand for seafood. Foreign
governments are aggressively investing in this sector. Singapore is the first country in the world
to bring cell-cultured foods to market. As a country that imports 90 percent of its food, Singapore
is betting on cell-cultured food playing a major role in its goal to produce 30 percent of its fooddomestically by 2030. The Netherlands just invested €60 million and additional €25 million in
financing to build an “ecosystem” for cell cultured technologies that will include an innovationhub, pilot scale-up facility, and education programs. China has made growing the cell cultured
technology sector a priority in its five-year plan. The U.S. has long been a leader in technologicaladvances in food and it is essential that the U.S. is not left behind as other nations drive
investment in innovation in this space. As a country that imports 75-80 percent of its seafood, theU.S. needs to capitalize on U.S. cell-culture seafood as a priority for American competitiveness,an increase in jobs, and to help shift us away from foreign reliance on seafood.
The Biden Administration has already recognized the cell-cultured food industry as a cuttingedge climate solution. We were so pleased to see the September 12, 2022, Executive Order tocoordinate a whole-of-government approach to advance biotechnology and biomanufacturing
towards innovative solutions in climate change, food security, and supply chain resilience, which
specifically called out cell-cultured foods and represents a recognition of the importance of thisindustry for the country. On March 22, 2023, the Biden Administration doubled down onprioritizing this field by setting Bold Goals and Priorities to advance cell-cultured foods. In
addition, The Food and Drug Administration (FDA) provided preliminary approval to cellPO Box 99020, Emeryville, CA 94662

www.finlessfoods.com

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

cultured chicken produced by Upside Foods and GOOD Meat, indicating many others may beclose behind. Just like the whole-of-government approach to ensuring U.S. competitiveness in
the global bioeconomy, we need a whole-of-economy approach to supporting a thriving domestic
U.S. seafood economy.
We respectfully recommend that NOAA articulate a vision for the future of U.S. seafood that
includes cell-cultured seafood all while supporting our fishermen, coastal communities, andocean as part of the National Seafood Strategy.
Sincerely,
Shannon Cosentino-Roush
Chief Strategy Officer
Finless Foods

PO Box 99020, Emeryville, CA 94662

www.finlessfoods.com

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

LCN Listening Session - Draft National
Seafood Strategy
Mar 6, 2023
Note taker: Sahir Advani, UMaine
TRIGGER QUESTIONS
1. Input on the content of the draft National Seafood Strategy
A. From your perspective, does the draft strategy capture what is important to you?
B. What else do you want to see/What is missing?
C. What would strengthen the strategy?
2. Feedback on what to include in a future implementation plan
A. Do you have recommendations on what actions to prioritize within each element of thestrategy?
B. How can the agency engage with small-scale and community-based entities in theimplementation phase?
1:08 PM: 28 participants
1:15: 31 participants.
Mike Rubino:
20 years of combatting overfishing, but there are still issues.
Covid disrupted seafood markets
Climate change continues to affect thng
What can NOAA do to increase resiliency?
This draft strategy is the result of these conversations as well as roundtable discussions hosted
by Janet Coit.
This strategy is one of several strategies developed by the agency. Other egs include climatechange strategy, aquaculture strategy, equity and diversity, etc. All these strategies intersectwith one another and fit in with NOAA’s 5 year priorities.
Sarah Shoffler: We really appreciate you taking the time to provide us with feedback. Our
agency doesnt have a history of many of these things and this is an opportunity for the agency
to explore these dimensions.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Larry Collins - 40 yrs in the seafood industry. Tuna, crab, rock cod, halibut. In 2011 they
opened a co-op in pier 45 in San Francisco. 25 boats supplying. 3 things are needed - access,infrastructure, and markets. They haven't had a fuel dock in SF for many years, trucks bring infuel. Ice machines are old.
The first thing to work on is access in California. Salmon includes habitat considerations - rivers
count as salmon habitats and they run dry. Issues with fisheries closures.
Money from a lot more fish hitting that dock will take care of the money for that ice machine.
We’re slipping away from Magnuson(-Stevens Act). We’re supposed to be employing as many
people as possible under Magnuson(-Stevens Act). But we’re not doing that.

Andrea Tomlinson: New England. Access an issue. We’re at 10% of the ground fishing
population. Access and capital requirement necessary to get from deck to wheelhouse is a big
challenge.
I would love for NOAA to be really aware of that access issue to be linked to capitalrequirements. Requests NOAA - Budget line a first time federal permit holder subsidy.
Increasing funding for organizations that support advancement in fleet. More funding towards
small and medium-sized fishing organizations would help support the movement towards this.
Straight line funding without grant applications would be awesome!

Jim Kendall: 3 points about ability. impacts the industry in different ways. 1. Sustainability Wind farms may affect fishing opportunities.
2. Manageability: Councils need to be able to adapt to the conditions we’re seeing out there - interms of climate change, wind farms etc. It’s slow to move these things.
3. Marketability: We have to be able to market our own products. Imports killing us. Shrimp
imports have driven prices down.

Jon Russell: Cool to see this strategy - kudos for getting the wheel rolling on this.
Potential missing point: Naming the role of consumers into this. Access to consumers is alsosuper important. The more people who are in the culture of wanting seafood, the more people
we have entering at various points in the supply chain.
A necessity in the strategy is to remove some of the top-down layers in the implementation ofthis strategy. NOAA alone is not going to have the diversity of knowledge and connections tocommunities. Crowdsourcing with community leaders who can be liaisons to help with theimplementation of the strategy would be great.

Maria Steyaart: Hook and line fisher SE Alaska - sell seafood in Vermont. Some things missing
is a consideration of bringing fishermen into these plans, supported by funding. Funding funding
funding. Food resiliency - so grateful that Petersburg, AK provides a community cold storage.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

What’s missing is an ice chute. If you want food resiliency and less fishing, provide support tofishers to make more money for their fish. Support marketing and then they don’t have to catchas much due to the better price per pound. Land ag is 20 years ahead in terms of funding
support for farmers.

Michael Rubino: Funding to the agency is fairly constant, but doesn't account for inflation.
NMFS is strapped for funding. USDA gets a lot more. We can help find other pots of money.
Deborah Granger: We represent a group of 140 members in the working waterfront in
Bellingham. Members want to upgrade their diesel engines, but there's no funding. Diesel
Emissions Reduction Act (DERA), is available to tribes and tug boats, but they can’t access it asyet.
Jim Kendall: The wind companies may be a pot of funding to look towards - particularly in lightof how they’ll affect fishing. Use it wisely.
Greening of the industry - the MA fishermens partnership is helping upgrade vessels. Money ismore for the study in terms of how they’re going to do it.
Les Brown: How is this strategy any different from stuff done in the past?
Michael Rubino: This is a new initiative. Some of these extraordinary stressors like covid andclimate change have been a wake-up call for the agency. The areas where NMFS can work withindustry are all there, but we’d like to focus on working with people and the supply chain sector
could help in the long term.
Kate Masury: Highlight the importance of the small and midsize seafood businesses - thesebusinesses really increase access to seafood. These small businesses are better able to adapt
to climate-change fisheries targets. If we want to increase access, we need to understand whichmarkets help link food desserts to seafood. New opportunities are on the horizon.
Bailey Bowden: Down East Maine. He’s involved with river herring and whiting. Habitat loss man-made dams affect the source of these fish that are so imp. To ecosystem. What have wedone to the chemical composition of the water by damming these systems?
Aquaculture: it's a big push in Maine. Lots of oyster aquaculture. They weren’t here earlier, but
are now surviving and reproducing. Shores littered with feral oysters. They’re showing up in
scallop beds and are affecting a lucrative fishery. Shouldn’t give up the needs of the many forthe profit of the few.
In chat: Melissa Mahoney: In case you don’t get to me, I also wanted to speak to Aquaculture
policy aimed at increasing production. There is a perceived/real conflict between wild capture
and fish farming, so this strategy should include ways to minimize conflicts/spatial and otherwise
between wild/farmed production. Thank you for this meeting.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Amanda Wlaysewski: Custom processor in AK - Direct marketing is great, fishermen do agreat job in connecting folks with seafood and celebrating their catch. One of the biggest
challenges in Bristol Bay is the lack of small custom processors is a huge barrier.
Melissa Mahoney: Exec Dir. Monterey Bay Fisheries Trust -Aquaculture in California is alreadyan economic liability and threatens wild capture fisheries. Can the strategy perceive andmitigate these conflicts? Comment on Goal 3 - they’re working on seafood accessibility. Connect
fishers and food banks. It's become a thing here now. Other communities have done that. The
accessibility for a lot of people in low-income groups to fresh seafood is so imp. Think about
accessibility for all.
Nicolas Gomez: Representing a young fishermen’s association in PR. Comments related towording - fisheries sci wording diminishes the economic and social dynamics. Impacts to local
economy and livelihoods from aquaculture. 4th goal - to strengthen the entire seafood sector pre-harvest stage such as gear shortages also need to be addressed.
Linda Behnken- Sitka AK. Longline fishermen's association - Need for this strategy to support
small and medium scale fisheries. Promotes community resilience and health. Agree with theneed to invest in infrastructure in rural communities. Boatyards, working waterfronts generally,
as well as cold storage capacity, and resilience regionally and locally.
Investment - climate change already affecting. Lower barrier to entry. Help SSF move from one
fishery to the next. Anchoring some of the access to fisheries in communities. Invest in aqua ina way that avoids conflict, coz otherwise we’re working against ourselves. Think of ways todevelop aqua to be complementary, avoid industrialization, and not promote aquaculture rearingof wild capture species that already have viable markets.

Michael Rubino: Over the next couple of months they’ll take in all these comments and may
rephrase. But really need to consider how they’re going to implement this.

From Nicole Wright, Ohio Sea Grant: Is there a way to link this strategy to the separate
aquaculture and fisheries strategic plans NOAA has? Also, regarding language: Great Lakes
fisheries, both wild caught and aquaculture are not directly mentioned and supported by thecurrent wording of the draft.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Re: NOAA’s National Seafood Strategy
To NOAA Fisheries,
FishWise's mission is to sustain ocean ecosystems and the people who depend on them by transforming
global seafood supply chains. We strongly believe that the health of people and ecosystems is
inextricably linked and work to implement a holistic approach to sustainability in pursuing our mission. We
focus on markets as the key lever of change through direct engagement with companies, participation in
pre-competitive forums, and collaboration with the government. Our consultative approach stems from18+ years of experience in seafood supply chain engagement, and our expertise is trusted by humanrights groups, conservation organizations, seafood buyers and suppliers, and government representatives
alike.
We are excited to see NOAA’s new strategy for supporting the domestic seafood sector and think the four
strategic goals are a great start to address the critical challenges (nicely outlined by NOAA) facing the US
seafood sector. There are key topics, however, that are not addressed either explicitly or in enough detail
within this draft.
We believe the below topics, whether incorporated within the four relevant Goals or specifically during theStrategy Implementation, would greatly support NOAA’s National Seafood Strategy and overall purpose.
●

Alignment with existing initiatives○ The seafood sector as a whole is at an inflection point, with many end buyers andmid-supply companies' sustainability commitments coming to an end or primed forrevision. The industry and supporting NGOs are working to increase alignment andleverage existing international frameworks to help organize and communicate
sustainability work with the public. This is aimed at addressing two challenges
communicated by the industry: the complexity of seafood sustainability and difficultycommunicating the work to the public in an accurate and simplified manner.
○ We suggest aligning or at least internally mapping these Goals to existing initiatives foradded impact and increased efficiencies (eg UN Sustainable Development Goals,
UNGPs on Buisness and Human rights, OECD Due Diligence for Responsible Buisness
Conduct, Conservation Alliance for Seafood Solutions etc).
○ Sourcing US-caught and processed seafood is a great solution to both sustainability andcommunication challenges, but additionally, mapping how US-sourced seafood translates
to global impact will help companies and NGOs alike monitor progress and communicate
benefits to the public.

●

Direct and intentional collaboration with seafood supply chains○ The industry is integral in shaping inclusive policies, and NOAA should strive to include
their experiences, feedback, and suggestions in this strategy and implementation.
Creating a range of pathways for different segments of the supply chain to provide
feedback and ideas is critical for operational success.
○ Once work is underway, communication about final work plans, effective socialization
about resources available to the industry, and transparency into progress against thework plan should occur.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

●

Traceability, verification, and transparency○ Although technology is mentioned, specific mentions of how improved traceability ofseafood, verification of data, and increased transparency across the sector would be
beneficial.
○ Data underpins the majority of sustainability work and is critical for food safety, legality,and business operations. Seafood companies are working hard to implement bestpractices, and US fishery regulations are some of the most stringent, so continuing toencourage traceability and supporting verification efforts by utilizing the data alreadybeing collected by US government will help progress this strategy's goals.
○ For example, ideally, there would also be some mention of supporting technologicaladvances under Goal 1, not just under Goal 4, since technological advances at theharvest level help achieve Goal 1 (and Goal 2).
○ For example, ideally, Goal 3 would also include traceability and or verification.
Strengthening the electronic traceability of the US seafood sectors helps reduce the riskof IUU entering the supply chain, helps increase public trust in US seafood products, andsupports broader FDA food safety initiatives. This could perhaps fit under Goal 4 as well.

●

Improving working conditions and advancing human rights○ There is no mention of how NOAA will work with other government agencies to improve
the seafood sector working conditions and ensure the US industry is free of any labor or
human rights violations. Based on the recent findings in the EU and what is happening inother sectors in the US, this should not be overlooked.
○ In addition to growing and diversifying the seafood workforce, NOAA should also ensurethat the US seafood workforce has access to a safe and healthy workplace. Ensuring thesafety of our workforce shows we value them, and in turn, the industry as a whole will
strengthen and grow.
○ An example of a mental health initiative for seafood workers in New Zealand can befound here.

FishWise is interested in supporting NOAA with the implementation of its new strategy and looks forward
to aligning our work with it to expedite results for the US seafood sector. I thank NOAA for taking
leadership on this important topic, allowing for the opportunity to provide input, and for its work to date.
Sincerely,
Michelle Beritzhoff-Law
Sr Project Director
FishWisePublic comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

March 30, 2023
Ms. Janet Coit
Assistant Administrator for Fisheries
NOAA Fisheries
1315 East West Highway
Silver Spring, MD 20910

Dear Asst. Administrator Coit,
Thank you for this opportunity to provide feedback on the Draft National Seafood Strategy
announced by NOAA Fisheries on February 14th, 2023. We are excited to see an open
conversation taking place that considers how we can build out our national seafood systems ina way that is good for the people and the planet while also being economically viable. NAMA is
led by fishermen and coastal community members across the country who share this sentimentand work to ensure these systems remain beneficial for the coastal communities associatedwith them.

PurposeThe purpose laid out for this seafood strategy aligns with NAMA’s mission and the work wesupport through our active and engaged network of fishing folks. Wherever possible, NAMA
seeks to highlight stand-out seafood operations to raise the collective skillset of our network,build deeper relationships among small- and medium-scale producers of sustainable seafood,and learn directly from those with on-the-water knowledge in how values-driven seafood
systems can be built and moved forward. We rely on these relationships to have a good pulseon the health of the oceans and coastal communities.
As the concept of ‘sustainability’ has gained prominence in mainstream food production andamong policymakers, the term itself has, in some cases, lost its grounding in small-scale,
localized production. Discussions around sustainability are often difficult in these spaces
because the sustainability of any two fisheries can require extremely different tools, people,
knowledge, etc. NAMA strongly believes that a broad network of communities who are
intimately familiar with and dependent on any given fishery is required for impactfulenvironmental restoration and protection. Any strategy aiming to sustainably grow our fishingcommunities must be as wide-reaching and diverse as the fisheries themselves.

StrategyThis strategy is driven by the truth that seafood is good for people, the planet, and the economy
is great, but as with anything healthy, the mismanagement of it can cause it to not only lose its
health benefits, but become something harmful altogether. Fortunately, we have many historicalparallels to draw from. If we look at the growth of agriculture, we can see that a shift away from
North American Marine Alliance - 222 Main Street - Gloucester, MA 01930 - Tel 978-865-3178 - www.namanet.org

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

community-based and regional food systems created troves of problems to our domestic
agriculture. We want to ensure that any strategy moving forward is supportive of a seafood
system that will be good for all people, good for the planet in the long-term, and creating an
economy that supports a living wage for everyone in the supply chain, not just record profits atthe top of the chain.
Currently the strategy fails to acknowledge that there are active policies in place driving ourseafood to not meet the very goals that are named. It is one thing to build and promote seafood
operations that meet these goals and foster the healthy future we all want. Equally important is
to address policies that have been a detriment to our communities, environment, and economy.
Offshore aquaculture is proven by many different entities globally to be incredibly harmful to theocean and operates at a scale that only benefits massive corporations who are far from needing
any extra economic support.1 Additionally, the commodification of permits under the catch sharesystem is continuing threaten the livelihoods of small-boat fisherman while allowing international
private equity firms to consolidate these permits as a form of long-term investment. This ismaking it nearly impossible for coastal communities to access fishing rights and it is taking
massive amounts of wealth away from them and the country altogether. 2 Attempts to challenge
this consolidation at Regional Fishery Management Councils are often thwarted due to thereality that the companies with the most resources can most easily maneuver through thesecouncil meetings and heavily skew decision-making in their favor.3

A Community-Informed Just Strategy
Ultimately, what will truly strengthen our seafood sector is a seafood strategy that is grounded infinding key allies across the country who can speak to their community’s issues and advocate
for the people who will be the most impacted. Currently there needs to be acknowledgement ofsystems and policies that are not working for small- and medium-scale fishermen and coastal
communities. Once that has been named, steps should be taken to meaningfully connect withthe people who can represent the communities most impacted and bring them in to help shape
the core of any strategy moving forward.
Conclusion and Gratitude
We have a lot of appreciation for the opportunity to provide feedback to this seafood strategy.
There are so many people in fishing communities who are excited and determined to ensure ourseafood is sustainable, both environmentally and economically, and we hope that is heard
loudly through all the comments.
Sincerely,
North American Marine Alliance

1: “The Foodprint of Farmed Seafood.” FoodPrint, GRACE Communications, 19 Oct. 2020, https://foodprint.org/reports/the-foodprint-offarmed-seafood/#section_4.
2: Sennott, Will. “How Foreign Private Equity Hooked New England's Fishing Industry.” ProPublica, 6 July 2022,
https://www.propublica.org/article/fishing-new-bedford-private-equity.
3: Touchstone Consulting Group. 2011. A Review of the New England Fishery Management Process. Report to NMFS April 2011

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Thank you for the opportunity to comment on the National Seafood Strategy. It is critical time for the
US domestic fishing industry.

Boutique fisheries, low trip limits, years to fish increased quotas, step downs for precautionary
measures, imbalanced councils, recreational discards, low quotas, re-allocations, shrimp boats tied to
docks because domestic shrimp is becoming very hard to sell against the flood of imports, loss of
infrastructure for the domestic fleet, incorrect information being distributed by special interest groups
villainizing the domestic fisheries, commercial fishing boats being sold out of the country to participate
in foreign countries fisheries that then will import to the US…..these practices are succeeding in
destroying the small fishing industry and infrastructure that remains.

Goal #1 will not be met unless the councils are balanced with council members that are experienced andknowledgeable in the fisheries. There must be balanced representation representing commercial fishingand the non-boating seafood consumer. Uncertainty buffers need to be addressed to maximize optimal
yield. Fishery data and decisions made regarding the data need to be implemented much quicker.
Correct and current information for economic data should be used-exvessel price should not be thebenchmark for a commercially landed product.

A major goal under #3 would be to create an equal playing field for domestic seafood and imports. Thisis critical for the food security in the US. It would be a huge step in becoming independent of foreigncountries food for US citizens. We saw this issue during COVID. Also under this goal, NOAA should bepromoting the sustainability of our fisheries and participating in letting the public know when false
information is being distributed. Special interest groups have been given the liberty to spreadmisinformation regarding the US fishing fleet. Any product harvested under MSA should be certified
sustainable by NOAA.

Goal #4 will not be met as long as boats are leaving the fisheries and docks are being sold for other uses.
Once the infrastructure is gone, it will be very hard to bring it back. We have witnessed this down
through the years-and the downsizing continues. It has become harder and harder to make a profit inthis business.

I have great hope that the National Seafood Strategy will stabilize and re-vitalize the commercial fishingindustry, put more domestic product on consumer’s plates, and the seafood consumer will be welleducated so they can make wise food choices while becoming more independent of imported food.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Janet Coit
Assistant Administrator
National Oceanic and Atmospheric Administration
National Marine Fisheries Service1325 East-West Highway
Silver Spring, MD 20910
March 31, 2023
Dear Administrator Coit,
The undersigned individuals and entities are members and representatives of the U.S.
commercial fishing industry, a category that includes vessel owners, captains, crewmembers,
port associations, and seafood businesses.
Although we hail from diverse ports and participate in many different fisheries, we are united byour shared support of fishery friendly climate action that simultaneously reduces, sequesters, oravoids GHG emissions at scales sufficient to hold warming well below 2°C (while pursuingefforts to limit warming to 1.5°C), while also:● Avoiding collateral impacts on ocean, coastal, estuarine, and watershed environments;● Avoiding interference with the harvest and provision of wild seafood for the public;● Contributing conservation co-benefits that enhance the resilience of these ecosystems
to climate change and other stressors; and/or● Facilitating the voluntary adoption of cost-effective, locally appropriate technologies
and practices to reduce fuel use and greenhouse gas emissions by fishing vessels andshoreside businesses.
We submit this letter in response to NOAA’s solicitation for public comment on its draft
National Seafood Strategy. Many of the undersigned have submitted additional responses to thiscall, and this letter neither supersedes, affirms, nor contradicts those other letters. Instead, its
purpose is to lend additional emphasis and guidance to the critical and timely topic of ensuringthat the NOAA National Seafood Strategy supports climate action that works for U.S. fisheries
and not at their expense.
In this letter, we focus our comments on the first and fourth focal areas in the draft Strategy,
namely “sustain or increase sustainable U.S. wild capture production” and “strengthen the entire
U.S. seafood sector.” As the draft correctly points out, both climate change and many oceanbased climate solutions represent drivers of unprecedented disruption to the U.S. fishing andseafood system. The draft also points out that seafood itself is a relatively low-carbon source ofprotein that offers particular promise in the context of food systems designed to reduce andmitigate the effects of climate change. Furthermore, the draft highlights the importance ofthemes such as: strengthening habitat conservation in support of fisheries; modernizing seafood
infrastructure (e.g., vessels, port and dock facilities, working waterfronts); and fostering a
growing and diverse seafood workforce.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Building on these themes, we outline below two priorities that should be considered in NOAA’s
National Seafood Strategy.
1. Illuminate a road to net-zero emissions that is “fishery friendly.”The years 2021-2022 marked a turning point in the U.S.’ commitment to addressing its
contribution to the crisis of global climate change, with the White House and Congress signaling
unprecedented ambition through domestic reinstatement of the Paris Agreement’s internationallyembraced greenhouse gas reduction goals and the passage of two groundbreaking pieces ofclimate legislation: the Inflation Reduction Act and Bipartisan Infrastructure Law.
While these steps are commendable and necessary, it is not enough to ensure that our nation’s
ecosystems and wild places are spared the worst effects of climate change. An equally important
step, which the federal government has yet to take, is to ensure that these ecosystems are also
protected from potentially harmful impacts of some of the technologies and approaches that arelikely to be deployed in the march towards net-zero.
In the context of the National Seafood Strategy, the ecosystems that produce wild seafood may
experience negative impacts from rapid development of industrial offshore wind, deployment ofrisky forms of marine carbon dioxide removal, escalated levels of extraction of copper andcritical minerals in sensitive watersheds, irresponsible forest removal for energy development or
biofuel production, large-scale hydroelectric power, and assorted other decarbonization strategies
that, especially when done hastily and without care, may impact the marine, coastal, andwatershed environments that support U.S. seafood. Conversely, production of wild seafood may
experience positive impacts from some decarbonization solutions, such as farmland and forest
conservation, which can offer win-wins for the climate and ecosystems by improving upstream
water quality while sequestering carbon in soils and long-lived woody biomass.
While NOAA’s direct role in deploying and permitting decarbonization solutions is limited,
NOAA’s expertise in oceans and fisheries make the agency indispensable in bringing to light thepotential negative and positive impacts of proposed decarbonization solutions to fisheryecosystems. NOAA scientists have a unique role to play in sorting “fishery friendly” from“fishery risky” decarbonization solutions and in developing guidelines that would result in theprioritization of “friendly” over “risky” investments, including in the context of investments andactions executed by other federal agencies.
Therefore, the signers of this letter implore NOAA to leverage its expertise at this pivotal time,
and to make a sustained and strenuous effort to support fishery and seafood stakeholders whenworking with other agencies, as well as the White House’s National Climate Task Force,
National Climate Advisory, Office on Clean Energy Innovation and Implementation, and Officeof Science and Technology Policy, in preferentially promoting climate-related investments andactions that avoid negative impacts and promote positive benefits to fishery ecosystems andseafood economies. This approach to stakeholder representation is currently missing from theseafood strategy and the agency’s approach generally, and it is sorely needed.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

To support this role, we ask NOAA to amend the National Seafood Strategy’s Goal #1, as
follows:
Changes in ocean conditions and the resulting shifts in distribution and abundance ofmarine resources, as well as the intensity of damaging storms are affecting access to andproduction of seafood as well as subsistence and Tribal fishing. Meanwhile, the oceans,coasts, and waterways that support U.S. fisheries are increasingly called into action to
support ambitious decarbonization strategies, with the goal of reducing further the U.S.
contribution to global climate change. These factors, in addition to new ocean uses andadvances in sampling technologies and data modernization call for an evolution inscience and management frameworks for a climate-ready seafood sector, including:o Fisheries Science. Provide the science and economic and social analyses
necessary for fisheries management under changing ecosystem dynamics and toproject and assess impacts of decarbonization strategies to fishery ecosystems
and fisheries….
o Habitat Conservation in Support of Fisheries. Protect and restore habitat
important to our nation’s fisheries and support resilient coastal communities,
including from any negative impacts posed by decarbonization strategies tofishery ecosystems and fisheries.
2. Accelerate a transition to a low-carbon fishing fleet by supporting locally led, bottom-up
innovation and planning.
Since the passage of the Inflation Reduction Act (IRA) in August 2022, members of thecommercial fishing industry have submitted at least four letters to various federal agencies,
including NOAA, asking that some portion of the Act’s $369 billion for decarbonization
programs be apportioned to support a transition to low-carbon fishing vessels. For example:● In a November 2022 letter, 190 associations, individuals, and businesses (facilitated by
the North American Marine Alliance) asked NOAA to allocate $100 million of the $2.6
billion that the agency received under the IRA for coastal resilience projects, to support
and/or finance clean energy opportunities for the nation’s small-boat fishing fleet,
including vessel retrofits and electric conversions, pilot projects demonstrating newtechnologies, and outreach and education.
● In a November 2022 letter, 14 associations and 34 individuals and businesses in thefishing industry wrote to the White House Office of Science and Technology on thecreation of an Ocean Climate Action Plan, calling for the streamlining of existing federal
programs (e.g., Diesel Emissions Reduction Act) as well as the establishment of new anddiverse dedicated funding streams to support bottom-up planning and innovation.
● In December 2022 letter, 7 fishing industry associations wrote to the Environmental
Protection Agency (EPA) regarding the IRA Greenhouse Gas Reduction Fund (which
allocates $27 billion for competitive grants for the provision of financial and technicalassistance to projects that reduce or avoid greenhouse gas emissions and other forms of
air pollution) asking the agency to design the program in such a way that funds might beavailable to fishing vessels and shoreside operators for investments in greenhouse gas
reduction activities on board fishing vessels and in fishing ports;

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

● In a January 2023 letter, 14 associations and 35 individuals and businesses in the fishingindustry submitted a letter to the EPA regarding the IRA Clean Ports Program (which
allocates $3 billion to provide grants related to reducing air pollution at ports) asking theagency to set aside ten percent of program funds, or $300 million, for investments in US
fishing and seafood facilities, vessels, and related working waterfront infrastructure inports across the nation.

These letters also urged the EPA and NOAA to ensure that commercial fishing is given an
opportunity to participate in emissions reductions initiatives through goals including creative
approaches to financing, bottom-up incentives, and robust engagement based on common
understanding and objective sharing. Additionally, the letters noted that due to the diverse
characteristics of fishing ports, the best mix of low- and zero-emissions technologies will not beuniversal, and consequently, planning and investment must be locally led and tailored to theunique uses, challenges, and opportunities found in each port.
Furthermore, these letters stressed the fact that application of high-efficiency and zero-emissions
technologies on fishing vessels in the U.S. is currently at a pilot stage, and technologies areprohibitively expensive. As a result, wraparound support is needed to launch more pilot
programs, develop fisherman-led educational exchanges to vet and build confidence in newtechnologies, work with port managers and energy systems experts to design linked vessel-port
decarbonization plans, and then ultimately, to bring the costs of zero-emissions technologies
down to a level that is competitive with diesel engines via grants, tax incentives, and/or otherfinancial mechanisms.
The White House’s Ocean Climate Action Plan (OCAP), published in March 2023, integrates
these recommendations in part, by recommending that NOAA work with the Departments ofEnergy (DOE) and Transportation (DOT) in the next 6-12 months to conduct scoping on
opportunities related to fishing fleet decarbonization, and to explore the potential expansion ofexisting (or the creation of new) funding programs to support this transition. Although the OCAP
recommendation on fishing fleet decarbonization is fairly cursory and technologically limited
when contrasted with the OCAP’s expansive three-page section on green ports and shipping,signers of this letter are broadly supportive of this goal and stand ready to offer our assistance. In
fact, many of us are already collaborating on a bicoastal, fishing industry-led scoping projectcalled “Accelerating a Transition to a Low Carbon Fishing Fleet,” with an estimated publication
date of November 2023. More information may be found athttps://www.fisheryfriendlyclimateaction.org/projects
The need to accelerate a transition to a low-carbon fishing fleet intersects with two elements of
the National Seafood Strategy: Goal #1’s emphasis on the impacts of greenhouse gas emissions
to seafood ecosystems and Goal #4’s emphasis on modernizing seafood infrastructure andfostering a resilient seafood and fishing workforce. Therefore, we encourage NOAA to elevatethe priorities articulated by the fishing industry in this and previous letters by amending thesecond bullet point under Goal #4 of the National Seafood Strategy, as follows:
Seafood Infrastructure. Work across federal agencies to modernize U.S. seafood
infrastructure (e.g., vessels, hatcheries, port and dock facilities, processing, storage,

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

working waterfronts) to strengthen and enhance opportunities for coastal seafoodcommunities and regional food economies and to promote locally led, cost-effective
opportunities to pursue low-carbon innovation in the fishing and seafood sectors.
Conclusion
As the National Seafood Strategy moves towards completion and then implementation, we
encourage NOAA to work with fishery stakeholders to advance fishery friendly climate action
by communicating and coordinating through the Fishery Friendly Climate Action campaign, anational network that convenes fishing businesses, fishermen, and seafood-related businesses topromote fishery friendly climate action at all levels through coordination, information sharing,and communications support. More information is available at fisheryfriendlyclimateaction.org.
We invite NOAA to coordinate and communicate with fishery stakeholders through theinfrastructure provided by the Fishery Friendly Climate Action campaign, in order to jointly
advance fishery friendly pathways to reaching net-zero targets, including but not limited to theadoption of low- and zero-carbon technologies and practices within our own industry.
NOAA leadership can enhance coordination and communication for these purposes by updating
the Seafood Strategy so that it is easier to establish partnerships between NOAA andorganizations/businesses that achieve the following goals and objectives:
1. Facilitating interagency coordination, i.e., with NOAA line offices and other federal agencies,
and support and encourage coordination efforts with other federal agencies and entities,
including the Environmental Protection Agency, Department of Agriculture, relevant WhiteHouse offices, and others where appropriate.
2. Assisting with interagency coordination through the National Climate Task Force, and otherrelevant interagency bodies as appropriate.
3. Facilitating and supporting data sharing and analysis with fishing communities in support offishing community supported efforts to promote fishery friendly climate action.
4. Contributing appropriate federal resources and subject matter expertise to support these
efforts.
Thank you for the opportunity to provide comment. Responses to this letter may be sent on ourbehalf to Sarah Schumann, coordinator of the Fishery Friendly Climate Action campaign, at
shiningseaconsulting@gmail.com.
Sincerely,
Pete Granger
Vice-President
Working Waterfront Coalition of Whatcom County
Bellingham, WAPublic comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Angela Sanfilippo
Executive Director
Massachusetts Fishermen’s Partnership
Gloucester, MA
Linda Behnken
Director,
Alaska Longline Fishermen’s Association
Sitka, AK
Andrea Tomlinson
Executive Director
New England Young Fishermen’s Alliance
Glen Spain, J.D.
Acting Executive Director
Pacific Coast Federation ofFishermen’s Associations (PCFFA)San Francisco, CA
Fred Mattera
Executive Director
Commercial Fisheries Center of Rhode Island
Wakefield, RI
Joel Kawahara
President
Coastal Trollers Association
Auburn, WA
Frank Mirarchi
Treasurer
XII Northeast Fishery Sector, Inc.
Scituate, MA
Melissa MahoneyExecutive Director
Monterey Bay Fisheries Trust
Santa Cruz, CA
Angela Sanfilippo
President
Gloucester Fishermen’s Wives Association
Gloucester, MA

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Aubrey Ellertson Church
Policy Manager
Cape Cod Commercial Fishermen’s Alliance
Chatham, MA
Eric Jordan
F/V I GOTTA
I Gotta Salmon
Sitka, AK
Vince Mortillaro
President
Mortillaro Lobster
Gloucester, MA
Kent Barkhau
Managing Director
Woodstock Fisheries LLC
Sitka, AK
Richard Nelson
Commercial fisherman, retired
Friendship, ME
Mark Chandler
President
Chandler Fisheries Inc.
Kodiak, AK
Jim Kendall
Owner
New Bedford Seafood Consulting
New Bedford, MA
Tav Ammu
F/V Sea La Vie
Dillingham, AK
Sarah Schumann
Crewmember, various vessels
Point Judith, RI & Bristol Bay, AK
Amy Grondin
Co-Owner
Duna Fisheries
Port Townsend, WAPublic comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Greg Friedrichs
Commercial Fisherman
F/V Arminta
Port Townsend, WA
Jackson Combs
Icy Cape Seafoods, LLC
Hoonah, AK
Robert Nagle
Vice President of Operations
John Nagle Co.
Boston, MA
Shirley Zuanich
Pure Alaska Salmon Co LLC
Bellingham, WA
Jeff Farvour
Owner Operator F/V Apollo
Sitka, AK
Aaron Longton
F/V Goldeneye
Port Orford, OR
Gerry O’ Neill
President
Cape Seafoods Inc.
Gloucester, MA
Gerry O’Neill
Director
F/V Challenger
F/V Endeavour
Gloucester, MA
Kevin Scribner
Forever Wild Seafood
Walla Walla, WA
James Moore
F/V Aljac
Sitka, AKPublic comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Michael Kohan
Science and Policy Director
Sitka Salmon Shares
Juneau, AK
Bob Morris
F/V Living Waters
Bristol, RI
Larry Collins
F/V Autumn Gale
President
San Francisco Community Fishing Association
San Francisco, CA
Jennifer Custer
F/V Miss Kathleen
Westport, WA
Todd Goodell and Susan McHugh
F/V Kingfisher
Martha's Vineyard, MA
Lindsey Bloom
F/V Rainy Dawn
Juneau, AK
Joshua Mims
F/V Shadow
Crescent City, CA
Tim Rovinelli
F/V P.O.S.
Providence, RI

Southeast Alaska Fishermen’s Alliance

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

1008 Fish Creek Rd
March

Juneau, AK 99801
Fax: 907-917-5470

Website: http://www.seafa.org

March 16, 2023

The Honorable Richard Spinrad, Ph.D
Administrator, National Oceanic and Atmospheric Administration
1401 Constitution Avenue NW
Washington, DC 20230

RE: Comments on Draft National Seafood Strategy
Southeast Alaska Fishermen’s Alliance appreciates the opportunity to comment on the draft
National Seafood Strategy. Overall, the strategy appears to touch on many of the issues webelieve are important, but it is a high level look at the priorities and goals. What NOAA/NMFS
actually puts in the implementation plan for specific actions, timelines and milestones, final
comments may result in different comments. To that end, we would request a second
comment period after the implementation plan is drafted and before being adopted. We areproviding some comments for consideration in developing more detailed aspects of the plan.
Southeast Alaska Fishermen’s Alliance (SEAFA) is a non-profit multi-gear, small boat commercial
fishing association representing our 330 members involved in the salmon, crab, shrimp andlongline fisheries mainly in Southeast Alaska.
SEAFA appreciates that U.S. wild capture seafood is highlighted as being responsibly harvested.
SEAFA supports the Purpose statement, Strategy Drivers and Framework of the draft strategy
document. Below are comments on specific goals for consideration.
GOAL 1:
Fisheries Science: SEAFA supports maintaining core fishery surveys and increasing where
possible without impacting the core fishery surveys that provides the necessary information forthe sustainable management of the nation’s fishery resources. Climate change and changing
ecosystems dynamics will necessitate additional science resources but this can not come at theexpense of long-term core fishery surveys.
GOAL 2:

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

SEAFA agrees that a gradual, and regionally-appropriate growth of the domestic aquacultureindustry depends upon a science-based regulatory approach. That said, a state needs theability to opt-out of any type of aquaculture that they are not interested in having off theircoast.
Increasing aquaculture opportunities should not come at the expense of U.S. sustainable wild
capture fisheries either by harm to the regional resources through the introduction of
aquaculture nor through competition in the marketplace.
SEAFA opposes the use of genetically modified aquaculture species being introduced into thewaters of the US. Introducing new species is the equivalent of adding an invasive species into
the environment.
GOAL 3:
SEAFA supports increasing domestic knowledge about U.S. sustainable seafood, it’s excellent
nutritional benefits and availability. In addition, NOAA should partner with the U.S. Trade Officeand provide the necessary expertise and awareness to appropriately support U.S. seafood
trade.
GOAL 4:SEAFA would remind NOAA when working on a seafood strategy that they have a wide variety
of seafood harvesters from very small boats to very large factory trawlers and that initiatives
need to be scaled to help all and not a single segment of the industry.
SEAFA would remind you that before adoption of the implementation plan, another comment
period would be beneficial and appropriate.

Sincerely,

Kathy Hansen
Executive Director

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

February 14, 2023/HSWRI Edits March 24 2023

NOAA’s National Seafood Strategy
PurposeThe National Seafood Strategy, outlines our direction for supporting a thriving domestic U.S. seafood economy and enhancing the resilience of theseafood sector in the face of climate change and other stressors. Our vision is to ensure that:● U.S. seafood continues to be produced sustainably● The U.S. seafood sector contributes to the nation’s climate-ready food production and to meeting critical domestic nutritional needs● U.S. seafood production increases to support jobs, the economy, and the competitiveness of the U.S. seafood sector● Supply chains and infrastructure are modernized with more value-added activity in the
United States● Opportunities are expanded for a diverse and growing seafood workforce● Promote a more secure supply of seafood for American consumers

Strategy Drivers
NOAA Fisheries’ National Seafood Strategy supports the growing
importance of seafood in meeting global needs and recognizes theunprecedented challenges faced by the U.S. seafood sector.
Seafood is Good for People
Seafood is one of the best sources of nutrients essential forhuman health and well-being. It is also critical to providing foodto a growing global population.
Seafood is Good for the Economy
The U.S. harvests about 10 billion pounds of seafood annuallywith a dockside value of $6.3 billion. Domestic seafood is also an
economic engine that supports 1.2 million jobs and generates$165 billion in sales across the broader economy.
Seafood is Good for the Planet
Harvested and grown responsibly, as it is in the United States,
seafood is also an environmentally friendly way to produce anutritious food given its relatively low carbon footprint andefficient use of resources, and is increasingly a critical part offood systems designed to reduce and mitigate the effects ofclimate change.

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Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

The U.S. seafood industry is facing unprecedented
challenges.
Climate change is rapidly altering species location, size, andcomposition. It is also intensifying storms and impacts on
infrastructure.
The coronavirus pandemic disrupted markets and trade, decreasing
the economic viability of the seafood industry and limiting access tosome seafood.
New technologies and other ocean uses, such as offshore windenergy, will affect use of ocean space and potentially result in
conflicts.

Significant labor shortages plus
aging harvesting, processing, anddistribution infrastructure affectproduction, safety, and costeffectiveness in the industry.
Commercial fishing cannot
produce all the seafood needed,
and aquaculture has emerged asa global imperative

February 14, 2023

Strategy Framework
The National Seafood Strategy focuses on NOAA Fisheries’ work to sustainably manage
marine fisheries and produce seafood responsibly, based on sound science. It is one of a suiteof strategies that describes how we will support the nation’s fisheries and execute our mission
in the face of climate change, market disruptions, and new ocean uses.
The National Seafood Strategy also allows NOAA Fisheries to address important national
issues such as the resilience of coastal fishing communities; the role that aquaculture must
play in the seafood supply chain; the financial viability of the seafood industry; the effects andopportunities of international trade; and the importance of seafood to nutrition, foodsecurity, food sovereignty, subsistence fishing, and traditional Tribal fishing rights.
To implement the Seafood Strategy, NOAA Fisheries will partner with state and other federal
agencies, the National Sea Grant College Program, Tribes, non-government organizations,fishermen, seafood farmers, and other stakeholders to address the challenges facing theseafood sector, especially when resources are limited.
GOAL 1: Sustain or increase sustainable U.S. wild capture production
Changes in ocean conditions and the resulting shifts in distribution and abundance of marine
resources, as well as the intensity of damaging storms are affecting access to and production ofseafood as well as subsistence and Tribal fishing. These factors, in addition to new ocean uses
and advances in sampling technologies and data modernization call for an evolution in scienceand management frameworks for a climate-ready seafood sector, including:● Fisheries Science. Provide the science and economic and social analyses necessary forfisheries management under changing ecosystem dynamics.
● Fisheries Management. Maximize fishing opportunities and sustainable seafood
production while ensuring the sustainability of fisheries through effective and efficientmanagement. Support the commercial fishing industry and fishing communities in theirefforts to adapt to climate change and thrive in a changing ocean economy.

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Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

● Habitat Conservation in Support of Fisheries. Protect and restore habitat important toour nation’s fisheries and support resilient coastal communities.
February 14, 2023

GOAL 2: Increase sustainable U.S. aquaculture production
Seafood is a healthy and climate-friendly nutrition choice and demand is increasing.
Aquaculture is one of few ways to significantly increase domestic seafood production—it’s how
the majority of growth in demand has been met in the last 20 years. Supporting gradual,
diverse, and regionally-appropriate growth of the domestic industry will depend on an efficient,strategic, and science-based regulatory approach that considers and mitigates impacts onprotected resources, essential fish habitat, and marine ecosystems.
● 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.
GOAL 3: Foster access to domestic and global markets for the U.S. seafoodindustry
A thriving, well-regulated domestic seafood industry—capable of competing at home andabroad—will translate into greater global seafood supply and food security from sustainable
U.S. fisheries. It will also decrease our reliance on foreign fisheries that are at greater risk ofoverfishing, IUU fishing, and forced labor.
● Communication and Promotion. 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 anddevelop U.S. seafood markets and put more U.S. seafood back on U.S. plates● Fair Trade. Promote fair seafood trade by combating IUU fishing and related harmful
fishing practices around the world and by expanding access to foreign markets for U.S.
seafood.
GOAL 4: Strengthen the entire U.S. seafood sector
The COVID-19 market disruptions highlighted systemic challenges to the U.S. seafood industry
and the importance of supporting the entire seafood/fisheries value chain, including after
seafood hits the docks. Addressing these challenges will help the seafood industry to rebuild
more quickly and enable the industry to be more resilient and flexible in the face of potential
future crises and market shocks.
February 14, 2023●

Seafood as a Vital Part of the Blue Economy. Support the U.S. commercial fishing,marine aquaculture, and seafood communities to adapt and thrive in a changing ocean
economy and given new competing uses.
● Seafood Infrastructure. Work across federal agencies to modernize U.S. seafood
infrastructure (e.g., vessels, hatcheries, port and dock facilities, processing, storage,
working waterfronts) to strengthen and enhance opportunities for coastal seafoodcommunities and regional food economies.

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Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

●

Workforce Development. Foster a growing and diverse seafood workforce and attract
young fishermen and seafood farmers to the sector.

Strategy Implementation
Informed by public comment and advice from our partners, NOAA Fisheries will prepare an
implementation plan for the National Seafood Strategy with specific actions, timelines,
partnerships, and milestones.

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Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

February 14, 2023

NOAA’s National Seafood Strategy
PurposeThe National Seafood Strategy, outlines our direction for supporting a thriving domestic U.S.
seafood economy and enhancing the resilience of the seafood sector in the face of climatechange and other stressors. Our vision is to ensure that:● U.S. seafood continues to be produced sustainably● The U.S. seafood sector contributes to the nation’s climate-ready food production andto meeting critical domestic nutritional needs● U.S. seafood production increases to support jobs, the economy, and thecompetitiveness of the U.S. seafood sector● Supply chains and infrastructure are modernized with more value-added activity in the
United States● Opportunities are expanded for a diverse and growing seafood workforce

Strategy Drivers
NOAA Fisheries’ National Seafood Strategy supports the growing
importance of seafood in meeting global needs and recognizes
the unprecedented challenges faced by the U.S. seafood sector.
Seafood is Good for People
Seafood is one of the best sources of nutrients essential forhuman health and well-being. It is also critical to providing foodto a growing global population.
Seafood is Good for the Economy
The U.S. harvests about 10 billion pounds of seafood annuallywith a dockside value of $6.3 billion. Domestic seafood is also an
economic engine that supports 1.2 million jobs and generates$165 billion in sales across the broader economy.
Seafood is Good for the Planet
Harvested responsibly, as it is in the United States, seafood is
also an environmentally friendly way to produce a nutritious
food given its relatively low carbon footprint and efficient use of

The U.S. seafood industry
is facing unprecedented
challenges.
Climate change is rapidly altering
species location, size, andcomposition. It is also
intensifying storms and impacts
on infrastructure.
The coronavirus pandemic
disrupted markets and trade,
decreasing the economic viabilityof the seafood industry andlimiting access to some seafood.
New technologies and otherocean uses, such as offshore
wind energy, will affect use ofocean space and potentiallyresult in conflicts.
Significant labor shortages plus
aging harvesting, processing, anddistribution infrastructure affectproduction, safety, and costeffectiveness in the industry.
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Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

February 14, 2023

resources, and is increasingly a critical part of food systems designed to reduce and mitigate theeffects of climate change.

Strategy Framework
The National Seafood Strategy focuses on NOAA Fisheries’ work to sustainably manage
marine fisheries and produce seafood responsibly, based on sound science. It is one of a suiteof strategies that describes how we will support the nation’s fisheries and execute our
mission in the face of climate change, market disruptions, and new ocean uses.
The National Seafood Strategy also allows NOAA Fisheries to address important national
issues such as the resilience of coastal fishing communities; the financial viability of theseafood industry; the effects and opportunities of international trade; and the importance of
seafood to nutrition, food security, food sovereignty, subsistence fishing, and traditional
Tribal fishing rights.
To implement the Seafood Strategy, NOAA Fisheries will partner with state and other federal
agencies, the National Sea Grant College Program, Tribes, non-government organizations,fishermen, seafood farmers, and other stakeholders to address the challenges facing theseafood sector, especially when resources are limited.
GOAL 1: Sustain or increase sustainable U.S. wild capture production
Changes in ocean conditions and the resulting shifts in distribution and abundance of marine
resources, as well as the intensity of damaging storms are affecting access to and production ofseafood as well as subsistence and Tribal fishing. These factors, in addition to new ocean uses
and advances in sampling technologies and data modernization call for an evolution in scienceand management frameworks for a climate-ready seafood sector, including:● Fisheries Science. Provide the science and economic and social analyses necessary forfisheries management under changing ecosystem dynamics.
● Fisheries Management. Maximize fishing opportunities and sustainable seafood
production while ensuring the sustainability of fisheries through effective and efficientmanagement. Support the commercial fishing industry and fishing communities in theirefforts to adapt to climate change and thrive in a changing ocean economy.
● Habitat Conservation in Support of Fisheries. Protect and restore habitat important toour nation’s fisheries and support resilient coastal communities.

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February 14, 2023

GOAL 2: Increase sustainable U.S. aquaculture production
Seafood is a healthy and climate-friendly nutrition choice and demand is increasing.
Aquaculture is one of few ways to significantly increase domestic seafood production—it’s how
the majority of growth in demand has been met in the last 20 years. Supporting gradual,
diverse, and regionally-appropriate growth of the domestic industry will depend on an efficient,strategic, and science-based regulatory approach that considers and mitigates impacts onprotected resources, essential fish habitat, and marine ecosystems.
● 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.
GOAL 3: Foster access to domestic and global markets for the U.S. seafoodindustry
A thriving, well-regulated domestic seafood industry—capable of competing at home andabroad—will translate into greater global seafood supply and food security from sustainable
U.S. fisheries. It will also decrease our reliance on foreign fisheries that are at greater risk ofoverfishing, IUU fishing, and forced labor.
●

Communication and Promotion. 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 anddevelop U.S. seafood markets and put more U.S. seafood back on U.S. plates● Fair Trade. Promote fair seafood trade by combating IUU fishing and related harmful
fishing practices around the world and by expanding access to foreign markets for
U.S. seafood.
GOAL 4: Strengthen the entire U.S. seafood sector
The COVID-19 market disruptions highlighted systemic challenges to the U.S. seafood industry
and the importance of supporting the entire seafood/fisheries value chain, including after
seafood hits the docks. Addressing these challenges will help the seafood industry to rebuild
more quickly and enable the industry to be more resilient and flexible in the face of potential
future crises and market shocks.

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Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

February 14, 2023●

Seafood as a Vital Part of the Blue Economy. Support the U.S. commercial fishing,marine aquaculture, and seafood communities to adapt and thrive in a changing ocean
economy and given new competing uses.
● Seafood Infrastructure. Work across federal agencies to modernize U.S. seafood
infrastructure (e.g., vessels, hatcheries, port and dock facilities, processing, storage,
working waterfronts) to strengthen and enhance opportunities for coastal seafoodcommunities and regional food economies.
● Workforce Development. Foster a growing and diverse seafood workforce and attract
young fishermen and seafood farmers to the sector.

Strategy Implementation
Informed by public comment and advice from our partners, NOAA Fisheries will prepare an
implementation plan for the National Seafood Strategy with specific actions, timelines,
partnerships, and milestones.

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Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

NEW BEDFORD
PORT AUTHORITY

123 MacArthur Drive
New Bedford, MA 02740

TEL (508) 961-3000

WWW.PORTOFNEWBEDFORD .ORG

March 31, 2023

NOAA’s NATIONAL SEAFOOD STRATEGYThe Port of New Bedford is the most economically valuable fishing port in the country.
Commercial fishing is a $5.5 billion dollar industry in the United States and the Northeast alone
is responsible for 30% of landings. New Bedford ex-vessel landings alone are almost half abillion dollars ($451m in 2020) with over $300 million from the scallop industry alone.
That number does not consider the countless jobs and shoreside economy supporting theindustry. A 2019 economic impact study of the Port of New Bedford and Fairhaven Harbor
conducted by Martin Associates and Foth-CLE Engineering Group calculated that 39,697 jobs
and $11 billion in total economic contribution are provided by our local seafood and commercial
fishing industry. A total of $162.8 million of direct, induced, and indirect state and local tax
revenue was generated by processing activity at the Port of New Bedford with another $391.1
million of federal taxes. In addition, $228.3 million of state and local taxes and $608.2 million
federal taxes were supported due to economic activity of the related users utilizing the Port of
New Bedford.
The seafood industry is facing unprecedented challenges, as laid out in the seafood strategy
document, it is therefore imperative that there is a significant investment in new technologies,
research development, and mitigation from new industries that will share our waters. Fishermen
and the industry as whole have been dealing with varying degrees of federal regulations over theyears and have a deep concern that the government may not always be doing what is best to
maintain a thriving and profitable fishing industry now and in the future. NOAA’s National
Seafood Strategy will have a positive effect on our domestic U.S. seafood economy; however
any strategy cannot lose site of the factors impeding industry growth.

Goal #1 Sustain or increase sustainable U.S. wild capture production
While it is important to establish protected areas to help preserve fish stocks and protect fragile
habitats from overfishing and pollution, as the emergence of offshore wind development isgenerating many more questions than answers when it comes to sustainability. Therefore,
proper, and extensive monitoring and data collection funded by the offshore wind industry willassist in identifying areas of concern and assessing the true impact of the offshore wind industry
on commercial fishing and fisheries. An increased effort is needed to identify potential new“open areas” for fishermen especially if new industries will add to current, often burdensome,regulations in place or projected. There must be a more flexible approach to restrictive fishingregulations to allow for adaptations in real time that address fisheries impacts as they arePublic comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

occurring. This is particularly the case when multiple wind lease areas are constructed in aconfined area, thereby compounding the impact on commercial fishing.
There are ways to sustain or increase seafood sustainability and production in place of justlimiting days at sea or extended closed areas. Some approaches may include:••••

Encourage sustainable fishing practices by providing incentives to fishermen who use
environmentally friendly methods.
Invest in research initiatives that monitor the health of fisheries resources and identify
trends in population and habitat health.
Develop targeted programs to reduce bycatch, or accidental catch of non-targeted species,
which can have an impact on marine ecosystems.
Establish incentives to promote responsible fishing practices such as gear restrictions andmodernization.

Goal #2 Increase sustainable U.S. aquaculture production
Countries around the world are implementing regulations and best practices to ensure thataquaculture operations are carried out in a sustainable manner, taking into accountenvironmental, social, and economic considerations. U.S. aquaculture offers Americans safe,
affordable, and healthy food choices produced with minimal impacts on the environment.
Expanding U.S. aquaculture will diversify and complement our well-managed fisheries andterrestrial food production systems by adding an important underdeveloped sector to enhance theresiliency of the overall US food supply.
The goal of increasing sustainable U.S. aquaculture production and economic growth throughaquaculture should focus on regional and local aquaculture projects to reduce dependence on
imported seafood products while creating jobs in coastal communities. A recent report preparedby The National Science and Technology Council Subcommittee on Aquaculture titled “A
NATIONAL STRATEGIC PLAN FOR AQUACULTURE RESEARCH” laid out critical objectives
and goals to increase sustainability in aquaculture production. These include, but are not limited
to:
•
•
•
•

Identifying market opportunities for U.S. aquaculture products
Educating and training a skilled aquaculture workforce
Developing production technologies that minimize environmental impacts
Promoting the safety and nutritional value of U.S. aquaculture products

https://www.ars.usda.gov/sca/Documents/2022%20NSTC%20Subcomittee%20on%20Aquacultu
re%20Research%20Plan_Final%20508%20compliant.pdf
NOAA has been a key partner in identifying the strategic expansion of US aquaculture. This
foundational support is critical and should continue to expand by working with our state andlocal partners. Investments of time and resources by NOAA is much needed in the development

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

of this new and promising industry as communities and companies alike will continue to needguidance and support.
Goal #3 Foster access to domestic and global markets for the U.S. seafood industry
Locally generated, or even U.S. produced, product consumption is far more attractive
than the global importing of often questionable seafood products. Increased regulation on
domestic fisheries increases prices and incentivizes purchase of cheaper products from otherforeign sources. Communicating and promoting a responsible seafood supply chain by labeling
who, what, where and how fish are caught will allow consumers to make informed decisions
about their seafood purchases.
Other ways to foster access to markets could include:
•
•
•
•
•

An increase in the availability of fresh, locally sourced seafood through farmers markets
and grocery stores.
The creation of materials and videos showcasing companies with the trademarked
message of “American Seafood is Sustainable Seafood”
More direct and simple supply chains to help maximize value to the fishermen andconsumer. Traceable and simple supply chains promote trust and a more direct
relationship between fishermen, the public, consumers, retailers, and wholesalers.
Taking the lead on tackling illegal fishing operations worldwide by strengthening
international cooperation between countries’ law enforcement agencies and adopting
sanctions against vessels caught engaging in illegal activities.
Raising awareness with the American public of the negative environmental and species
impacts from the foreign illegal fishing methods, to help them better appreciate thecontrasts and importance of supporting domestic wild caught seafood.

NOAA and our other federal partners should collaborate with academic institutions, economic
development agencies, local ocean clusters, and organizations such as the Local Catch Network(LCN) which was established in 2011 and is a hub for knowledge exchange and innovation to
support and catalyze local and community-based seafood systems. Today, the network is madeup of more than 500 members, including 200 seafood businesses from across North America. In
doing so, we can collaboratively support fisheries initiatives that provide economic opportunities
for coastal communities while also promoting sustainable fisheries management practices.
Goal #4 Strengthen the entire U.S. seafood sector
It is imperative that NOAA works with Congress to identify the challenges our current fishingindustry is facing. In doing so, legislative action will be needed in the areas of amending theMagnuson-Stevens Act with extensive input from the industry, re-opening the Northeast
Canyons and Seamounts Marine National Monument area to sustainable commercial fishing, andthe mitigation and compensation to the entire fishing industry from the potential negative effects
of offshore wind development.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

To date, the Bureau of Ocean Energy Management (“BOEM”) has auctioned over 24.7 million
acres for offshore wind in the Atlantic. With these leases comes significant revenue for thefederal government. This lease revenue, or a portion thereof, should be used to support scientificsurvey mitigation work and activities to avoid, minimize and mitigate the environmental andeconomic impacts of offshore wind.
We, and the fishing industry as whole, also have deep concerns with Administration’s “30 by
30” order committing 30 percent of our lands and oceans to conservation by 2030. Fisheries in
all Federal waters are already conserved under the Magnuson-Stevens Act, which has beenpraised for its success by nearly every major environmental organization. Numerous global
studies have found U.S. fisheries to be among the most sustainably managed fisheries in theworld. We therefore believe that fisheries in all Federal waters outside formal properly-createdmarine sanctuaries, including fisheries in marine monuments, should be managed sustainably
under the Magnuson-Stevens Act. There is no scientific justification for the 30% number, andno likelihood of increasing our national food security to be derived from closing 30% of U.S.
waters to sustainable commercial fishing.
Between offshore wind and the stated conservation goals, the potential impact in the commercial
fishing industry is daunting. There must be a concerted effort to use the offshore lease funds toresearch and encourage new technologies, new areas and lessen barriers to entry into fisheries
before it is too late. As aforementioned, fisheries management must be nimble and adaptableand based on sound scientific data especially due to climate change and the new development ofoffshore wind. We would not want to see a shift in demand to less sustainable seafood sources
abroad, creating disadvantages for our domestic industry stakeholders.
Seafood supply chains and policies should foster and strengthen community-based fisheries.
Fisheries access should be kept available to future generations and must be balanced against theneeds and limits of the ocean as well as fishermen’s ability to sustain a livelihood with pride.
Building a better seafood system requires creativity and innovation. It also requires that forwardthinking ideas are not isolated but rather spread through a network of diverse stakeholders
working together, aligning around shared values. Creativity and networking fosters knowledge
sharing and collective understanding to have a truly sustainable and successful seafood trade on a
local, national and global level.
Sincerely,

Gordon M. Carr
Executive Director
New Bedford Port Authority

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Comments on NOAA Draft National Seafood Strategy
Frank Mirarchi
XII Northeast Fishery Sector, Inc.
March 1, 2023

XII Northeast Fishery Sector, Inc. is a cooperative association established underprovisions of Amendment 16 to the Northeast Multispecies FMP in 2010. Its
membership represents 23 multispecies permits and 6 active vessels based in
Scituate, Mass. Our members share and support the vision statement provided in
the Strategy Document. Our vessels are family owned and operated and arecontinuing a tradition that spans generations.
Having withstood the burdens and sacrifices imposed by two decades ofregulations designed to rebuild overfished groundfish stocks, we find ourselvesfacing new challenges. Several of these, along with some proposed solutions or
mitigations are listed below:
1. Fisheries science. For fishery managers and regulators to have timely andrepresentative data it is imperative that we do more to incorporate fisherydependent data into stock assessments. Monitoring programs, both humanobservers and electronic systems, have evolved into assuring complianceand accuracy of counting regulatory discards with little attention to the
biological condition of catches. Apparently, the port observer program,which collects aging information at processing facilities, has also been
diminished leaving growing uncertainty over the age structure of catches as
well.
Our recommendation would be to train fishermen and compensate themfor providing lengths and biological samples, such as otoliths, from
representative catches. In addition, information on spawning condition
could provide a broader picture than is now available from biennial fisheryindependent surveys.
2. Management. Enrollment in a sector has become a necessity for fishermen
who depend on predictable access to the groundfish (multispecies) fishery.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

The costs of sector operation have increased substantially due to theadministrative burden of programs such as at sea monitoring. Ultimately,
these costs are imposed on the fishermen through membership fees.
Congress has agreed that costs for training and placing of at-sea monitors
on multispecies trips are reimbursable. It is our belief that costs for thisprogram imposed on sectors and ultimately borne by member vessels
should be treated similarly.
3. Seafood infrastructure. There is a serious disconnect between theavailability of groundfish stock and landed harvests. For example, for fishingyear 2022, as of 2/21/23, with 85% of the fishing year elapsed only one
stock (white hake) had been harvested at over 50% of the allocated ACL.
For fishing year 2021 (5/01/21 through 4/20/22) the fishery landed 18,700
metric tons out of an allocated 131,400 metric ton allocation. This is 14% of
the total allocation.
A large factor in this poor performance is a lack of processing capacity. The
industry lost a large part of capacity during the COVID business closures. As
the economy rebounded, domestic groundfish species lost market share toimported products. Since then limited capacity to process has depressed
ex-vessel prices and contributed to volatility adding an additional level of
uncertainty to vessel owners’ business planning.
The industry desperately needs to upgrade infrastructure, especially insmaller ports. Capital costs for ice making, cold storage and processing
machinery are presently beyond the reach of boat owners, and processors
in these regions. A program of grants or loans designed to enable rebuilding
is essential. Without investment in shoreside infrastructure, we willcontinue to lose opportunity for economic vitality and food security in thisfishery.
We urge you to consider the points listed here when developing a strategy
implementation plan for our nation’s fisheries.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

The Port of Port Orford appreciates this opportunity to comment on the NOAA Draft
Seafood Strategy. Port Orford is a small rural community located on the southern Oregon coast,with a population of about 1,100, which has not grown appreciably in many decades.
Approximately 30% of the local workforce is employed in the commercial fishing industry, and
the Port of Port Orford is the center of this commercial seafood activity. For its size, the fleet of
approximately 40 vessels is disproportionally productive, landing an average of more than $5M
in ex-vessel value seafood annually, and contributing approximately $12M to Oregon’s economy
annually, with the greatest values occurring in the last 10 years. Like most Oregon ports,
Dungeness crab is king here, and makes up the largest portion of the value, but the Port Orford
fleet also specializes in value added innovations such as live fish, which can fetch 6-7 times asmuch when kept alive and transported to live fish markets and restaurants in the San Francisco
Bay Area, Portland, and Seattle markets. The Port Orford fleet is also a leader in proactive
efforts to protect fish populations, by proposing and supporting the Redfish Rocks Marine
Reserve and Marine Protected Area more than ten years ago. The Port is generally supportive of
NOAA’s draft Seafood Strategy and is providing some feedback and suggestions regarding eachof the goals outlined in the strategy, as follows.

GOAL 1: Sustain or increase sustainable U.S. wild capture production.
As outlined above, the Port of Port Orford and the local fleet are an integral part of the Port
Orford community, comprise a substantial portion of the local economy, and are an essential
part of its culture. In short, there is no Port Orford without the Port. We encourage NOAA torecognize and support the vitality of small rural fishing communities like Port Orford, and therevitalization of these working waterfronts, once at the core of these communities.
Fisheries Science: In addition to the other initiatives outlined in Goal 1 concerning includingchanges in ecosystem dynamics in fisheries management, we encourage NOAA/NMFS topromote and support collaborative fisheries research and collaborative data collection to informfisheries management using more “real time” data.
Fisheries Management - We support effective and efficient fisheries management that supports
fishing communities in our efforts to adapt to climate change and to thrive in a changing ocean
economy. In addition, we encourage NOAA to promote and support community-based fisheries
management, using real time data to inform in-season adjustments, and streamlining thefisheries management decision making process. We encourage NOAA to promote and support
efforts to engage in emerging fisheries in response to range shifts due to ocean warming.
Habitat Conservation - In addition to NOAA’s efforts to protect and restore habitat that is vitalto the health of commercially fish stocks, we encourage NOAA to promote and support efforts
to protect and restore kelp forest habitats, on which many groundfish species depend in ourPublic comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

region, and to promote and restore wild salmon habitat, without which the wild salmon runs
cannot endure.
Goal 2: Increase sustainable U.S. aquaculture production.
We support the goal of gradual, diverse, regionally appropriate growth in the aquaculture
sector. We do not support large scale, rapid growth approaches to open ocean aquaculture,
which has not been tested, and for which consequences are unknown at this time.
We support NOAA’s goal of science-based approaches that mitigate impacts on protectedresources, Essential Fish Habitat, and marine ecosystems. In addition, we support appropriately
scaled restorative mariculture approaches that are appropriate to the local region. We supportscience-based approaches, and regulatory efficiency, as long as it does not “fast track”
aquaculture projects the consequences of which are not adequately understood.
Goal 3 – Access to Domestic and Global Markets for US Seafood.
We promote the goals of improved communication and promotion of US Seafood, with a focus
on local and regional markets. We support market development, with a focus on local seafoodmarket opportunities, and promoting equity in access to local seafood. We support fair trade inseafood and NOAA’s efforts to combat IUU fishing, which places small fishing communities likeours at an economic disadvantage.
Goal 4 - Strengthen the entire U.S. seafood sector.
We support NOAA’s goal of strengthening the entire seafood sector and fisheries value chain,including after seafood has hit the dock. We encourage efforts to promote resilience andflexibility in the face of changes to the oceans and to seafood markets.
Seafood is a vital part of the Blue Economy We agree and are an example of the essential
nature of the major role played by the seafood sector, particularly in small fishing communities
like ours, where 30% of the local workforce is employed in commercial fishing sector. We also
support the development of living wage jobs in this sector so that community members canremain in their community as these new opportunities develop.
Seafood Infrastructure
We agree that it will be important to work across federal agencies to modernize U.S. seafood
infrastructure (e.g., modernized vessels, port and dock facilities, processing, storage, working
waterfronts) to strengthen and enhance opportunities for coastal seafood communities andregional food economies. The Port of Port Orford is currently launching an ambitious but long
overdue Redevelopment Program to revitalize our working waterfront, and prepare for thefisheries of the future, ocean and fisheries research, restorative mariculture, and outdoor
recreation that respects the ocean environment. This program includes a proposal to the
Economic Development Administration to upgrade a high-capacity pump ashore seawater
system to supply undiluted seawater uniquely available at our ocean direct location. This projectwill supply expanded value-added commercial seafood operations, retail and wholesale, ocean
research, aquaculture, and emerging ocean innovations. This program also includes a FEMA
project to strengthen the sole access road to our Port, increasing our capacity to ship product,
while making the Port safer by providing a tsunami evacuate route, and a MARAD/PIDP
proposal for port infrastructure to upgrade vessel, product, and personnel transportation,
holding, processing, packing, and shipping operations. We are happy to be working with NOAA
Fisheries on this strategy, and welcome opportunities to engage in interagency consultation torealize the full potential of the Port of Port Orford, and to serve as an example for other small

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

ports. We are also actively exploring opportunities to build a low carbon emissions commercial
fishing fleet for those who wish to embrace this new technology and are seeking opportunities
to pair this with clean energy generation and supportive infrastructure as we look toward aclean energy future in the maritime sector.
Workforce development – Finally, we agree with NOAA’s goal to foster a growing and diverse
seafood workforce and attract young fishermen and seafood farmers to the sector. The Port ofPort Orford shares this goal and is embracing opportunities to support a more diverse workforce
and seeks to attract a new generation of commercial fishermen and seafood farmers. In
collaboration with our fleet members and partners at Oregon State University, we haveidentified several initiatives that we think will be essential components of a successful programto achieve this goal.
Elements of successful workforce development in Port Orford and similar rural fishingcommunities:• Workforce housing – like many coastal communities, real estate speculation is buying up
housing stock and converting it to vacation rentals, eliminating workforce housing, which
is a major obstacle for fishermen and deckhands seeking to live in the community.
• Access to capital – new generation fishermen and women are facing substantial
investment to enter commercial fishing and need access to low interest loans and othersmall business development strategies to enter the commercial fishing business.
• Continuous safety training will be essential to ensure the ongoing safety of new entrants
into the fishing business.
• New generation fishermen are embracing collaborative research, and NOAA should
promote and embrace this unique opportunity to diversify and enrich fisheries research.
One challenge is the need for creative approaches to insuring commercial fishing vessels
so that small vessel fishermen can competitively bid on research contracts with agencies
and universities to conduct collaborative fisheries research.
• Climate change is leading to range shifts in stocks and this and other drivers are resulting
in emerging fisheries. NOAA should support opportunities for more rapid fisheries
diversification to keep up with rapid changes in ocean ecosystems.
• NOAA should explore ways to support the development of community led fishermen’s
associations in rural communities where this capacity is needed.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

To Whom it May Concern,
My name is Anna Woods. My husband, Eric Woods, and I own a commercial fishing businessthat harvests seafood of all kinds from the Gulf of Mexico. It is our top priority to maintain the integrityof ALL of the fisheries available in Gulf waters, especially those we target. We are proud of the work wedo and we believe our business plays an important role in our economy. We are able to bring fresh
seafood to the tables of American consumers, who otherwise, would never get the opportunity to enjoy
these natural resources and important sources of nutrition. We would like to show our support for
NOAA's National Seafood Strategy and believe it is a necessary initiative to manage, not only thesustainability of marine fisheries, but of the commercial fishing industry as a whole.
To ensure this strategy comes to fruition, I also believe it is of the utmost importance to provide
support to our commercial sector. Our Gulf Council has little support for the commercial fishingindustry. I would like to see more commercial sector advocates hold seats on the Gulf Council for a morebalanced, unbiased group of individuals. This will ensure sound decisions being made that are best for
the Gulf of Mexico, NOT political or personal agendas. As said earlier, we commercial fisherman are thebiggest proponents of sustainability, accountability and growth in the Gulf of Mexico. It is our priority to
see our Gulf species thrive for future fisherman and consumers alike. We would appreciate support fromNOAA to encourage higher officials to reconsider Gulf Council seats for more balanced representation of
the commercial industry. We care about our Gulf!
Sincerely,
Anna Woods

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

March 20, 2023
Re: Comments on NOAA’s National Seafood Strategy
Dear NOAA Fisheries,
Alaska Seafood Marketing Institute (ASMI) is a public-partnership between the State of Alaska and the
Alaska seafood industry representing over 60,000 Alaskan harvesters, processors and businesses thattake pride in providing nutritious, wild, natural and sustainable seafood to consumers worldwide. The
seafood industry is the largest private sector industry in the state of Alaska and naturally produces over
60 percent of all seafood in the United States. Nationally, seafood from Alaska annually generates over
$6 billion in labor income and nearly $15 billion in economic output.
ASMI’s work to boost the value of Alaska’s seafood product portfolio is accomplished through a varietyof tactics, including partnerships with retail grocers, foodservice distributors, restaurant chains,
foodservice operators, universities, culinary schools, and the media. ASMI conducts consumer
campaigns, public relations and advertising activities, and aligns with industry efforts for maximum
effectiveness. ASMI also functions as a global brand manager of the Alaska Seafood family of brands.
The Association of Genuine Alaska Pollock Producers (GAPP) is a nonprofit trade association that
advocates for one of the world’s most sustainable and nutritious seafood products, U.S.-caught Wild
Alaska Pollock. Wild Alaska Pollock is the most consumed wild-caught fish in the world and the fourthmost consumed fish in the U.S. GAPP’s mission is to build demand and awareness for the fish throughdriving product innovation, conducting research, and creating awareness about product quality and the
responsibly managed fishery the product comes from. GAPP’s membership encompasses the entire
fishery from harvest to processing and includes those that both support the industry as well as help
bring the product to retail and foodservice markets around the world. Included in GAPP’s membership
are the Community Development Quota (CDQ) groups that have ownership of shares of the Wild Alaska
Pollock quota and use that ownership to benefit their communities. GAPP works in collaboration with
ASMI to raise awareness of Wild Alaska Pollock’s attributes and build the brand for Wild Alaska Pollock
beyond an anonymous whitefish.
We appreciate NOAA’s efforts to support a thriving domestic U.S. seafood economy, and to enhance
resilience in the seafood sector and our coastal communities. NOAA’s National Seafood Strategy(Strategy) provides a high-level framework, and our comments highlight and expand on the specificcomponents that we believe are the most important for our industry. When NOAA develops an
implementation plan, we request additional opportunity to comment on that more detailed plan.
ASMI & GAPP appreciate introductory comments in the Strategy document highlighting that wild
seafood in the U.S. is responsibly harvested and one of the best sources of essential nutrients. In Alaska,
we are incredibly proud of our sustainably managed commercial fisheries and believe that characteristic
distinguishes us from many foreign competitors. We encourage NOAA to continue pushing this message
out to the American public to encourage more domestic consumption of U.S. seafood.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Goal 1: Sustain or increase sustainable U.S. wild capture production
Fisheries Science. Core fishery surveys provide necessary information that underpins our entire sciencebased management system. Existing core surveys must continue, and NOAA should consider expanding
what is considered core (for example, adding regular surveys in the Northern Bering Sea or increasing
surveys in the Gulf of Alaska to occur annually). There is also a need for expanding fisheries science andresearch to better understand the impacts of rapidly changing ecosystem dynamics. However, any
expansion made must be in addition to existing efforts and not come at the cost of core fisheries
surveys.
Fisheries Management. This goal speaks to the importance of maximizing fishing opportunities while
ensuring the sustainability of fisheries through efficient and effective management and supporting thecommercial fishing industry and fishing communities to adapt and thrive in the face of a changing ocean
economy. Conditions are changing rapidly, including supply chains, domestic and international markets,and ocean conditions. ASMI & GAPP support effective fisheries management that can respond to thesechanges, ensure sustainable fisheries for tomorrow while maximizing commercial harvest today, andallow our fishing businesses and coastal fishing communities to thrive.
Goal 2: Increase sustainable U.S. aquaculture production
Marine Aquaculture Management and Regulatory Efficiency. ASMI & GAPP recognize the value ofmariculture and aquaculture and advocates that each state retain the ability to choose which types ofaquaculture activities are appropriate for themselves by including opt-out provisions.
Goal 3: Foster access to domestic and global markets for the U.S. seafood industry
Communication and Promotion and U.S. Market Development. ASMI & GAPP support increasing
domestic awareness about the sustainability, availability and nutrition of U.S. seafood. There istremendous opportunity to better promote U.S. seafood. The Saltonstall-Kennedy (SK) grant program,which was created to market and promote U.S. seafood, should be better utilized to promote U.S.
seafood. The program is funded through fees collected on seafood imports, and in FY2023 the SK
program is slated to receive about 3% of the collected fees. ASMI believes there is room to grow the SK
grant program and supports allocating a higher percentage of the collected fees for industry grants
targeted at marketing and promoting U.S. seafood.
Fair Trade. Most of Alaska’s seafood competes in global markets. ASMI recommends NOAA establish aformal partnership with the U.S. Trade Office and the USDA to align U.S. seafood trade objectives. For
example, Alaska seafood industry representatives met with U.S. Trade Ambassador Tai in June 2022 andnoted the following key trade challenges facing the Alaska seafood industry.

1. The U.S. Trade Office does not have dedicated staff for seafood, as it does for
textiles and agricultural products. ASMI & GAPP recommend ensuring the Trade
Office has the necessary expertise, awareness and bandwidth to appropriately
support U.S. seafood trade.
2. The U.S. seafood industry lacks U.S. trade policy support often afforded to farmers
and manufacturers. For example, foreign seafood often enters the U.S. entirely dutyfree, while seafood harvested in the U.S. and processed overseas is subject to hightariffs when entering U.S. markets.
3. Tariff barriers in key export markets continue to grow, including China and Japan
where Phase One agreements should have increased purchases and opened

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

markets. At the same time, the U.S. continues to allow import of Russian-harvested
pollock and crab via third-party countries which undercuts the value of Alaska
seafood within its most important market – the U.S.
4. Failure to address low-hanging fruit like removing Section 301 Tariffs on Alaskan
flatfish; all other Alaskan seafood products were removed from the Section 301 lists
and removing the last five flatfish product codes is truly low-hanging fruit.
Goal 4: Strengthen the entire U.S. seafood sector
Seafood Infrastructure. Alaska has aging fishing fleets and processing facilities and our seafood industry
would greatly benefit from investments to modernize its infrastructure. Modernizing and replacing
commercial fishing vessels would increase efficiency and safety on the water, while modernizing
processing facilities would increase efficiency while creating opportunities for more value-add
processing in the U.S. and an ability to be more competitive with foreign seafood production. Bringing
more seafood processing back to the U.S., rather than continuing to ship product overseas, is atremendous opportunity for U.S. seafood and the U.S. economy. Updating seafood industry
infrastructure will benefit our coastal fishing communities and increase local and national food security.
Workforce Development. ASMI & GAPP support workforce development and training for the seafoodindustry, and trades necessary to support our fleets and infrastructure. There is also growing concernthat fewer young people are opting to become fishermen, and we support initiatives that will raiseawareness and attract the next generation into the U.S. seafood sector to strengthen our nation’s foodsecurity. In addition, rapidly changing fishery conditions have led to an unprecedented number offishery disasters in Alaska in recent years. This has highlighted the need for much faster disaster relief tofishermen and communities, and challenges with quickly identifying and accessing other mitigation
measures when they are needed for fishing businesses and individual fishermen (e.g., SBA EIDL program,or job retraining resources).
We understand NOAA Fisheries will prepare an implementation plan that contains specific actions,timelines, partnerships and milestones, and we request an opportunity to review and comment on thatplan when it becomes available.
As the marketing representatives for the largest seafood producing region in the U.S., ASMI & GAPP arewilling partners to help NOAA achieve its near and long-term goals of an economically strong, resilient,sustainable and thriving U.S. seafood sector.
Thank you,

Jeremy Woodrow
Executive Director
Alaska Seafood Marketing InstitutePublic comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Dear Michael Rubino and Sarah Shoffler,Thank you for the opportunity to provide input on NOAA Fisheries’ Draft National Seafood Strategy. We
appreciate the agency’s efforts to develop a strategic vision for the seafood sector in these unprecedented
times and your commitment to integrating input from public comments and listening sessions. As a groupof researchers and practitioners involved in seafood systems in the United States, we offer the comments
below to encourage an inclusive, resilient, and community-focused Strategy.
The Strategy should directly address issues of access, distribution of benefits, and the retention of
those benefits in U.S. communities. The benefits of fisheries and aquaculture in the U.S. should be
widely distributed among communities within the U.S. There is an urgent need to address consolidationof seafood system benefits among a small number of actors. The wealth and non-monetary benefits
generated by U.S. fisheries must have a clear path to benefiting seafood producers and consumers at local,
regional, and national scales. Small-scale, community-based, and Indigenous harvesters and businesses in
the U.S. and people who rely on seafood require access to fisheries, working waterfronts, and scaleappropriate infrastructure. Such considerations are essential to the goals of food security, thriving
economies, and healthy ecosystems.
The Strategy should address seafood system resilience using best available science. In the wake ofthe hardship to seafood communities caused by the COVID-19 pandemic response and in the face ofclimate change, we see an opportunity to center resilience in the Strategy. There is robust evidence that
local and regional seafood supply chains offer food system resilience, particularly during times of crisis.
This resilience is critical to ensuring food security and stable seafood livelihoods for people in the U.S.
and must be supported. The draft Strategy’s aims of “meeting critical domestic nutritional needs” and“expanding access to foreign markets” are contradictory without further elaboration and do notadequately incorporate the body of research demonstrating that food system resilience is rooted in local
supply chains. Similarly, the goal of increased wild catch seems counterintuitive to the Strategy’s
overarching goal of adapting to climate change. Rather than increasing the quantity of catch, we suggest
the Strategy should focus on creating more value from current production, including improved
distribution of seafood to domestic consumers and improved retention of value for producers. With
respect to decision-making, the Strategy should meaningfully include local and Indigenous Traditional
Ecological Knowledge (ITEK), as well as social and natural science, in the information considered as the‘best available science’ to inform decision-making.
Aquaculture and fisheries should be more integrated in the Strategy. Aquaculture and fisheries coexist in our seafood system. They share infrastructure, ecosystems, markets, and in some cases are
inseparably integrated (e.g., salmon ranching via hatchery). The Strategy should take a more holistic
approach to the spectrum of aquaculture to wild-caught seafood that prioritizes the community benefits offisheries and aquaculture. Doing so could serve to minimize conflicts as aquaculture production increases.
The Strategy should address the next generation of seafood and should be explicit about expanding
access for people from historically marginalized backgrounds. In its current form, the Strategy
addresses symptoms, rather than root causes, of unequal opportunity to participate in the U.S. seafood
system. Young and new entrants to the seafood industry face numerous barriers to establishing or

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

accessing livelihoods, including but not limited to access to limited-entry fisheries and workforce
training. The Strategy should address challenges young people face accessing capital, permits/quota,
health insurance, waterfront access, and scale-appropriate infrastructure, among other barriers. The
Strategy should explicitly address the need to diversify access to seafood livelihoods and meaningful
inclusion in governance, particularly for people from historically marginalized backgrounds. Expanding
access will be critical to address the aging workforce, the distribution of benefits from seafood, andenhancing the creativity and innovation within seafood systems to address pressing challenges.
The Strategy could be strengthened if aligned with existing federal mandates and other NOAA
commitments and will better address some of the gaps and contradictions illustrated above. A nonexhaustive list to consider includes:● The NOAA Draft National Strategy on Equity and Environmental Justice lists among its six core
objectives, “Ensure that our policies promote equal opportunities for all and do not create
unintended inequities or unequal burdens for underserved communities,” “Distribute benefits
equitably among stakeholders by increasing the access to opportunities for underserved
communities,” and “Provide for the meaningful involvement of underserved communities in thedecision-making processes.”● The 2012 DOC Environmental Justice Strategy states that all populations should share in (and not
be excluded from) benefits of Departmental programs, policies, and activities affecting humanhealth or the environment.
● Executive Order 13175 (Consultation and Coordination With Indian Tribal Governments) states,“Tribes shall, on a government-to-government basis, be afforded regular and meaningful
consultation and collaboration opportunities in the development of Department policies that have
Tribal implications.”● The White House’s Guidance on Indigenous Traditional Ecological Knowledge (ITEK) for
Federal Agencies “commits to elevating ITEK in federal scientific and policy processes.”● Executive Order 13985 (Advancing Racial Equity and Support for Underserved Communities
Through the Federal Government) states, “Because advancing equity requires a systematic
approach to embedding fairness in decision-making processes, executive departments andagencies must recognize and work to redress inequities in their policies and programs that serveas barriers to equal opportunity.”● Executive Order 14008 (Tackling the Climate Crisis at Home and Abroad) directs Federal
agencies to make achieving environmental justice part of their missions by developing programs,
policies, and activities to address the disproportionately high and adverse human health,environmental, climate-related, and other cumulative impacts on disadvantaged communities, aswell as the accompanying economic challenges of such impacts.
● Executive Order 12898 (Federal Actions to Address Environmental Justice in Minority
Populations and Low Income Populations) directs each federal agency, “[t]o the greatest extent
practicable and permitted by law…” to identify and address, as appropriate, thedisproportionately high and adverse human health or environmental effects of their actions on
minority and low-income populations.
● The Magnuson-Stevens Act ensures, “...preservation of a way of life for fishermen and theirfamilies, dependence of local communities on a fishery (e.g., involvement in fisheries and ability
to adapt to change),... non-fishery related indicators (e.g., unemployment rates, percent ofPublic comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

March 9, 2023
Ms. Janet Coit
Assistant Administrator for Fisheries
NOAA Fisheries
1315 East West Highway
Silver Spring, MD 20910
Dear Assistant Administrator Coit:
Thank you for the opportunity to comment on NOAA Fisheries’ Draft National Seafood Strategy(Strategy). Stronger America Through Seafood (SATS), an industry coalition that advocates for increasing
Americans’ access to healthful, sustainable, and affordable seafood, applauds NOAA Fisheries forrecognizing the need to increase U.S. aquaculture production. Our members include seafood processors
and distributors, feed ingredient suppliers, aquaculture farmers, technology providers, and capital
partners. With supply chain disruptions due to COVID-19 and uncertainty for wild capture in the face ofclimate change, it has never been more important for the U.S. to diversify its seafood supply throughU.S. offshore aquaculture. The growth of domestic aquaculture is an important part of a holistic
approach to a more diverse, sustainable, healthful food strategy.
SATS fully supports Goal Two of the Strategy which calls for increasing sustainable U.S. aquaculture
production. We applaud the agency’s plan to accelerate progress towards an efficient, predictable,
timely, and science-based regulatory framework for marine aquaculture. Further, we recognize thevalue of NOAA Fisheries’ science-based advice and tools and coordinated, applied scientific research insupport of sustainable industry development. We encourage the continued progress in these areas.
Responsible marine aquaculture has the potential to feed a growing population, mitigate climatechange, increase the resilience of the global food system, and be a major economic engine for thecountry. The U.S. aquaculture supply chain supports many American industries on land and sea. If we
expanded the industry to the deep Pacific and Atlantic waters off our coasts, it would boost the fish feedmarket and seafood retail businesses and supply restaurants, markets and grocery stores with locallygrown, sustainable seafood. In addition to boosting growth for the seafood industry, Americanaquaculture would provide a new market for U.S. farmers, specifically for crops such soybeans, corn andpeas, which can be used to create fish feed and ease pressure on ocean resources. The growth of
aquaculture production would also spur job creation and revenue across the country and lessen
dependence on the uncertainty of foreign trade relationships.
Further, offshore aquaculture has been recognized as one of the most resource-efficient methods for
producing animal protein. Modern science and technology have helped make the production ofsustainable seafood possible, fueling the growth of the aquaculture industry worldwide. With a far

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

lower environmental impact than most terrestrial means of food production, aquaculture has been
identified as a remedy to address threats to global food security resulting from climate change and a
growing population.
Use of advanced technology combined with careful management and science-based techniques,continue to build the case for aquaculture as a safe and environmentally responsible way to produce
seafood. Applications of emerging technology in aquaculture, such as AI and machine learning,
computer vision, sensors, and biotechnology, help fish farmers produce healthy fish efficiently andsustainably. We support NOAA Fisheries’ commitment to providing science-based advice and tools tominimize potential effects of an aquaculture operation on the environment and conducting appliedscientific research in support of sustainable industry development.
There is great potential for expansion of U.S. marine aquaculture where vast expanses of favorable
growing areas with suitable depths, current speeds, temperatures, and access to ports create some ofthe highest production potential in the world. However, the lack of a comprehensive, nationwide
system for permitting in federal waters is limiting the development of U.S. marine aquaculture farms.
Few venture capital investors and even fewer entrepreneurs are willing to invest without thecertainty of obtaining long term permits or licenses. The agency’s focus on developing an efficient,predictable, timely, and science-based regulatory framework for marine aquaculture is essential tocreating a thriving offshore aquaculture industry and the benefits it provides.
SATS supports a clear permitting process for U.S. marine aquaculture that also prioritizes environmental
and societal health as provided for in the bipartisan Advancing the Quality and Understanding ofAmerican Aquaculture (AQUAA) Act. For example, the proposed AQUAA legislation would establish
National Standards for Sustainable Offshore Aquaculture which, like the National Standards forcommercial fishing outlined in the Magnuson Stevens Act, are guiding principles for growing coastal
economies, protecting ecosystems, and avoiding conflict among stakeholders. AQUAA leverages modern
siting and monitoring technologies to mitigate potential environmental impacts. It also provides forstrict federal enforcement and includes a process for robust public input which ensures that coastal
communities and states are considered prior to permitting new operations. In short, AQUAA provides
much-needed regulatory certainty for U.S. marine farmers while also preserving the environment, local
economies, and public health.
Thank you again for recognizing the importance of a thriving U.S. aquaculture industry to the seafood
economy and the resilience of the seafood sector in the face of climate change and other stressors. We
appreciate the opportunity to comment.
Sincerely,

Drue Banta Winters
Campaign Manager
Stronger America Through Seafood

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Dear Sarah Shoffler and Michael Rubino,
Thank you for the opportunity to provide commentary on NOAA Fisheries’ Draft National Seafood Strategy.
Developing a comprehensive framework to guide us into the next era of sea-based community and industry is adaunting task. I sincerely thank you for your commitment to this process, and offer the below comments from theperspective of the Hanover Co-op Food Stores of Vermont and New Hampshire. We are a $90 million community
owned cooperative that works to strengthen our local and regional food shed, while providing our customers withaccessible, high quality, and nutritious foods.
I also write from my capacity as the Board Treasurer for New Hampshire Community Seafood, a small multistakeholder cooperative based out of Portsmouth, New Hampshire. Our mission is to provide the highest quality New
Hampshire landed fish and seafood to ours consumers through a weekly CSF style pick-up of fish filets as well asshell-fish shares. We only purchase seafood that can be traced directly to small boat fishermen off of the coast of
New Hampshire, and pay a 50 cent premium above market prices to our fishermen. Our customers love the delicious
fresh seafood, and their connection to the local working waterfront. Notably, we had our highest sales to date in 2020,
when other food supply chains faltered under the pressures of the pandemic.
Taking a broad view of our opportunities and strategies moving forward, I encourage you to continue advocating forsmall and medium scale seafood businesses. These smaller players are often left out of incentives and funding
opportunities, when in fact they are the backbone of working waterfronts and sustainable seafood culture. We should
strongly prioritize creating a diverse seafood harvesting industry through education, funding for appropriately sizedprocessing facilities within reasonable distance to docks, and the promotion of the benefits of seafood in a healthy
diet and lifestyle.
In reading the draft strategy, I was struck by the inherent contradiction between “meeting critical domestic nutritional
needs” and “expanding access to foreign markets.” As the political climate and global markets have changed over thelast several decades, the US has responded across many agricultural sectors by encouraging exponentially scaling up
individual powers, who gobble up smaller producers and harvesters by running them out of resources and market
share, only to export their products leaving many consumers with lower quality and under-regulated imported
seafood options at the store.
Even carefully crafted strategic supports can only succeed if our leadership meaningfully addresses the barriers thatbeginning fishermen face. Without access to training and capital, health insurance, and waterfront access, we willcontinue to see the numbers of fishing communities dwindling. I would like to take this opportunity to highlight thework of the New England Young Fisherman’s Alliance. NEYFA provides grants and training in: business
management, collaborative marketing, industry regulation and permitting, and cooperative research opportunities toseafood professionals who are establishing unique businesses. These program graduates are the future of our local
seafood industry. For many of these small seafood producers access to shared infrastructure determines their ability
to successfully enter into their local food markets. Left to commodity species pricing, we are neglecting the criticalneeds of these emerging community assets.
In conclusion, I offer my sincere thanks and collaboration in the development of this strategy. By prioritizing
building an essential domestic seafood industry, and subsequent domestic processing and distribution channels, we
can grow the value of US commercial fisheries. Through your leadership and attention to the complexities andnuance that comprise our working shorelines, we work towards a bright future afforded by our marine resources.
Respectfully,
Rebecca J. H. White (she/they)
Public & Government Affairs Associate
Hanover Co-op Food Stores

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

July 26, 2023
Janet Coit
Assistant Administrator for Fisheries
National Oceanic and Atmospheric Administration
NOAA Fisheries Directorate
1315 East-West Highway, 14th Floor
Silver Spring, MD 20910
Dear Assistant Administrator Coit:
The Seafood Nutrition Partnership is pleased to submit comments in response to the National Oceanicand Atmospheric Administration’s (NOAA’s) Request for Public Comment on its draft “National Seafood
Strategy.” We appreciate the leadership of NOAA taking the first step to develop a national seafood
strategy – a welcome policy shift for the entire seafood community. Our comments are as follows.
Seafood is Good for People: Seafood is good for overall public health. The 2020-2025 U.S. Dietary
Guidelines recommend eating at least two servings of seafood per week, especially for pregnant womenand those with heart conditions. Research shows that people who regularly eat seafood are 20 percent
less likely than their peers to experience depression and live an average of 2.2 years longer than those
who do not. Seafood consumption also provides unique health benefits as a lean protein and is the bestsource for Omega-3 fatty acids, which are healthy fats essential to human health and development.
Seafood is Good for the Economy: In 2020 alone, U.S. commercial and recreational fishing
generated $253 billion in sales impacts, contributed $117 billion to gross domestic product, andsupported 1.7 million jobs in the U.S. marine fishing sector and across the broader economy.
Seafood is Good for the Planet: Seafood is recognized as a climate friendly protein. With the Earth’s
population projected to reach 9 to 10 billion people by 2050 and with limitations of land based
agriculture, we must look to the ocean to ensure our future food security.
Strategy Framework: To successfully implement a national seafood strategy for Goal 3, it is imperative aconvening entity takes the leading role. NOAA should heed the recommendations of the Marine
Fisheries Advisory Committee and establish an industry-led National Seafood Council, which should betasked with implementation of a national seafood promotion campaign. The Council would also conduct
education, research, promotion, and marketing on behalf of U.S. seafood – including both wild-capture
fisheries and aquaculture.
Goal 3: Communication and Promotion. Increase public awareness of the availability, sustainability, andnutritional value of all U.S. seafood: A comprehensive national seafood marketing campaign for
consumers that features the value of seafood for health and nutritional benefits should be a goal thatwould help existing U.S. seafood marketing efforts amplify their messages and strengthen the U.S.
seafood sector as a whole.
We appreciate the opportunity to submit these comments. As NOAA continues to build out andimplement its national seafood strategy, we urge you to consider the Seafood Nutrition Partnership as aresource.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Thank you for your consideration.
Sincerely,
Linda Cornish
Founder & PresidentPublic comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Mar 31, 2023
To:

Ms. Janet Coit
Assistant Administrator, National Marine Fisheries Service
1314 East-West Highway
Silver Spring, MD 20910
Submitted electronicallyRe:

Comments on NOAA’s National Seafood Strategy

Dear Assistant Administrator Coit,
On behalf of Businesses for Conservation and Climate Action (BCCA) and thecommunity-based enterprises we represent, thank you for the opportunity to provide
input on NOAA’s national seafood strategy. We are grateful for the work NOAA is
doing to support the domestic ﬁshing industry as well as the sustainable aquacultureindustry and enhance stewardship, oversight, and opportunity in our oceans.
BCCA is a coalition of Indigenous and non-Indigenous community-scale,resource-dependent business leaders from across the country. Our mission is toestablish national policies that recognize sustainable businesses as compatible withhealthy lands and oceans, and to include those businesses in conversations about
resource access at every step of the decision-making process. Our work is guided by aﬁrm commitment to social equity, local and traditional wisdom, and triple bottom line
solutions that restore social, ecological and economic health.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

We support the broad strokes of this seafood strategy - NOAA’s stated purpose iswell-aligned with our own and many of our partners’. We’d like to take this opportunity
to advocate for a true community engagement process that centers community-scale
and tribal ﬁsheries to help you build out the actions, timelines, and milestones for thisroadmap.
The process of building this strategy needs to begin with ﬁshing andﬁshery-dependent communities. Strategic, adaptive, and hard-working,community-scale ﬁshermen are your eyes on the water. Not only are they on the front
lines of climate change and climate adaptation, these business leaders are committed
to feeding their communities. In terms of building out this strategy, what better place tostart?
Engaging in genuine partnership from the ground up can help inform our country’s
seafood strategy going forward. Please make deep community engagement thestarting point for the next phase of development of this strategy. Start with
community-scale ﬁshermen and ﬁshery-dependent tribes, and engage with their ideas
as you pull together the details of this strategy. Additional comment periods should bebuilt into the process along the way.
Community-scale ﬁshing businesses are the backbone of the commercial ﬁshingindustry and their needs should be centered in any evolution of ﬁsheries management
policies. Furthermore, policies that help sustain and/or increase sustainable domestic
wild capture production should be designed to meet the needs of community scaleﬁshermen. Working with community partners across the country will grant NOAA the
opportunity to co-design strategies that are keyed to different ﬁsheries, with theirdifferent needs, in all regions of the country.
The rising cost of ﬁshery access means small scale ﬁshermen are struggling to remain
viable participants in local ﬁsheries. . Fishery trusts and community permit banks haveworked to anchor access in ﬁshery dependent communities while also preventing
overﬁshing. Providing capital and low interest loans to ﬁshery trusts and permit banks
will support access for community-based young ﬁshermen, ﬁshermen of color, andothers who have historically been shut out of permit or quota systems Ultimately, wewant to see investment in a strategy that supports living wages for all workers along
the supply chain.
When strengthening the overall seafood sector, more investment is needed forinfrastructure and working waterfronts. Investment on this level can help keep bothPublic comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

jobs and seafood in local communities. Concerted investment is needed in these areas(especially in rural communities), not just to sustain the industry but to propel it
forward, especially if that investment promotes decarbonization and value-added
processes - which are essential to the future development of the industry.
Aquaculture is often touted as the way to feed a growing population and we agree thata robust sustainable low-trophic mariculture sector is a key piece of domestic foodsecurity as well as a factor in growing our blue economy. However, offshore
open-ocean aquaculture is often at odds with commercial ﬁsheries and we urge you to
support an aquaculture opt-out on the state level. Any investment by NOAA inaquaculture should complement rather than compete with wild capture ﬁsheries, andnet pen ﬁnﬁsh aquaculture, which NOAA does not regulate, should not be a part of theagency’s seafood strategy. The further development of the farmed shellﬁsh andseaweed industries should take precedence over ocean-based ﬁnﬁsh aquaculture. This
includes investment in shoreside infrastructure to help boost local processing capacity
and create jobs in the blue economy.
Our ﬁnal recommendation concerns the Strategy’s implementation plan, wherein
speciﬁc actions and partnerships will be listed. This plan should speciﬁcally call for theestablishment of partnerships between NOAA and external organizations representing
Tribal Governments, coastal communities, and coalitions of ﬁshing and seafoodbusinesses. Memoranda of understanding for the development of policy strategies andengagement with small-scale ﬁshing and seafood businesses, similar to the agreement
our organization recently signed with the Department of the Interior (available at
bit.ly/ASBN-DOI-MOU), would serve NOAA well as it seeks to become a more
stakeholder-focused organization and enhance its service model. Truly productive,
mutually beneﬁcial, bilateral partnerships should be the most vigorously pursued
result of NOAA’s Seafood Strategy implementation.
Once again, we thank you for the opportunity to provide feedback andrecommendations on NOAA’s seafood strategy. BCCA is just one part of a muchbroader network of ﬁshing communities around our country’s coasts who are working
at building a more socially and ecologically sustainable blue economy, and we hope
NOAA will look to this network for guidance as you build out your strategy.
Sincerely,
Businesses for Conservation and Climate Action

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

NOAA Fisheries
1315 East-West Highway
Silver Spring, MD 20910

March 24, 2023

SUBMITTED ONLINE

RE: Draft National Seafood Strategy – Request for Public Input
To Whom it May Concern:
We appreciate the opportunity to submit comments on the Draft National Seafood
Strategy (the Draft). From our humble beginnings in 1941, Pacific Seafood has grown toemploy more than 3,000 team members across 41 facilities in 11 states. Still family
owned, Pacific Seafood manages all parts of the supply chain from harvesting/fishing toprocessing, and distribution in order to provide customers with fresh, sustainable, highquality products.
Pacific Seafood is in full support of the Draft’s Purpose, Strategy Drivers, Strategy
Framework, and Goals, but we wish to provide two recommendations specific to someof the stated Purposes and Goals of the Draft to help inform the Strategy
Implementation Plan.
Recommendation #1: More West Coast seafood needs to be included in the U.S.
Department of Agriculture's (USDA) National School Lunch Program (NSLP).
The Draft’s Purpose states: “Our vision is to ensure that: The U.S. seafood sector contributes
to the nation’s climate-ready food production and to meeting critical domestic nutritional
needs.” The Draft’s GOAL 3: “Foster access to domestic and global markets for the U.S. seafoodindustry” points to the need for U.S. (seafood) Market Development and to “Work withfederal partners and others to identify and develop U.S. seafood markets and put more U.S.
seafood back on U.S. plates.”
The USDA’s NSLP provides healthy meals to millions of kids from low-income
households. Dietary guidelines show school age kids should eat 4-10 oz. of seafood
weekly. Shockingly, a recent study 1 from the U.S Government Accountability Office1

https://www.gao.gov/products/gao-23-105179

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

(GAO) found seafood made up just 1-2% of all animal proteins that USDA purchased
for the program (about 3 oz. per student per year) in FYs 2014-19. This identifies aglaring opportunity to address the Draft’s GOAL 3 to “develop U.S. seafood markets
and put more U.S. seafood back on U.S. plates.”
The GAO study points to several factors — allergy concerns, student preferences, andcost—that affected states' and school food authorities' efforts to offer seafood. While the
USDA could support them by providing nutrition education, allergen and food safety
training, and recipes, the issue of cost remains to be a hurdle that is preventing West
Coast seafood from making it on to more of our kid’s lunch plates at school.
Furthermore, school districts can currently choose to bypass existing Buy American
provisions and purchase imported food products if they document a “significant costdifferential” between domestic and imported products. To help address this, PacificSeafood submitted comments2 on November 2, 2021, in response to the USDA’s
Request for Information: Buy American in the National School Lunch Program andSchool Breakfast Program. We recommended that the “significant cost differential”
exception to the existing Buy American provisions be eliminated. Currently, there is no
Food and Nutrition Service standard that provides sufficient assurance that domestic
seafood producers and processors need to competitively compete with cheaper, lower
quality, and less sustainable foreign produced goods which are typically associatedwith increased carbon emissions compared to domestic sources. Instead, its application,
permitting foreign-sourced products into school lunches, has disrupted West Coastseafood sales into the school food program. This is particularly problematic at thepresent time when the entire U.S. seafood industry is working to recover from thedisruption of COVID-19 and the devastating impact it has had on the entire U.S.
seafood market chain. This cost exception is an open invitation for foreign suppliers totake over school food markets.
We want NOAA Fisheries, the USDA, and the world to know that Pacific Seafood andthe rest of the West Coast seafood industry is fully committed to providing the NSLP
with the highest quality, sustainable seafood now and far into the future. Today, Pacific2

https://www.regulations.gov/comment/FNS-2021-0027-0151

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Seafood offers 34 Marine Stewardship Council (MSC)-certified species and 20 MSCcertified sustainable facilities, plus our Best Aquaculture Practices (BAP)-certified
steelhead farm and being the first and ONLY company in the world to offer BAP FourStar certification. Our West Coast seafood products are not only 100% sustainably
sourced and processed in the U.S. by the hands of U.S. workers, but they are alsoavailable year-round and at a reasonable price.
In addition to being 100% sustainably sourced and processed in the U.S. and available
year-round at a reasonable price, West Coast seafood is also very nutritious. Up until
recently, there was no species-specific nutrient information available for West Coast
Groundfish species. That was until 2022 when Positively Groundfish, a non-profit tradeassociation, set out to fill this knowledge gap. They commissioned Exact Scientific
Services Lab, a certified food analysis lab in Bellingham, WA, to carry out an
independent study of 10 of the most common groundfish species. 3 The analysis
revealed that West Coast groundfish species are some of the most nutritious foods inexistence, not just compared to other seafood, but all animal proteins. While seafood is
overall healthy, some species analyzed in this new study pack a much greater
nutritional punch than other popular species. For example, calorie for calorie Lingcod
has twice as much protein as wild Alaska King Salmon, and Pacific Dover Sole likely 4
has the highest protein content of any food. This new study helps to highlight how
introducing more West Coast seafood into the USDA’s NSLP comports to the Purposeof the Draft as far as “meeting critical domestic nutritional needs.”
Recommendation #2: Work with USDA Rural Development to create a Seafood
Processing Expansion Program that provides grants to help eligible processors
expand their capacity.
Although several COVID-era USDA programs provided funds to address issues withthe supply chains of other proteins such as beef and poultry, the same was not true for
seafood, and we believe there is an opportunity to address various supply chain issues.

https://www.positivelygroundfish.org/nutrition“likely” because there may be foods that are not in the USDA’s nutrient database or have never been
analyzed.

3
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USDA Rural Development administers a Meat and Poultry Processing Expansion
Program (MPPEP) 5 to provide grants to help eligible processors expand their capacity.
USDA Rural Development designed the MPPEP to encourage competition andsustainable growth in the U.S. meat processing sector, and to help improve supply
chain resiliency. A similar grant program for seafood processors would help NMFS toaddress the Draft’s GOAL 4 to “Strengthen the entire U.S. seafood sector” and the need to“Work across federal agencies to modernize U.S. seafood infrastructure (e.g., vessels, hatcheries,
port and dock facilities, processing, storage, working waterfronts) to strengthen and enhance
opportunities for coastal seafood communities and regional food economies.”
As lack of workforce continues to be one of the major issues plaguing the seafood
processing industry, automated fish processing machinery is needed to supplementlack of hand filleters while increasing throughput but requires multimillion dollar
investments that are often unattainable. Funds from a Seafood Processing Expansion
Program grant could be used to offset significant capital expenditures on cutting edge
fish processing machinery. Such grants could also be used to invest in additional tunnel
freezers to expand cold storage capacity, and repairing the aging docks that support
critical shoreside infrastructure.
We thank you for the opportunity to provide comments. We look forward to theopportunity to work with NOAA Fisheries and USDA officials to maximize
opportunities for West Coast seafood procurement for the benefit of our U.S. seafoodindustry and to benefit the health of over 30 million children across the U.S.
Sincerely,

Jonathan Gonzalez
Government Affairs Manager

https://www.rd.usda.gov/programs-services/business-programs/meat-and-poultry-processingexpansion-program5

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

George Bradshaw
President
Larry Collins
Vice-President
Lorne Edwards
Secretary
Lori French
Treasurer

PACIFIC COAST FEDERATION
of FISHERMEN’S ASSOCIATIONSIn Memoriam:

Nathaniel S. Bingham
Harold C. Christensen
W.F. “Zeke” Grader, Jr.

Please Respond to:□ California Office

Glen H. Spain, Acting Executive
Director, Northwest Regional Director
Vivian Helliwell
Watershed Conservation Director

www.pcffa.org[X] Northwest Office

P.O. Box 11170
Eugene, OR 97440-3370
Tel: (541) 689-2000

P.O. Box 29370
San
DeFrancisco, CA 94129-0370
Tel: (541) 689-2000

17 March 2023
Reply Email: fish1ifr@aol.com

Comments Re: Draft National Seafood Strategy
Dear Ms. Diedrick:Thank you for requesting our input on the draft National Seafood Strategy. We hope that you
will take our comments as an in-kind contribution to the overall success of your efforts. The key
to restoring fishing infrastructure, markets, local food security, a younger fleet, and resilient fishingcommunities is fishing opportunity to access sustainably managed fish stocks. To that end, thePacific Fisheries Management council requires a “harvestable surplus,” above minimum numbers
needed for viable reproduction, before commercial, recreational, or subsistence fishing. It also
depends upon access to fishing areas, which is getting more and more limited by other uses of theocean.
The Pacific Coast Federation of Fishermen’s Associations (“PCFFA”) is the West Coast’s
largest trade organization for commercial fishing vessel owners and family commercial fishing
operations. For nearly fifty years, PCFFA has advocated to ensure the rights of individual
fishermen and to fight for the long-term survival of commercial fishing as a livelihood and way oflife. The livelihoods of PCFFA’s members who rely on ocean harvest of Pacific salmon are greatly
affected by the damaged health and abundance of once numerous salmon. The decline of
California’s salmon species has severely impacted PCFFA members by limiting commercial
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PCFFA/IFR Comments
Re: Draft National Seafood Strategy
17 March 2023

harvest opportunities, both through lost production of impaired stocks and because of closures
imposed on the fishing fleet to protect impaired salmon populations.
The Institute for Fisheries Resources (“IFR”) is a nonprofit, public interest, marine resources
protection and conservation organization dedicated to protecting the natural resources and seafoodbounty of the Pacific Ocean along the western seaboard of North America. IFR was founded in
1992 by the Pacific Coast Federation of Fishermen’s Associations (PCFFA) when West Coastsalmon fishing was being shut down because too many salmon bearing rivers have been blocked,
diverted or polluted over the past decades to maintain these valuable salmon runs, severely
impacting the economic health of several local communities.
IFR’s mission is to support working fishing families and crews to protect, restore and maintainsalmon and other fish stocks and their “critical habitats” in order to produce a “harvestable surplus”
well above the self-sustaining levels required by the ESA. Since our future is tied to the future ofseveral ESA listed salmon stocks, we are committed to the salmon Habitat Protection Policy
established by the Pacific Fisheries Management Council (PFMC) in 1986, the primary goal ofwhich is “...no net loss in the productive capacity of any marine, estuarine or freshwater habitatsthat sustain Pacific Salmon.”The attempt to meet the challenges stated in the Draft National Seafood Strategy are admirable.
However, there are some problems that still need to be addressed. For example, you omitted oneof the most important challenges facing our West Coast fishing communities: the near extinctionof one of the most valuable commercial stocks, Pacific salmon.
California’s three biggest historical salmon-producing river systems -- the Sacramento, theKlamath and the Eel -- are all in trouble. Egg-to-fry survival (ETF) of winter-run Chinook in the
Sacramento River System was only 2.56% in 2021, and 2.17% in 2022, (back-to-back record lows)when the average ETF survival rate for this ESA-listed stock from 2002 to 2020 was 23.4%.
Returns of Chinook salmon to the Eel River System are now around 1.5-2% of historical numbersof fish. Klamath River Chinook natural spawner salmon escapement this year is around 20,000
fish, and requires a minimum recruitment of 40,700 natural spawners before any fishing can takeplace. The 2023 projection for Sacramento River fall-run Chinook, estimated at 169,767 adults, is
one of the lowest forecasts since 2008. The Klamath fall-run Chinook forecast is 103,793 adults,
the second lowest forecast since 1997. As a result, the Pacific Fisheries Management Council has
recommended a complete closure of the salmon season for California and most of Oregon this year
(see reference below).
The severe decline of our robust salmon fisheries greatly accelerated in the 1970’s (although
the destruction of their habitat began with the beaver, gold, and timber “rushes”) and has continued
to dive until only a tiny percentage of the salmon are left, and most are listed as threatened or
endangered under state and federal ESA criteria. We have zero salmon fishing opportunity in theocean this year, and likely for several years to come. In NOAA’s Socioeconomic section, it is clearthat NOAA has the data showing the decline. Therefore, we were surprised to hear Michael
Robino, Senior Advisor for Seafood Strategy, say on a NOAA “listening session” that the West
Coast fish stocks have been recovered. Although certain rockfish (Sebastes complex) have2

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PCFFA/IFR Comments
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17 March 2023

recovered faster than expected, and many others are doing well, salmon have declined to near
extinction.
Meanwhile, other alternate fisheries were becoming more limited by closures for stock
rebuilding programs, such as the Rockfish Area Closures and trawler buybacks. Small hook-andline boats were shut out of the remaining rockfish quotas. Privatization of this public resource bygifting of Individual Quota Shares also concentrated the wealth upward and out of local
communities.
Access:Marine Protected Areas (MPA’s) are being presented as a cure-all for international fishingproblems, at the expense of access to local seafood. See Appendices for PCFFA’s policy on
MPA’s. Also, the 30x30 program needs to recognize sustainable fishing as conservation, and not
shift fishing effort into smaller and smaller areas with more fishing closures. The Pacific Fisheries
Management Council is already managing fisheries very conservatively, including providing
protections for critical marine ecosystems and habitat. Additionally, fish stocks move around in
the ocean as the climate shifts, so closed areas are not necessarily protecting moving stocks.
NOAA says they want to help fishermen not get run over by offshore wind, but we have notseen any evidence of NOAA involvement yet, and the fishermen have been dealing with it for
years already.
Public Participation:
In responding to NOAA’s request for public input on the “listening sessions,” it was surprisingthat only a handful of people spoke on such a vital national issue. It makes us wonder how
serious/effective NOAA is about outreach for public input. In the Draft, it says that the Seafood
Policy is part of a “suite of strategies,” but you don’t say what they are. It was only by searching
deeply into NOAA webpage layers that we discovered that the Seafood Policy is a small part of alarger NOAA Fisheries Strategy Plan for 2022-2025, and that is part of a Department of Commerce
Strategy Plan for 2022-2026. Most people will not have the time or skills to search for these
documents. NOAA did not elaborate about these programs, which seem to have multiple
overlapping parts. It is not clear how the different programs work together; for example, habitat is
an essential part of seafood resilience, but is a separate program.
In response to a process question on one of the “listening sessions” it was stated that there are
five “focus areas” involved in NOAA fisheries strategy. A search for NOAA “focus areas” turned
up only the Habitat Blueprint, which focuses resources to a few certain places. On the West Coast,in California, the Russian River was chosen in 2013, it says, to receive focused funding and sciencein order to “improve habitat conditions that support fisheries, coastal communities, and marine
life, and provide environmental, economic, and cultural benefits” and “maximize its investments
and the benefits to marine resources and coastal communities.” Focusing on the Russian River
won’t achieve your goals. However, habitat is the key to all your other goals, so having separate
programs is part of the problem.
Our coastwide commercial fishing group did not hear about input opportunities for choosing
the Russian River as the “focus area” for resources to support habitat. There should always be aprocess for wide public input on such decisions. That choice shows a complete lack of3

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PCFFA/IFR Comments
Re: Draft National Seafood Strategy
17 March 2023

understanding of the situation here concerning protecting, restoring and maintaining resilient
fisheries and fishing communities. The Russian River is the wrong river to invest in to achieve
your goals; our three major salmon producing river systems are the Sacramento, Klamath, and theEel.
Markets:
Salmon fishing was the mainstay of California and West Coast fisheries for decades, until theirspawning and rearing habitat became so multiply impacted by inland extractive practices acrossthe landscape that by now the runs have declined to almost nothing. Thousands of familybusinesses went under—a boat and permits become worthless without fishing opportunity. We lost
our world markets from lack of production—our New York lox market, our French market, ourJapanese market. Declines of the natural runs occurred at the same time as imports of farmed
salmon from Norway, Chile, and British Columbia were booming. These markets are difficult torecover. Complicating world markets, fish exports and imports are often used as bargaining chips
in international trade tariff conflicts.
Additionally, with loss of fish production, attrition reduced multiple competing fish processors
to one main monopoly company, Pacific Seafood, with a record of settling anti-trust violations for$520 million (see reference below). This year the ex-vessel price for choice Dungeness crab, analternate fishery whose stocks have remained strong, started at $2/lb., less than half of last year’s
price, while the retail cost in the store is dollars per pound higher than last year, while operating
costs have soared. Finally, Pacific Seafood is being sued again for alleged price-fixing (seereference below).
Habitat:
In recent years, the destruction of these already ESA-listed salmon populations has been nearlycompleted by the Bureau of Reclamation water release policies, prioritizing water contracts oversalmon, that have cooked the salmon fry and made the rivers uninhabitable. NOAA Fisheries hasapparently not been able to ensure that endangered and threatened salmon get the cold water thatNOAA and California Department of Fish and Wildlife say they need in the Klamath andSacramento River Systems. Cold water temperatures provided at the right seasons could help
reverse that process.
When the draft talks about “protecting and restoring” habitat, the third part and most importantpart is “maintaining” those stocks/conditions. This has not been done for so long that the salmon
have now declined to the point where it will be very difficult to recover them.
Penalties for violations of current state regulations on illegal diversion and sediment pollution
are inadequate, so damage to the water quality resources that support salmon are written off byserial violators as the cost of doing business.
Here are our comments to specific sections, as follows:
1. Sustain or increase sustainable U.S. wild capture production
The problems of infrastructure decay, loss of markets, and monopoly of processors, graying of
the fleet and its operators, all can be addressed by increasing access to sustainably fished andrecovered stocks, and by protection, restoration, and maintenance of ESA-listed anadromous
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PCFFA/IFR Comments
Re: Draft National Seafood Strategy
17 March 2023

salmon stocks to a level of having a “harvestable surplus” above and beyond the viable, selfsustaining populations needed for ESA de-listing.
Unfortunately, inland habitat for these stocks have been declining for several decades, until theocean salmon season is completely closed this year.
2. Increase sustainable U.S. aquaculture production
Aquaculture needs to be regulated so that it doesn’t pollute freshwater, groundwater, or
estuaries. Offshore pen-raising of fish has been outlawed in Washington State after massive
escapes of genetically different species, and they are also a large source of pollution due to fecal
waste matter concentrations, like concentrated feed lots. Atlantic salmon farms in British
Colombia have been a source of sea lice infestations on wild salmon stocks. Inshore facilities suchas the proposed Nordic Aquaculture facility in Samoa, California, is proposing to pump 10 million
gallons/day of Humboldt Bay estuary water through their buildings and release it into the sea at ahigher temperature. It would be difficult to ensure that entrainment of larvae does not occur.
Temperature and low oxygen pollution may be a problem for the increase in toxic algal bloomsthat have increasingly impacted markets and marine mammals. Additionally, such large
aquaculture projects require a large investment of infrastructure by local agencies that can detractfrom efforts to recover native stocks, require massive amounts of electricity, and compete inmarkets for wild seafood products.
3. Foster access to domestic and global markets for the U.S. seafood industry
Product is first required, to create access to markets. Fisheries have long been used by federal
agencies as bargaining chips in international and border trade and tariff negotiations.
4. Strengthen the entire U.S. seafood sector
The Magnuson-Stevens Fisheries Management Act was passed in 1976 and created theFisheries Management Councils. The Pacific Fisheries Management Council has a Habitat
Committee, and in 1986 they developed the following Habitat Policy. The NOAA could approach
their goals by including and using this policy:“Pacific Fisheries Management Council, Habitat Committee
Salmon Habitat Protection Policy, 1986▪

There shall be no net loss in the productive capacity of any marine estuarine or freshwater
habitats that sustain Pacific salmon;▪

Pacific salmon shall be assured co-equal treatment with other purposes of water and land
resource development programs;▪

There shall be vigorous efforts by responsible public agencies to restore and strengthensalmon stocks.
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PCFFA/IFR Comments
Re: Draft National Seafood Strategy
17 March 2023▪

State and federal regulatory agencies should be strict in requiring the best management
practices available for timber harvest, mining, water development, agriculture and otheractivities under their control that can have adverse effects on salmon; and▪

Water development programs should be reviewed and undertaken on a comprehensive
or programmatic basis, in order to identify and eliminate cumulative or “synergistic”
impacts in drainages where salmon spawn and rear.”

The federal criteria for ESA listing and de-listing describe the problems that must be overcome
to develop actions to recover the fishing industry and achieve the goals of NOAA’s National
Seafood Strategy. Pacific salmon populations must be de-listed before we can have the thriving“harvestable surplus” we need to have resilient fishing communities.
“Under the ESA, a species must be listed if it is threatened or endangered because of any of
the following 5 factors:
1. Present or threatened destruction, modification, or curtailment of its habitat or range;
2. Over-utilization of the species for commercial, recreational, scientific, or educational
purposes;
3. Disease or predation;
4. Inadequacy of existing regulatory mechanisms; and5. Other natural or manmade factors affecting its continued existence.
…Once a species is listed under the ESA, NOAA Fisheries must determine whether there
are areas that meet the definition of critical habitat.”(https://www.fisheries.noaa.gov/national/endangered-species-conservation/listingspecies-under-endangered-species-act)////

Thank you for considering our comments.
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PCFFA/IFR Comments
Re: Draft National Seafood Strategy
17 March 2023

Glen Spain,
Acting Executive Director
PCFFA/IFR
Vivian Helliwell,

Watershed Conservation Director
PCFFA/IFR

Cc: Gina M. Raimondo, Commerce Secretary
Janet Coit, Assistant Administrator NOAA Fisheries
Kelly Denit, Director of Office of Sustainable Fisheries
Kim Damon-Randall, Office of Protected Species
Carrie Selberg Robinson, Office of Habitat Conservation
Laura Diedrick, External Affairs
Michael Robino, Senior Advisor for Seafood Strategy
Sarah M Shoffler, National Seafood Strategy Coordinator
Gabriela McMurtry, Fishery Policy Analyst

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PCFFA/IFR Comments
Re: Draft National Seafood Strategy
17 March 2023

References:https://www.fisheries.noaa.gov/feature-story/noaa-fisheries-strategic-plan-2022-2025
NOAA Fisheries Strategic Plan for 2022–2025
https://www.commerce.gov/sites/default/files/2022-03/DOC-Strategic-Plan2022%E2%80%932026.pdf
U.S. Department of Commerce Strategic Plan | 2022 – 2026
Report: Pacific Seafood settles antitrust lawsuit, Portland Business Journal, April, 2012https://www.bizjournals.com/portland/morning_call/2012/04/report-pacific-seafood-settles.html
https://sfstandard.com/business/california-crabbers-sue-seafood-giant-alleging-dungeness-pricefixing/
Pacific fishery council to close California salmon fishing in 2023.
Dan Bacher Special to The Stockton Record:
https://www.recordnet.com/story/sports/outdoors/fishing/2023/03/15/pacific-fishery-council-toclose-california-salmon-fishing-in-2023/69981901007/

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PCFFA/IFR Comments
Re: Draft National Seafood Strategy
17 March 2023

APPENDIX
Marine Protected Areas (MPAs)and Fishermen (PCFFA Statement February, 2002)
PRINCIPLES OF THE PACIFIC COAST FEDERATION OF FISHERMEN’SASSOCIATIONS REGARDING MARINE PROTECTED AREAS
Marine Protected Areas (MPAs) occur along the coast of California and many othercoastal areas of the nation. The sizes, purposes, and regulations on use of theseareas vary greatly, as do the terms to describe them. Some, for example, have few
restrictions, while others may be complete ‘no-take’ areas. MPAs have garneredmuch attention recently among researchers and marine advocacy groups as a tool
for fishery management, protecting marine habitats, or preserving unique marine
ecosystems. While MPAs may offer promise for the conservation and managementof marine fisheries and their habitats, much is unknown about what benefit, if any,has been derived from existing MPAs for the conservation and management ofmarine fish and their habitats (other than in small, localized areas) or what benefit
may be derived from the establishment of new MPAs. To date, there has been agreat deal of hype, but precious little science.
Although MPAs may offer potential benefits for marine fish resources and theirhabitats, they may pose a real danger, too, if strict adherence to good science is not
maintained regarding their purposes and siting. MPAs, particularly those imposing
no-take, could result in vast areas of prime fishing grounds being ‘locked up’, which
could needlessly impact fishery production. Moreover, no-take MPAs may result inheavier fishing or other activities outside of their boundaries, exacerbating rather
than resolving fish resource problems. MPAs, by themselves, may also create a
false sense of security about fishery resources – neither fish nor currents respect
artificial boundaries.
In California, for example, reserves have been in existence for as long as 39 years,
yet little data exists regarding their overall performance. To date no funding has
been dedicated to ongoing monitoring of these reserves, even in the developing
Channel Islands process. The fishing industry does not support the establishmentof any reserve without a structure for assessing its performance and the funding
for that assessment, nor of any reserve whose establishment is inconsistent withthe principles of this document.

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PCFFA/IFR Comments
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17 March 2023

To initiate a rational and science-based discussion on MPAs, mindful of the need toconserve and manage fish resources on a sustainable basis, and to protect marine
habitats and ecosystems and the fisheries that depend on these fish resources, thePacific Coast Federation of Fishermen’s Associations establishes the following
principles:
1. No establishment of an MPA shall inhibit sustainable fisheries within that
MPA that have negligible impacts on the habitats or species of concern.
2. MPAs are not a substitute for other forms of fishery management, including
seasons, quotas, or gear restrictions, nor shall MPAs be a substitute for prohibitions
on pollution, dumping, or the introduction of exotic species.
3. MPAs shall not be used as a tool to reallocate resource use. Creation of any
zones for recreational fishing only, or for dive fishing only, must be balanced bycreation of zones of comparable value for commercial fishing only.
4. Planning and management for the marine environment must be done on aregional scale, and be catch-based and multiple-use. The planning approach
must ensure participation by stakeholders and other interested parties from the
beginning. Land use and other non-fishing impacts must also be addressed.
5. Methodologies and criteria for assessing performance of all MPAs must be
developed before new MPAs are implemented; this includes funding for
performance assessments.
6. The review of the effectiveness of existing MPAs, as well as the siting andestablishment of any new MPAs, must include fishing men and women fromboth the commercial and sport sectors. This is necessary not only because MPAs
affect or could affect fishing areas, but more importantly because fishermen havean intimate and working knowledge of the marine environment, including that ofmany areas of the ocean where there has been no research.
7. A thorough and science-based review needs to take place of all existing
marine protected areas along the U.S. Pacific coast to determine theireffectiveness for either: a) providing baseline research information; b) protecting
critical marine habitats; or c) protecting specific marine fish or organisms. This
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PCFFA/IFR Comments
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17 March 2023

review should be undertaken by a panel, including marine scientists, appropriate
fishery agency representatives, knowledgeable commercial and sport fishermen,
and knowledgeable marine conservation representatives, and will include a reportwith recommendations for each existing MPA and no-fishing zone as to its
effectiveness and whether there should be any changes in regulations andboundaries, and whether it should be maintained, reduced, expanded, or
eliminated, and why.
A similar review must be conducted of the types and effectiveness of MPAs in
use in other parts of the world to provide the state, scientists, and the fishingindustry guidance on whether new MPAs should be established offshore California
and other states and, if so, what their objectives should be, their appropriate size,
and types of regulations for their use. It is important to recognize the uniquenessof the U.S. Pacific Coast when developing objectives. Measures that are appropriate
in tropical waters may not be appropriate here.
8. If, after thorough review, there is a decision to proceed with revising current
MPAs or establishing new ones, the objectives of each MPA must be statedclearly; i.e., whether it is to provide baseline research, protect habitat, or protect
specific species, or some combination thereof. Regulations for use of the MPA must
be appropriate to the objectives. A reasonable time frame for meeting the MPA’s
objectives must be included.
9. The regulation of the types of use to be permitted in each MPA can andshould vary depending on the objectives of the MPA, with MPAs established as
any one of three or more types, including those to protect habitats, those to protect
specific species of marine fish or organisms, and those where take is prohibited.
10. Where no-take MPAs may be established, not only must all types of fishing
be prohibited, but so too must any unpermitted scientific collection or any
other form of removal from within the boundary of the MPA be prohibited. No
dumping or introduction of pollutants shall be permitted in any no-take
MPA, and human access shall be greatly restricted in order to maintain the pristinecondition of the MPA and its value for baseline research.
11. In the siting of any new MPAs, factors to be considered shall include theuniqueness of the area, its biological productivity/diversity or special habitats, thehuman impacts on that area (including fishing, other types of aquatic harvesting11

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PCFFA/IFR Comments
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or collection, pollution, and structural changes such as dumping, artificial reefs, oroil rigs). Siting shall be based solely on the evidence regarding the site
itself and without regard to proximity of existing parks, marine sanctuaries, or
research institutions.
12. Recent changes in fishery management practices, fishing effort, and gear
types used must be included in consideration of any new MPAs so as not to use
MPAs to address problems already addressed by existing fisheries
management. The entire existing and proposed web of federal and state
fisheries regulations applicable to the area must be considered in designing
any new MPA.
13. In the establishment of any new MPAs, careful consideration shall be given
to what, if any, impacts the establishment may have on fishing, or the use ofcertain types of fishing gear, what impacts an MPA may have on fishing effort
outside the MPA boundary, and what steps can be taken to mitigate any impacts
on fishing from the establishment of an MPA. Any such impacts shall be
distributed among fishermen in a fair and equitable manner. Every effort shallbe made to protect existing fisheries, consistent with the science-based selection ofunique or productive areas deserving of some level of protection under MPA
status.
14. Where significant reduction in fisheries is an unavoidable consequence of
establishment of an MPA consistent with the above guidelines, funding for thecompensation of fishermen in proportion with the reduction of the fishery
shall be part of the establishment of the MPA.
15. Recognizing a changing ocean environment and the continuing increase in
human knowledge of the marine environment, MPAs shall be subject to adaptive
management, with regular reviews conducted of their performance while
recognizing that regulatory or protective measures may not have immediate
results. Reviews should include assessment of non-fishing factors that inhibit the
productivity of an MPA, including non-point source pollution problems. Under anadaptive management program, utilizing experts from the fishery agencies,
marine researchers, social scientists, and the fishing and conservation community,
MPAs should be subject to periodic review of their regulations, boundaries,
and whether some existing ones should be eliminated and/or new ones
established.
#####
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Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

March 24, 2023

Ms. Janet Coit
Assistant Administrator, NOAA Fisheries
1315 East-West Highway
Silver Spring, MD 20910
Via email: janet.coit@noaa.gov
Dear Assistant Administrator Coit:NOAA Fisheries’ draft National Seafood Strategy (Strategy) envisions a thriving and resilient
domestic U.S. seafood economy that can deliver sustainable, responsibly produced, andnutritious U.S. seafood to consumers at home and around the world. In doing so, it can deliver
sustainable benefits to commercial fishing families, communities, and seafood support
businesses across the United States. This vision will only happen, however, if the Strategy’s highlevel words are translated into meaningful actions at all levels of the Administration andimplemented through whole-of-government coordinated policy and regulatory approaches, manyof which would be unprecedented. Members of the Pacific Seafood Processors Association(PSPA) support the stated purpose of the Strategy and strongly urge vigorous implementationof it, recognizing that it provides the best opportunity for launching the interagency policy
leadership and collaboration needed to ensure the future viability and competitiveness of U.S.
seafood producers.
PSPA members are among the largest seafood processing companies operating in and off
Alaska, positioned at the center of the United States’ largest seafood supply chain. Our
members are deeply invested in supporting the health and sustainability of Federal and State of
Alaska fisheries. Members companies buy billions of pounds of sustainably harvested wild
Alaska pollock, cod, salmon, halibut, crab, and other fish, which they turn into premium seafood
products for consumers at home and around the world. We are, therefore, deeply engaged in
the Federal government’s roles in supporting the operational and commercial aspects of theseafood supply chain. Alaska’s seafood industry generates $15 billion in total U.S. economic
output annually, including spending for safe operations, capital reinvestments, regulatorycompliance, payroll and compensation, marketing, innovation, and other costs. Alaska’s
industry supports more than 31,000 commercial fishermen and 27,000 processing workers in
160 shore-based plants, 52 catcher-processor vessels, and 30 floating processors in Alaska.
PSPA reviewed an early draft of this Strategy, supplying written comments to NOAA Fisheriesin March 2022. PSPA staff and members were guided by the following considerations, which
we repeat here:
First, we recognize that managing fisheries for sustainable production and supporting
seafood markets occur in separate, but highly interdependent, spheres. Fisheries
www.pspafish.net
ANCHORAGEJUNEAUSEATTLEWASHINGTON DC

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

production requires a highly technical and science-based process for setting
responsible catch limits and other rules for fish harvest, and this process is thefoundation upon which the U.S. seafood industry is based. In turn, seafood markets arecomplex economic and distribution systems that determine the prices ultimately paid
for fish, and fair, competitive access to these markets enables seafood producers to
successfully generate and return economic benefits to fisheries and seafood
stakeholders. The U.S. seafood supply chain integrates both fisheries production andseafood markets. Supporting this supply chain holistically will deliver the greatest
overall benefits to the Nation, as directed by the optimum yield and other provisions of
the Magnuson-Stevens Act (MSA). In fact, commitment to comprehensive U.S. seafood
supply chain support should not only be included in the goals in this Strategy – it shouldbe embraced by NOAA Fisheries’ leadership and staff, carried forward in the agency’score mission, and deployed through sustained agency operations in the regions.
Second, we understand that in developing and implementing this Strategy to advanceresilience and competitiveness, NOAA Fisheries must operate within the bounds ofcurrent statutory authorities. Statutory mandates and their resulting policies andregulations affecting fisheries and seafood production are exceedingly complex andpresent tremendous cost to multiple agencies and regulated entities. A strategic
approach to policy and regulation under existing authorities will enhance the efficiency
and effectiveness of NOAA Fisheries and other agencies that regulate the U.S. seafood
supply chain. Importantly, it will also identify opportunities for NOAA Fisheries to best
exercise its discretion, both internally and in collaborating with other agencies, in
support of statutory responsibilities and common policy goals.
Third, and perhaps most importantly, developing and successfully implementing a
Seafood Strategy will require NOAA Fisheries’ leadership to recognize the outstanding
merits of the U.S. fisheries and seafood industries and defend against unwarranted
threats. By any measure, this industry achieves remarkable performance. U.S. wild
capture commercial fisheries are managed to ensure sustainability and advance all
National Standards under MSA. Fisheries management follows laws for sustaining
stocks, conserving biodiversity (protecting habitat, marine mammals, and endangered
species), and protecting cultural and historical resources. Robust U.S. laws mandatethat fisheries and seafood production follow workplace safety and protection rules, that
seafood is safe for consumers to eat, and that associated environmental impacts areminimized and mitigated (such as with clean water). Companies utilize internal
controls and audits, backed by third-party verification, to maintain product traceability
and integrity of their supply chains. Wild seafood production, such as Alaska pollock,has among the lowest carbon footprints of any animal protein. The USDA’s Dietary
Guidelines for Americans highlight remarkable health benefits of seafood, including for
pregnant women and early child development, and recommends increasing
consumption levels for improved public health. U.S. seafood is ideally suited to meet
public health and nutrition needs, as well as promote compliance with the Biden
Administration’s “Buy American” initiatives.

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Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Given these qualities, U.S. commercial fishermen and seafood processors are wellpositioned to provide global leadership for commercial fisheries, support jobs andcommunities, and thrive as a vital food source. Without priority consideration in NOAA
Fisheries’ core mission and leadership in delivering an effective strategy, this may notcome to pass. This Strategy to advance resilience and competitiveness must recognizethat fishermen and seafood processors not only face changing environments and global
supply chain vulnerabilities, but they must also contend with increasing regulatory
costs and burdens that threaten their viability and competitiveness with other nations.
Access to fishing grounds is increasingly threatened by competing uses for ocean space,including calls for arbitrary numerical targets for “no fishing” zones. U.S. producers’
access to foreign seafood markets is stifled by foreign quotas and tariffs on U.S. exports
and ever-changing non-tariff trade barriers. Consumers are inundated withmisinformation by special interest campaigns meant to undermine confidence in U.S.
seafood sustainability, safety, and responsible production. Yet, in reality, U.S. seafood is
one of the best protein choices in all regards. NOAA Fisheries should address andcounter these threats in building its Strategy for seafood resilience and competitiveness.
In light of these considerations, PSPA reviewed the very high-level vision, strategy drivers, andchallenges conveyed in the Strategy and supports these statements, but we also find them to beincomplete. First, we suggest adding a bullet to the list of challenges on page 1 of the Strategy
document, recognizing that domestic seafood producers are at a competitive disadvantage inseafood markets compared to producers in other countries that do not operate with the same
regulatory costs and commitments to responsible production upheld by U.S. seafood producers.
Throughout the strategy, NOAA should specifically recognize this and seek to level the playing
field in seafood markets as a key objective in its National Seafood Strategy.
Second, while the Strategy does reference the role of Federal partners on some elements, PSPA
recommends that NOAA Fisheries add additional emphasis and detail in the Strategy
framework section on how interagency work will be pursued. Domestic seafood producers andour supply chain depend on many agencies working on trade and commerce; food chain
support, safety, and security; and workforce and economic development. Effective seafood
support, especially for Goals 3 and 4 (below), cannot be achieved without effective
engagement; therefore, NOAA’s strategy should establish a firm commitment to building
effective and durable interagency functions for collaborating and coordinating on domestic
seafood industry support.
Finally, the Strategy Implementation section on page 4 notes that NOAA Fisheries intends toprepare an Implementation Plan (Plan) with specific actions, timelines, and milestones. PSPA
offers the following recommendations for implementing each section of the Plan.
Wild Capture Fisheries
Goal 1 of the draft Strategy is to sustain or increase sustainable production of U.S. wild-capture
seafood through an evolution in science and management frameworks. PSPA strongly supports
this goal, and we offer additional recommendations for implementation:3

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

•

Fisheries Science. The draft Strategy states NOAA Fisheries will provide the science andeconomic and social analyses necessary for fisheries management, which is already adecades-long core function of NOAA Fisheries. We strongly support NOAA’s formal
recognition of fisheries science as a top priority, given the need to increase and expand
surveys in a changing climate while facing increasing costs to do so. The Plan will
require specific commitments and actions that the agency will undertake to better
deliver this core function, including steps to ensure fisheries management decisions are
based on the best available science and that Federal fisheries surveys are conducted.
We find that fully-funded, reliable, and sustained stock assessments and vessel-based
surveys are the most important form of support NOAA can provide to councils to facilitatesustainable fishing in the face of climate and ecosystem change, especially in areas
undergoing rapid change such as Alaska. We recommend that NOAA explicitly include
in the Plan a commitment to increase (not just adjust) surveys to meet growing needs
for ecosystem and climate resilience in the Alaska region, and NOAA should firmly
commit to delivering the vessel-based surveys necessary for long-term continuity of key
biological datasets including species distribution, condition, diet, age, sex, and genetics.
The Plan should clarify that any NOAA effort to utilize new data collection systems (e.g.,
acoustics, uncrewed systems) to meet more complex scientific needs associated with
understanding climate impacts on marine resources will supplement, not replace,vessel-based surveys. This commitment is especially important in the face of increasing
challenges facing the NOAA vessel fleet, which is at risk of being under continual repair,understaffed, and diverted to uses other than fisheries surveys.

•

Fisheries Management. We support NOAA’s stated objective to maximize fishing
opportunities while ensuring sustainability. This is consistent with the agency’s longstanding mandate under MSA to achieve optimum yields, as defined in MSA to include
the greatest overall benefit to the Nation and maximizing fish production whileaccounting for other factors. Therefore, we again look to the Plan as the vehicle fordelivering meaningful improvements for fisheries management. We urge NOAA
Fisheries to state how it will support efforts to uphold MSA National Standards, defend useof the best available science, assist councils in the development of more flexible
management actions to adapt to changing conditions, and maintain the necessary
regional NMFS and science center staff to support the development of council analyses andrulemaking. NOAA should articulate in the Plan how it will ensure councils will manage
fisheries throughout the EEZ, an MSA requirement, in the face of competing uses orcreation of no-fishing zones outside the MSA process. We urge implementation actions
that seek continual improvement in regulatory streamlining, informed by an audit of thetrue regulatory costs and burdens necessary to comply with complicated legal
requirements and efforts to reduce those costs and burdens. NOAA Fisheries should
include implementation actions aimed at communicating the strong scientific basis forfisheries management actions to improve public awareness of fisheries sustainability
under MSA.

•

Habitat Conservation in Support of Fisheries. This objective states NOAA Fisheries will
“protect and restore” habitat and support resilient coastal communities. First, PSPA
notes that habitat conservation is not simply a matter of protecting and restoring

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Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

habitat; in reality, it also embodies a full range of actions aimed at proactively
conserving resources and reducing impacts. In the Plan, NOAA Fisheries should
explicitly state how it will recognize the full range of all actions undertaken under
myriad authorities in the ocean space to conserve, protect, and restore habitat andbiodiversity contained therein, including the area-based conservation measuresestablished by councils under MSA authority. In the “America the Beautiful” initiative,
NOAA Fisheries should make sure all forms of area-based marine conservation areaccounted for, and it should only pursue additional area-based conservation measuresin coordination with fishery management councils.
To support resilient coastal communities, PSPA urges NOAA to include specific items in
the Plan advancing partnerships with coastal communities to improve resilience andfortification for coasts and coastal infrastructure. In addition, we recommend NOAA
focus on the infrastructure capacity and modernization needs of seafood-dependentcommunities, particularly those in rural locations. We recommend close consultation
with local fishermen, seafood processors, and community leadership to identify priority
community resilience and infrastructure projects, including those authorized by theInfrastructure Investment and Jobs Act (P.L. 117-58).
Aquaculture
Goal 2 of the draft Strategy is focused on increasing domestic aquaculture production. Given
PSPA members’ full dependence on processing fish harvested in wild commercial fisheries, ourcomments here are limited.
•

Marine Aquaculture Management and Regulatory Efficiency. NOAA Fisheries states itwill advance an efficient, predictable, timely, and science-based aquaculture regulatory
framework. Achieving this long-standing agency goal will require additional funding,authority, and – most importantly – transparency for all stakeholders, including thoseconcerned about the environmental, economic, and social impacts of advancing a newoffshore industry and potentially adding more seafood into domestic and global
markets. We recommend that the Plan 1) clarify how the agency will work with otheragencies, the seafood industry, and other stakeholders to identify aquaculture’s impacts
on marine life and habitats and how negative impacts will be avoided, minimized, andpaid for by aquaculture operators; 2) address challenges created by new ocean space
allocation issues and changing environmental conditions; and 3) identify aquaculture’s
impacts on existing seafood markets and measures to proactively address any
conflicting interests of market sectors. The Plan should clearly state that Aquaculture
Opportunity Areas in Alaska would be developed in close consultation with the State of
Alaska and fisheries managers and be limited to mariculture in state waters. On any
Congressional advocacy by NOAA related to aquaculture bills, the Plan should recognize
the importance of overcoming key objections by accommodating state interests,
including language to leave certain Federal waters off-limits to finfish aquaculture.

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•

Aquaculture Science. We appreciate a commitment to science-based aquaculture
production and the need for science-based reduction of environmental impacts. Any
expansion of effort in this area, however, should not come at the expense of science insupport of other long-standing core science functions. We recommend clearly stating in
the Plan that aquaculture-oriented science will not reduce NOAA’s funding, staff, andother resources needed for wild fisheries science and surveys in support of councils’
fisheries management and climate resilience work.

Market Access
The third goal of the draft Strategy is to foster access to domestic and global markets for the
U.S. seafood industry. In pursuing this goal, NOAA Fisheries must recognize that seafood is a
global commodity, and the economic benefits of harvesting this public resource depend on U.S.
seafood producers’ abilities to compete in all markets. In defining this goal, the agency should
also recognize that delivering on this goal will require vigorous new forms of trade policy andinteragency advocacy for terms of trade that do not put U.S. seafood producers at a competitive
disadvantage. PSPA continues to urge priority focus on seafood exports in particular, as threefourths of the volume of Alaska seafood – and tens of thousands of U.S. fishermen and hundredsof thousands of seafood supply chain workers – depend upon competitive access to seafoodexport markets.
•

Communication and Promotion. NOAA is well-positioned as an authoritative source of
science-based outreach on fish and seafood, and PSPA supports the objective of
conveying the availability, sustainability, and nutritional value of U.S. seafood. The Planshould include specific actions for NOAA Fisheries to take, including maximizing its
public outreach to bolster consumer confidence in U.S. seafood and communicating the2020-2025 USDA Dietary Guidelines for Americans that support eating more seafood.
In the Plan, NOAA should advance its current FishWatch program as a primary source
for consumers to understand sustainable seafood choices and increase public andinteragency outreach on seafood’s role in meeting U.S. dietary needs (e.g., through theWhite House’s initiative on hunger, nutrition, and health). The Plan should articulate
how NOAA will improve upon existing government market support programs by 1)
ensuring sufficient and stable funding for Saltonstall-Kennedy grants and effective
operation of the American Fisheries Advisory Committee that guides S-K decisions, 2)partnering with USDA to provide more effective and timely support for its domestic
food marketing and seafood purchase programs, and 3) working to help deliver on thegoals of President Biden’s “Buy American” initiatives. PSPA supports the intent of a
National Seafood Council, but unresolved questions about its relation to existing
programs, operation, funding sources, and long-term viability need clarity before NOAA
establishes it as a priority program.

•

U.S. Market Development. The second objective of the Market Access goal is to identify
and develop U.S. seafood markets and put more U.S. seafood on U.S. plates. PSPA finds
this objective laudable, yet it is largely redundant with the Communication andPromotion objective described above. We find that if NOAA Fisheries works more

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Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

effectively with USDA and seafood stakeholders on communicating the outstanding
merits of seafood to U.S. consumers, domestic markets will further develop and provide
vital outlets for seafood producers. Therefore, PSPA’s recommendations for the Plan on
this objective are the same as above, with the additional recommendation to regularly
consult with domestic seafood producers to better understand their domestic market
access issues, such as ensuring reliable access to shelf space, controlling costs to ensurecompetitive prices, and identifying barriers to and opportunities for productinnovation. NOAA must recognize that costs of seafood production cannot continually
be absorbed or passed along to consumers before they simply buy other proteins;therefore, cost burdens (regulatory, operational, and other) for U.S. seafood processors
must be understood and accounted for in government actions.
•

Fair Trade. NOAA Fisheries’ third objective under Market Access is to promote fairseafood trade by combatting IUU fishing and expanding access to foreign markets. In
the simplest terms, this objective is about leveling the playing field, which PSPAstrongly supports. Like other items in this Strategy, however, the true value of thisintent will only be realized if the Implementation Plan promotes meaningfulinteragency actions. PSPA recommends, therefore, the following for inclusion in the
Plan:o NOAA Fisheries should advance work toward a National Trade Policy for theseafood industry, through which NOAA Fisheries would work with theInternational Trade Administration (ITA) and the Office of the United States
Trade Representative (USTR) in designing and implementing a targeted plan for
pursuing free and fair trade. As you know, on May 7, 2020 the White House
issued Executive Order 13921, Promoting American Seafood Competitivenessand Economic Growth. Section 11 of that EO created an Interagency Seafood
Trade Task Force and charged it with delivering a national Seafood Trade
Strategy. PSPA provided comments on that strategy (letter dated July 22, 2020,
attached). Our key recommendations remain applicable to this new Strategy
and its Implementation Plan. Specifically, we continue to recommend that
seafood trade receive priority consideration in NOAA, ITA, and USTR and thatthese agencies work collaboratively to prioritize seafood exports in both limited“phase” and full international trade agreements. Agencies should pursue thiswork through outcome-oriented action plans specific to key seafood export
markets, including China, Japan, Russia, the EU, and UK, with a goal of removing
tariff and non-tariff trade barriers to foreign market access. These agencies
should create a standing interagency committee on seafood trade andcompetitiveness to coordinate and be accountable for effective seafood tradeactions and oversee frequent and effective communications between the
Administration and U.S. seafood exporters.
o In addition to developing plans to advance free and fair seafood trade, PSPA
recommends that the Plan include collaboration between the USDA’s Foreign
Agricultural Service and the other trade-related agencies to help ensure that U.S.

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Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

overseas seafood marketing programs and U.S. seafood export action plans areworking collaboratively toward common goals.
o We further recommend that NOAA Fisheries’ Office of Seafood Inspection is
integrated in this part of the Plan to maintain robust support for seafood healthcertification and other U.S. seafood export requirements, including strategies for
rapid resolution of unforeseen certification problems and strategies to facilitatesustained government support and engagement with U.S. seafood exporters. We
further request that NOAA develop and seek public input on a plan forstabilizing the Seafood Inspection Program as needed to avoid the substantial
and rapid price increases over the last two years, and to ensure consistency andefficiency in service levels and audit functions across regions.
o PSPA supports the objective to combat Illegal, Unreported and Unregulated(IUU) fishing. The Plan should include items that make full use of current
authorities and programs to fight IUU fishing and exploitative labor practices
worldwide, and in particular to leverage the cross-sector collaboration andgovernmental coordination functions called for in the Maritime SAFE Act.
Current authorities also allow agencies to address cases of domestic seafood
fraud, and the Plan should ensure these foreign IUU fishing and fraud
enforcement programs are fully resourced.
o PSPA recognizes that NOAA Fisheries faces pressure to do more domestically tocombat foreign IUU fishing, such as expanding the Seafood Import Monitoring
Program (SIMP). If the Plan addresses SIMP, PSPA strongly recommends that itremain focused on only a few of the highest-risk categories. Given its
administrative complexity, high costs, risks to lawful seafood trade, and lack ofeffectiveness in identifying IUU fish, we strongly oppose expanding SIMP.
o PSPA also finds that any WTO agreement to ban subsidies linked to IUU or
unsustainable fishing should not inadvertently affect beneficial government
support programs for sustainable fisheries in the U.S., including a range ofwidely used domestic fisheries and seafood programs (e.g., disaster relief,marketing support, government seafood purchases addressing food security,etc.). The Plan should explicitly reinforce that Federal funding for programs
supporting sustainable fisheries will not be affected by the WTO agreement.
Seafood Sector Support
The fourth goal of the Strategy is to strengthen the entire seafood sector value chain throughactions that support industry resilience and flexibility, infrastructure modernization, andworkforce development, all of which are vital in helping the industry evolve and respond tochronic and acute challenges. PSPA supports this goal and suggests additional focus on theroles of NOAA’s technical infrastructure (e.g., seafood inspection services and quality
assessments), interagency coordination on immigration policy to facilitate domestic seafood

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Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

production, and the need to integrate this US seafood strategy with the Federal government
strategy for food security and resilient food supply chains.
•

Seafood as a Vital Part of the Blue Economy. This objective establishes that NOAA
Fisheries will support seafood producing communities and help them adapt and thrive
in a changing ocean economy with new competing uses. The Plan must explain, in
detail, how NOAA will invest in and help fishing and seafood-dependent communities“thrive” as competing uses for ocean space increase and erode access to fish stocks.
Specifically, it must explain how NOAA will bolster fishing community support andpromote access to sustainable fishing, based on fully articulated values of seafood-based
economies, while other parts of NOAA (and other agencies in the Administration) seek todevelop offshore industries and/or block commercial fishing access from other parts of theocean to protect non-fishery resources. The Plan should state that before actions aretaken to remove commercial fishing from ocean space, NOAA must proactively identify
the full range of economic impacts (e.g., losses to jobs, income, reinvestment, tax
revenue, etc.) throughout the seafood value chain and commit to avoid and mitigate
those impacts. At the same time, the Plan should state how NOAA can help drive
government investment to Blue Economy communities in the form of technologies,
infrastructure, and market access, thereby increasing their long-term ability to compete
in seafood markets.
Additional Objective: Following the point on seafood in the Blue Economy, NOAA
should add a section to the Implementation Plan recognizing and upholding seafood’srole in domestic food security. Domestic wild seafood is a sustainable, reliable, andabundant source of protein, essential fatty acids, and nutrients, and the United States
produces up to 10 billion pounds annually. Fishing and seafood processing employers
are part of the United States’ essential and critical infrastructure, as recognized by the
Department of Homeland Security’s (DHS) Cybersecurity and Infrastructure Security
Agency.1 Threats against domestic food supplies, including fish and seafood, areaddressed in a 2021 public-private analysis with participants from DHS and the Officeof the Director of National Intelligence.2 This analysis highlights many foreign anddomestic threats to our seafood supply chain, including many issues (e.g., seafoodsustainability and inspection, regulatory and cost burdens on domestic producers,
dependence on foreign seafood produced at lower cost, the need for climate resilience)in which NOAA Fisheries is active. Specifically, the Plan should articulate how NOAA
Fisheries will work with DHS, USDA, and other agencies on domestic food security, toensure agencies are sharing information about – and taking action to address – threats(domestic and foreign) that could destabilize domestic seafood production and delivery
to American consumers, including through USDA public nutrition programs thatprovide food for millions of underserved and food insecure Americans.

1 U.S. Department of Homeland Security, Cybersecurity and Infrastructure Security Agency, Office of the

Director. Advisory Memorandum on Identification of Essential Critical Infrastructure Workers During COVID19 Response. March 28, 2020 (and subsequent guidance on August 10, 2021).
2 Public Private Analytic Exchange Program. Threats to Food and Agriculture Resources. 2021.

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•

Seafood Infrastructure. PSPA supports the objective of modernizing U.S. seafood
infrastructure and supply chain components to advance the resilience of fishing andseafood communities and regional food economies. In the Plan, we recommend thatNOAA look for every opportunity to better understand the U.S. seafood supply chain –from harvest to consumer – and work with industry to identify infrastructure needs at
the local level. NOAA can then best understand how to use its authorities and/or workwith states and partner agencies to increase technical assistance and direct grant
programs for vessel modernization and recapitalization, port facilities, processing andstorage facilities, and programs for modernizing seafood storage and shipment.

•

Workforce Development. In the third objective of this goal, NOAA plans to foster a
growing and diverse seafood workforce and attract new industry entrants. PSPA
supports this goal, and we find that the best way to attract commercial fishermen andseafood producers is to clearly facilitate economic success and further signal to the entire
economy that domestic seafood is a national priority. The Plan should state how NOAA
Fisheries will help minimize industry cost, burden, risk, and uncertainty – and how itwill help ensure that seafood jobs are in demand, pay well, and attract investments. It
should explain how NOAA will work collaboratively with other agencies, educators, andseafood employers to expand workforce development, training, and extension
programs, which are needed to instill valuable and unique fishing and seafood
processing skillsets.
Additional Objective: PSPA recommends that NOAA Fisheries add a new objective on
workforce issues, specifically supporting the role of non-immigrant, seasonal visa guest
workers in U.S. seafood processing. H-2B visas are a critical link in Alaska’s seafood
supply chain, and NOAA should work with the Department of Labor (DOL) and the DHS
to prioritize access to the limited number of H-2B visas for Alaska’s seafood processors.
While we understand that NOAA does not have a role in administering the H-2B visa
program, we urge NOAA to use its discretion to make sure DOL and DHS understand theirroles in facilitating the Administration’s purpose of achieving optimum yields, delivering
the greatest overall benefit to the Nation, and maximizing domestic fisheries production
while accounting for other needs. Shortfalls in the processing workforce have cascading
impacts: fishermen may have to halt fishing and product volumes decrease due tolimited processor capacity, processors produce lower value seafood products
domestically (higher value products require more labor), choices for seafood markets
and consumers are constrained, jobs and income in support sectors and distribution
systems are impacted, and states and local communities receive fewer fish tax revenues
from processors. The Plan should state how NOAA will engage with DOL and DHS tocommunicate urgency for using any discretion to ensure timely and effective delivery ofthese visas for Alaska’s seafood employers.

NOAA Fisheries’ leadership on the National Seafood Strategy and subsequent Implementation
Plan are essential to our industry, as no other Federal agency’s primary responsibility is toreturn the greatest overall benefit of fishery resources to the Nation, as directed by MSA.

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Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Delivering this National benefit requires holistic, comprehensive support for domestic seafood
producers. Therefore, it remains incumbent on NOAA Fisheries to lead and effectively partnerwith many other agencies to implement this Strategy through an all-of-government approach,with NOAA Fisheries at the helm. The need to establish formal interagency coordination bodies
is particularly clear for goals 3 and 4, and PSPA encourages NOAA Fisheries to address thisneed more directly in both its Strategy and Implementation Plan.
PSPA offers this input with a sincere desire to facilitate the success of this Strategy, and toembed the Strategy’s objectives in NOAA Fisheries’ core mission. Thank you for carefully
considering our input.
Sincerely,

Mark JoHahnson
Chairman11

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Pacific Fishery Management Council
7700 NE Ambassador Place, Suite 101 Portland, OR 97220‐1384
Phone 503‐820‐2280 | Toll free 866‐806‐7204 | Fax 503‐820‐2299 | www.pcouncil.org
Marc Gorelnik, Chair | Merrick J. Burden, Executive Director

March 16, 2023
Re: National Oceanic and Atmospheric Administration Draft Seafood Strategy
To Whom It May Concern:
The Pacific Fishery Management Council (Pacific Council) appreciates the opportunity to provide
comments on the Draft National Seafood Strategy (Draft Strategy). Sustainable seafood production
for both commercial and recreational fisheries is the fundamental mission of the Pacific Council.
We support the vision of the Draft Strategy, which prioritizes sustainable seafood production,
climate-ready fisheries and communities, economic competitiveness, and opportunities for a
growing and diverse workforce. We also have some suggested changes. Successful
implementation of the Draft Strategy will be dependent on National Oceanic and Atmospheric
Administration Fisheries’ commitment to fund and execute regional implementation plans. We
offer the following comments on the Draft Strategy.
The Pacific Council is well positioned to contribute to the Draft Strategy goals of increasingsustainable wild capture production, fostering access to domestic and global markets, andstrengthening the seafood sector. Pacific Coast fisheries have experienced enormous challenges inrecent decades, such as overfished stocks, habitat degradation, climate change, market disruptions,and infrastructure declines. Although nearly all Federally managed stocks have been rebuilt, ourWest Coast fleets are in some cases prevented from achieving full utilization of several species,
due to catch constraints or other factors. Achieving Optimum Yield and increasing opportunities
for greater attainment of underutilized species represents excellent opportunities to address Goal
1 of the Draft Strategy, while also supporting Goals 3 and 4.
Increasing seafood production capacity would also increase the resilience of fishing-dependentcommunities. Revitalizing the seafood capacity and supply chain would support Goals 1, 3, and 4of the Draft Strategy.
We believe that the Draft Strategy could be more inclusive by not excluding the recreational sector.
We suggest the following changes:
 in the “Fisheries Management” bullet within Goal 1: “Support the recreational andcommercial fishing industries and fishing communities in their efforts to adapt to climatechange and thrive in a changing ocean economy.” In the “Blue Economy” bullet in Goal 4: “Support the U.S. recreational fishing,commercial fishing, marine aquaculture, and seafood communities to adapt and thrive ina changing ocean economy and given new competing uses.”Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Page 2

Under the “Strategy Drivers” heading, we recommend that the “Seafood is Good forPeople” bullet articulate recreational benefits and the “Seafood is Good for the Economy”
bullet incorporate the recreational fishing economics.

The Draft Strategy highlights the importance of protecting and restoring habitats important to ournation’s fisheries, which in turn supports resilient coastal communities. The Pacific Council isproud of our actions to protect and conserve habitats vital to healthy and sustainable fisheries. We
note that a vast majority of the benthic habitat within the Pacific Coast Exclusive Economic Zone
is protected, and that nearly all the historic range (both ocean and freshwater) of Pacific salmon isdesignated essential fish habitat (EFH). However, more actions to protect fisheries habitat,
especially in freshwater systems, should be a priority. These actions should include designating
EFH in watersheds that are likely to become accessible to Pacific salmon via fish passage
improvements, as well as ensuring more robust water quality standards in vital river systems suchas the California Central Valley and Klamath systems. The final Strategy should include
opportunities for NMFS to use its authorities to address these important habitat concerns. We notethat improving habitats and water quality standards also benefits food security, food sovereignty,
subsistence fishing, and traditional Tribal fishing rights, and supports resilient communities.
We would also like to emphasize the crucial role of scientific surveys and reliable stock
assessments in fisheries management and seafood production. Best available scientific informationis the foundation of sustainable fisheries management, and adequate funding is critical to support
the surveys and the science that goes into sustainable fisheries management.
The Draft Strategy highlights many benefits of sustainable seafood production, which is good forfood security and nutrition, for fishing-dependent communities, and for the U.S. economy. Goal 2of the Draft Strategy addresses sustainable aquaculture production, which could play a role inseafood production. However, we strongly suggest that the most efficient and effective path toincreasing seafood production is to capitalize on existing wild capture opportunities and utilize
existing infrastructure.
Thank you for considering these comments, and please contact me with any questions or further
discussion.
Sincerely,

Marc Gorelnik
Chairman
KFG:rdd
Cc:

Pacific Council Members
Sarah Shoffler
Michael Rubino

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

LOUISIANA SHRIMP ASSOCIATION
109 17th Place, Larose, La. 70373
504-382-9341

March 29, 2023
Michael Rubino, Ph.D.,
Senior Advisor for Seafood Strategy
NOAA Fisheries Office,
NOAA Fisheries Directorate“National Seafood Strategy”
WRITTEN COMMENTNOAA Fisheries Draft National Seafood Strategy
The Louisiana Shrimp Association (LSA) is a nonprofit organization formed by commercial shrimpers
throughout the State of Louisiana. Membership consists of commercial shrimp fisherman, wholesale andretail seafood dealers, statewide merchants, and individuals concerned about issues related to domestic
seafood and shrimp production as well as the preservation of the culture and heritage of the traditional
Louisiana shrimper.

Dr. Rubino,
We thank you for taking the time to read our comments and consider them for NOAA’s
National Seafood Strategy.
Louisiana Shrimp Association (LSA) was formed in 2002 when the European Union started
banning contaminated shrimp from global aquaculture farms. These shiploads of imported
shrimp, unfit for human consumption in Europe, were then shipped to the United States andsold at undervalued prices and ruined our domestic market.
Now, (21 years later), these contaminated shrimp, (antibiotics, pesticides, salmonella, MRSA,etc.) are being allowed into our country. We now (21 years later) have a worldwide antibiotic
resistance problem. According to CDC reports, 35/50 thousand deaths in the United Statesalone, 1.27 million deaths worldwide and is associated with 5 million deaths worldwide.
* see footnote links to articles connecting this to shrimp aquaculture.
As we see, you are one of the people at the top to improve domestic aquaculture. If we cannot
compete against the influx of contaminated, undervalued seafood coming into our country,
there is no way for a domestic aquaculture industry to survive.
*footnote links:
https://sentientmedia.org/farmed-shrimp-india/
https://www.google.com/search?q=farm+raised+shrimp+antibiotic+resistance&ie=UTF-8&oe=UTF8&hl=en-us&client=safari#fpstate=ive&vld=cid:56565cae,vid:OJVrCnjL4a8

1

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Recommendations to the National Seafood Strategy:
1. Increase testing and destroying all contaminated products being imported and stored incold storage facilities in our country. Yes, this includes the ones already in our storesalso through board of health testing or whatever means necessary.
2. The American domestic seafood Industry paid for, fought for, and did the work for thetariffs on these dumped shrimp. Please ask our government to return it to the industry
by way of fuel subsidies, grants for improvements etc. but mainly to the harvesters
because they are the ones that took the brunt of the price drop. We feel that it belongs
to the industry and not our government.
3. We would like our Federal Government to hold foreign imports to the same standards
as American Aquaculture (American aquaculture will never be able to compete against
forced labor, cheap labor and the use of antibiotics to increase production of shrimp).
We believe this to be important for food independence and public health during war
time.
Thank you for your time and remember we are supposed to have standards above any country
in the world but yet (21 years later) the European Union standards of imported seafood are
better than ours in the United States. Raising our standards would be a more level playing field
for both industries (wild caught and aquaculture) to stand a chance to thrive while saving lives.
Fair trade is not fair unless other countries are held to the same standards.
Thank you for your time. We forward to working with your agency on future industry issues.
Sincerely,

Acy J. Cooper
Acy J. Cooper
President LSA

2

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

March 31, 2023

To:

Michael Rubino, Ph.D., Senior Advisor for Seafood Strategy
NOAA Fisheries Oﬃce, NOAA Fisheries Directorate

From:

The domes�c shrimp industry of the Gulf of Mexico and South Atlan�c United States

Re:

Comments on the Dra� Na�onal Seafood Strategy

Dr. Rubino,
Thank you for the opportunity to comment on the NOAA Dra� Na�onal Seafood Strategy. We
commend NOAA Fisheries for recognizing the value of stakeholder input in addressing the many
opportuni�es and challenges facing our domes�c seafood sectors.
We are a group of 20 allied organiza�ons and companies represen�ng more than 4,000 seafoodbusinesses of the U.S. Gulf of Mexico and South Atlan�c region involved in the harves�ng,
processing, and distribu�on of wild shrimp. Through this leter, we hope to brieﬂy highlight our
background and status and to emphasize three prac�cal recommenda�ons for addressing the
economic vulnerability of our industry.
BackgroundThe commercial harves�ng of shrimp dates to the mid-1700s and is one of America’s oldest
seafood sectors. The U.S. domes�c shrimp industry experienced rapid growth throughout most of
the 20th Century, rising in prominence to become one of the na�on’s largest marine commodi�es byvolume and value. In the past 40 years, dockside revenues for U.S. landed shrimp have exceeded$500 million annually, with more than a billion in value-added sales suppor�ng many thousandsof sector-dependent business and jobs. Nearly all of this ac�vity derives from commercial
opera�ons in the U.S Gulf of Mexico and South Atlan�c region. These shrimping families represent
the founda�on of the local cultural fabric and basis of localized economies.
During this same period, shrimp have emerged as the na�on’s most popular seafood, accoun�ng forthe largest percentage of seafood market share and per capita consump�on. Most of this recent
growth, however, has been driven by imported shrimp.
From ini�al produc�on trials in the 1960s, the global shrimp aquaculture industry has grown to an
economic juggernaut, with an annual volume approaching 5 million tons. This produc�on derives
primarily from countries of the Asian-Paciﬁc Rim, and for decades the primary importer has been
the Unites States. The amount of shrimp imported to the U.S. rose from 225 million pounds in1980 to more than 2 billion pounds in 2021. The value of these imports exceeded $7.8 billion
dollars in 2022.
Status
The inﬂux of imported shrimp and the resul�ng commodi�za�on of the global shrimp market has
proven especially problema�c for domes�c harvesters. Despite rising costs for fuel and labor, theprice of Gulf shrimp, for example, has not increased since 1980. For the past 40 years, the average
dockside price of Gulf shrimp (all species and grades combined) has ranged from $1.50-$2.00 per

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

pound. Adjusted for inﬂa�on, this stagna�on equates to a 70% reduc�on in the real price ofshrimp paid to domes�c harvesters since 1980. As the proﬁtability of domes�c shrimp harves�ng
has decreased, increases in shrimp demand have been serviced by imports - and the share ofdomes�c landings in the U.S. shrimp market has dwindled from 90% to less than 10%. As a result of
these forces, the U.S. now has less than 40% of the shrimp harves�ng vessels it had just 20 years
ago. The remnant ﬂeet, which for years has operated on increasingly thin margins, is now at athreshold that will prove devasta�ng in the absence of interven�on. Last year, and this year, manyof our vessels could no longer aﬀord to operate, and will remain in port during much of the season.
Recent ar�cles from seafood news media have conveyed the crisis with headlines like Brink ofCollapse and Verge of Extinction. The value of the shrimp ﬁshery is not purely economic but
cultural and personal as well. Genera�ons of people have carried forth this industry and its richhistory. The connec�on of this industry to food on the table is not readily understood by the
consumers who should be made aware of its importance. We feel that the American market
demand for good quality shrimp is suﬃcient to support our wild caught shrimping industry ifmechanisms are in place to give domes�cally harvested product priority access to the American
consumers.
Recommendations
At the height of our crisis, we are heartened to see that the Dra� Na�onal Seafood Strategy alreadyhighlights several issues of tremendous importance to our industry. We are par�cularly encouraged
to see an emphasis on fair trade and domes�c markets under Goal 3, and the focus on seafood
security under Goal 4.
We agree that a viable Na�onal Seafood Strategy (to quote the Dra� Plan) should address
important issues such as:“…the resilience of coastal ﬁshing communities; the ﬁnancial viability of the seafoodindustry; the eﬀects and opportunities of international trade; and the importance of
seafood (to) food security…”
To this extent we strongly encourage that three cri�cal issues be fully addressed in the ﬁnal
revisions to the Na�onal Seafood Strategy.
1.

Expand the capacity for seafood import inspec�on and enforcement

The Dra� Plan recognizes the need to “…decrease our reliance on foreign ﬁsheries that are at
greater risk of overﬁshing, Illegal, Unreported, and Ungulated (IUU) ﬁshing, and forced labor”.
We contend that the ﬁnal document should also include foreign aquaculture as an addi�onal
source of these concerns. There are many well-documented cases of IUU and labor issues inforeign aquaculture. Foreign shrimp farming con�nues to be challenged by environmental
degrada�on and the use of harmful substances. In comparison, domes�c shrimp are highlyregulated and free from banned chemicals and an�bio�cs.
We encourage NOAA to speciﬁcally acknowledge and endorse the more than 20 goals andobjec�ves called for by the Food and Drug Administra�on (FDA) in their February 2023 report:“Activities for the Safety of Imported Seafood”. We request that NOAA Fisheries acknowledge
this report in the revised plan and reiterate the call for increased capacity and training for
seafood import inspec�on agents, increased border surveillance, public awareness of
consump�on risk, and more rapid and eﬀec�ve response to seafood import viola�ons.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

2.

Develop new programs to improve domes�c seafood security

It is commendable that the issue of food security has been included in the Dra� Plan. Indeed,
an increasing na�onal focus on food security has grown from supply chain vulnerabili�es
exposed by the Covid-19 pandemic. American consumers are coming to grips with howdependent they have been on foreign sources especially in �mes of interna�onal stress. Goingforward, seafood must be included in this emerging na�onal focus of food security. We
encourage NOAA Fisheries to acknowledge in the Na�onal Seafood Strategy the need forprograms and policies for seafood that are similar to those implemented for agricultural
security under the U.S. Farm Bill. There are many poten�al approaches, including domes�cprice supports, tax incen�ves, increased fuel credits and ins�tu�onal purchases of domes�cseafood commodi�es that should be implemented on a con�nuing basis to ensure ongoingna�onal food security.
Beginning in 2020, the Agricultural Marke�ng Service (AMS) branch of the United States
Department of Agriculture (USDA) increased its purchase and distribu�on of food products by$159.4 million. This expansion included the largest ins�tu�onal purchase of American
seafood in our na�on’s history. Embedded in the seafood purchase was the ﬁrst-ever inclusionof wild-caught American shrimp, never before considered eligible for the USDA/AMS program.
From 2021 to 2022, a total of $50 million in cash from USDA was infused into the shrimping
industry, and 7.6 million pounds of domes�c shrimp taken out of inventory and distributedna�onwide. We request that NOAA Fisheries speciﬁcally acknowledge this ini�a�ve in therevised plan. Expanded ins�tu�onal purchases are vital to securing domes�c seafood security
and sustaining our domes�c shrimp sector.

3.

Reevaluate the distribu�on seafood import du�esSec�on 32 of the Agricultural Adjustment Act of 1935 authorizes the federal government toredistribute public funds in support of agricultural prices and markets. In the context ofseafood imports, the law allows for the collec�on of trade du�es to provide ﬁnancial
assistance to domes�c shrimp producers that may be nega�vely aﬀected by imports ofseafood products.
The two billion pounds of foreign shrimp imported annually account for the largest volume of
any U.S. imported seafood commodity. The U.S. Department of Commerce has worked throughthe Interna�onal Trade Commission (ITC) to impose an�-dumping du�es on shrimp imports
from six countries (Brazil, Ecuador, China, India, Thailand, and Vietnam). These import du�eshave resulted in almost a half billion dollars in government collec�ons from 2010-2020. Yet
the businesses for which these du�es are collected to protect rarely see direct support fromthis program.
Although seafood import du�es do support the domes�c industry indirectly by funding
government opera�ons (NOAA Fisheries) and targeted research (Saltonstall-Kennedy), we callon your oﬃce to revisit the original intent of Sec�on 32 and to iden�fy more direct andequitable ways to allocate these funds across the industry, including harvesters. Withoutsome realignment and interven�on, there will be no domes�c shrimp sector to protect.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

We understand these recommenda�ons come with a substan�al commitment of �me and eﬀort by
NOAA Fisheries and other federal agencies. Our organiza�ons have spent decades on the front lineof these issues, and we are prepared to con�nue working with federal agencies and ourcongressional delega�ons to achieve much needed progress.
Our overriding request is that the 3 issues outlined above be fully addressed in the ﬁnal versionof the Na�onal Seafood Strategy. Please let us know when and where we can expect to receive
feedback from your oﬃce. Responses can be sent to the email addresses below.
NOAA Fisheries has an opportunity to signal its commitment and support to one of the na�on’s
oldest seafood sectors. In doing so, your oﬃce will provide hope to the many coastal communi�es,
business, families, and individuals who depend on domes�c seafood for their heritage andlivelihood.
We thank you again Dr. Rubino for the opportunity to provide our collec�ve input to this important
document and we look forward with great an�cipa�on to working with you and your oﬃce.
With apprecia�on,
Organization Signees
Capt. George P McShea, Jr. - aosusa@sbcglobal.net
Apostleship of the Sea of the United States
Crystal Truong - crystaltruong4@yahoo.com
Galveston Area Vietnamese Shrimp Fleet
Nuoi Bui - nuoivanbui@gmail.com
Gulf Vietnamese Commercial Fishermen Associa�on
Lieutenant Governor William “Billy” Nungesser - ltgov@crt.la.gov
Louisiana Department of Culture, Recrea�on, and Tourism
Samantha Carrol - scarroll@crt.la.gov
Louisiana Seafood Promo�on and Marke�ng Board
Acy J Cooper - acycooper@louisianashrimp.org
Louisiana Shrimp Associa�on
Acy J Cooper - acycooper@louisianashrimp.org
Louisiana Shrimp Task Force
Thuy Vu - tweecte@yahoo.com
Palacios Area Vietnamese Shrimp Fleet
Capt. Kyle Kimball - pashrimpersassocia�on@gmail.com
Port Arthur Area Shrimpers Associa�onCapt. James B Robertson- jim@strategictowingservices.com
Port Arthur Interna�onal Seafarers’ CenterPublic comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Huger McClellan - Huger2ndSC@gmail.com
McClellanville Watermen’s Associa�onJohn Williams - john@shrimpalliance.com
Southern Shrimp Alliance
Very Reverend Sinclair Oubre, JCL, AFNI - sinclair.oubre@stellamarismail.org
Stella Maris Diocese of BeaumontAndrea Hance - andreahance@texasshrimpassocia�on.com
Texas Shrimp Associa�on

Other Signees
Earnest “Earnie” Aparicio - ernieaparicio@hotmail.com
Anchor Seafood
Chris Londrie - chris.londrie@texasgoldshrimp.com
Co-PakDung Bui - dungthibui@gmail.com
Intracoastal Seafood
Devan Phan - annahphan@gmail.com
Palmer Foods
Ken Garcia - kengarcia09@yahoo.com
Quality Seafood
Gary Graham - glgshrimp@embarqmail.com
Teal Trawlers LLC

CC: Congressional delega�ons of Texas, Louisiana, Mississippi, Alabama, Florida, Georgia, South
Carolina, and North Carolina.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

March 31, 2023

To:

Michael Rubino, Ph.D., Senior Advisor for Seafood Strategy
NOAA Fisheries Oﬃce, NOAA Fisheries Directorate

From:

The domes�c shrimp industry of the Gulf of Mexico and South Atlan�c United States

Re:

Comments on the Dra� Na�onal Seafood Strategy

Dr. Rubino,
Thank you for the opportunity to comment on the NOAA Dra� Na�onal Seafood Strategy. We
commend NOAA Fisheries for recognizing the value of stakeholder input in addressing the many
opportuni�es and challenges facing our domes�c seafood sectors.
We are a group of 20 allied organiza�ons and companies represen�ng more than 4,000 seafoodbusinesses of the U.S. Gulf of Mexico and South Atlan�c region involved in the harves�ng,
processing, and distribu�on of wild shrimp. Through this leter, we hope to brieﬂy highlight our
background and status and to emphasize three prac�cal recommenda�ons for addressing the
economic vulnerability of our industry.
BackgroundThe commercial harves�ng of shrimp dates to the mid-1700s and is one of America’s oldest
seafood sectors. The U.S. domes�c shrimp industry experienced rapid growth throughout most of
the 20th Century, rising in prominence to become one of the na�on’s largest marine commodi�es byvolume and value. In the past 40 years, dockside revenues for U.S. landed shrimp have exceeded$500 million annually, with more than a billion in value-added sales suppor�ng many thousandsof sector-dependent business and jobs. Nearly all of this ac�vity derives from commercial
opera�ons in the U.S Gulf of Mexico and South Atlan�c region. These shrimping families represent
the founda�on of the local cultural fabric and basis of localized economies.
During this same period, shrimp have emerged as the na�on’s most popular seafood, accoun�ng forthe largest percentage of seafood market share and per capita consump�on. Most of this recent
growth, however, has been driven by imported shrimp.
From ini�al produc�on trials in the 1960s, the global shrimp aquaculture industry has grown to an
economic juggernaut, with an annual volume approaching 5 million tons. This produc�on derives
primarily from countries of the Asian-Paciﬁc Rim, and for decades the primary importer has been
the Unites States. The amount of shrimp imported to the U.S. rose from 225 million pounds in1980 to more than 2 billion pounds in 2021. The value of these imports exceeded $7.8 billion
dollars in 2022.
Status
The inﬂux of imported shrimp and the resul�ng commodi�za�on of the global shrimp market has
proven especially problema�c for domes�c harvesters. Despite rising costs for fuel and labor, theprice of Gulf shrimp, for example, has not increased since 1980. For the past 40 years, the average
dockside price of Gulf shrimp (all species and grades combined) has ranged from $1.50-$2.00 per

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

pound. Adjusted for inﬂa�on, this stagna�on equates to a 70% reduc�on in the real price ofshrimp paid to domes�c harvesters since 1980. As the proﬁtability of domes�c shrimp harves�ng
has decreased, increases in shrimp demand have been serviced by imports - and the share ofdomes�c landings in the U.S. shrimp market has dwindled from 90% to less than 10%. As a result of
these forces, the U.S. now has less than 40% of the shrimp harves�ng vessels it had just 20 years
ago. The remnant ﬂeet, which for years has operated on increasingly thin margins, is now at athreshold that will prove devasta�ng in the absence of interven�on. Last year, and this year, manyof our vessels could no longer aﬀord to operate, and will remain in port during much of the season.
Recent ar�cles from seafood news media have conveyed the crisis with headlines like Brink ofCollapse and Verge of Extinction. The value of the shrimp ﬁshery is not purely economic but
cultural and personal as well. Genera�ons of people have carried forth this industry and its richhistory. The connec�on of this industry to food on the table is not readily understood by the
consumers who should be made aware of its importance. We feel that the American market
demand for good quality shrimp is suﬃcient to support our wild caught shrimping industry ifmechanisms are in place to give domes�cally harvested product priority access to the American
consumers.
Recommendations
At the height of our crisis, we are heartened to see that the Dra� Na�onal Seafood Strategy alreadyhighlights several issues of tremendous importance to our industry. We are par�cularly encouraged
to see an emphasis on fair trade and domes�c markets under Goal 3, and the focus on seafood
security under Goal 4.
We agree that a viable Na�onal Seafood Strategy (to quote the Dra� Plan) should address
important issues such as:“…the resilience of coastal ﬁshing communities; the ﬁnancial viability of the seafoodindustry; the eﬀects and opportunities of international trade; and the importance of
seafood (to) food security…”
To this extent we strongly encourage that three cri�cal issues be fully addressed in the ﬁnal
revisions to the Na�onal Seafood Strategy.
1.

Expand the capacity for seafood import inspec�on and enforcement

The Dra� Plan recognizes the need to “…decrease our reliance on foreign ﬁsheries that are at
greater risk of overﬁshing, Illegal, Unreported, and Ungulated (IUU) ﬁshing, and forced labor”.
We contend that the ﬁnal document should also include foreign aquaculture as an addi�onal
source of these concerns. There are many well-documented cases of IUU and labor issues inforeign aquaculture. Foreign shrimp farming con�nues to be challenged by environmental
degrada�on and the use of harmful substances. In comparison, domes�c shrimp are highlyregulated and free from banned chemicals and an�bio�cs.
We encourage NOAA to speciﬁcally acknowledge and endorse the more than 20 goals andobjec�ves called for by the Food and Drug Administra�on (FDA) in their February 2023 report:“Activities for the Safety of Imported Seafood”. We request that NOAA Fisheries acknowledge
this report in the revised plan and reiterate the call for increased capacity and training for
seafood import inspec�on agents, increased border surveillance, public awareness of
consump�on risk, and more rapid and eﬀec�ve response to seafood import viola�ons.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

2.

Develop new programs to improve domes�c seafood security

It is commendable that the issue of food security has been included in the Dra� Plan. Indeed,
an increasing na�onal focus on food security has grown from supply chain vulnerabili�es
exposed by the Covid-19 pandemic. American consumers are coming to grips with howdependent they have been on foreign sources especially in �mes of interna�onal stress. Goingforward, seafood must be included in this emerging na�onal focus of food security. We
encourage NOAA Fisheries to acknowledge in the Na�onal Seafood Strategy the need forprograms and policies for seafood that are similar to those implemented for agricultural
security under the U.S. Farm Bill. There are many poten�al approaches, including domes�cprice supports, tax incen�ves, increased fuel credits and ins�tu�onal purchases of domes�cseafood commodi�es that should be implemented on a con�nuing basis to ensure ongoingna�onal food security.
Beginning in 2020, the Agricultural Marke�ng Service (AMS) branch of the United States
Department of Agriculture (USDA) increased its purchase and distribu�on of food products by$159.4 million. This expansion included the largest ins�tu�onal purchase of American
seafood in our na�on’s history. Embedded in the seafood purchase was the ﬁrst-ever inclusionof wild-caught American shrimp, never before considered eligible for the USDA/AMS program.
From 2021 to 2022, a total of $50 million in cash from USDA was infused into the shrimping
industry, and 7.6 million pounds of domes�c shrimp taken out of inventory and distributedna�onwide. We request that NOAA Fisheries speciﬁcally acknowledge this ini�a�ve in therevised plan. Expanded ins�tu�onal purchases are vital to securing domes�c seafood security
and sustaining our domes�c shrimp sector.

3.

Reevaluate the distribu�on seafood import du�esSec�on 32 of the Agricultural Adjustment Act of 1935 authorizes the federal government toredistribute public funds in support of agricultural prices and markets. In the context ofseafood imports, the law allows for the collec�on of trade du�es to provide ﬁnancial
assistance to domes�c shrimp producers that may be nega�vely aﬀected by imports ofseafood products.
The two billion pounds of foreign shrimp imported annually account for the largest volume of
any U.S. imported seafood commodity. The U.S. Department of Commerce has worked throughthe Interna�onal Trade Commission (ITC) to impose an�-dumping du�es on shrimp imports
from six countries (Brazil, Ecuador, China, India, Thailand, and Vietnam). These import du�eshave resulted in almost a half billion dollars in government collec�ons from 2010-2020. Yet
the businesses for which these du�es are collected to protect rarely see direct support fromthis program.
Although seafood import du�es do support the domes�c industry indirectly by funding
government opera�ons (NOAA Fisheries) and targeted research (Saltonstall-Kennedy), we callon your oﬃce to revisit the original intent of Sec�on 32 and to iden�fy more direct andequitable ways to allocate these funds across the industry, including harvesters. Withoutsome realignment and interven�on, there will be no domes�c shrimp sector to protect.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

We understand these recommenda�ons come with a substan�al commitment of �me and eﬀort by
NOAA Fisheries and other federal agencies. Our organiza�ons have spent decades on the front lineof these issues, and we are prepared to con�nue working with federal agencies and ourcongressional delega�ons to achieve much needed progress.
Our overriding request is that the 3 issues outlined above be fully addressed in the ﬁnal versionof the Na�onal Seafood Strategy. Please let us know when and where we can expect to receive
feedback from your oﬃce. Responses can be sent to the email addresses below.
NOAA Fisheries has an opportunity to signal its commitment and support to one of the na�on’s
oldest seafood sectors. In doing so, your oﬃce will provide hope to the many coastal communi�es,
business, families, and individuals who depend on domes�c seafood for their heritage andlivelihood.
We thank you again Dr. Rubino for the opportunity to provide our collec�ve input to this important
document and we look forward with great an�cipa�on to working with you and your oﬃce.
With apprecia�on,
Organiza ion Signees
Capt. George P McShea, Jr. Apostleship of the Sea of the United States
Crystal Truong Galveston Area Vietnamese Shrimp Fleet
Nuoi Bui Gulf Vietnamese Commercial Fishermen Associa�on
Lieutenant Governor William “Billy” Nungesser Louisiana Department of Culture, Recrea�on, and Tourism
Samantha Carrol Louisiana Seafood Promo�on and Marke�ng Board
Acy J Cooper Louisiana Shrimp Associa�on
Acy J Cooper Louisiana Shrimp Task Force
Thuy Vu Palacios Area Vietnamese Shrimp Fleet
Capt. Kyle Kimball Port Arthur Area Shrimpers Associa�onCapt. James B Robertson
Port Arthur Interna�onal Seafarers’ CenterPublic comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Huger McClellan McClellanville Watermen’s Associa�onJohn Williams Southern Shrimp Alliance
Very Reverend Sinclair Oubre, JCL, AFNI Stella Maris Diocese of BeaumontAndrea Hance Texas Shrimp Associa�on

Other Signees
Earnest “Earnie” Aparicio Anchor Seafood
Chris Londrie Co-Pak
Dung Bui Intracoastal Seafood
Devan Phan Palmer Foods
Ken Garcia Quality Seafood
Gary Graham Teal Trawlers LLC

CC: Congressional delega�ons of Texas, Louisiana, Mississippi, Alabama, Florida, Georgia, South
Carolina, and North Carolina.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

March 31, 2023

To:

Michael Rubino, Ph.D., Senior Advisor for Seafood Strategy
NOAA Fisheries Oﬃce, NOAA Fisheries Directorate

From:

The domes�c shrimp industry of the Gulf of Mexico and South Atlan�c United States

Re:

Comments on the Dra� Na�onal Seafood Strategy

Dr. Rubino,
Thank you for the opportunity to comment on the NOAA Dra� Na�onal Seafood Strategy. We
commend NOAA Fisheries for recognizing the value of stakeholder input in addressing the many
opportuni�es and challenges facing our domes�c seafood sectors.
We are a group of 20 allied organiza�ons and companies represen�ng more than 4,000 seafoodbusinesses of the U.S. Gulf of Mexico and South Atlan�c region involved in the harves�ng,
processing, and distribu�on of wild shrimp. Through this leter, we hope to brieﬂy highlight our
background and status and to emphasize three prac�cal recommenda�ons for addressing the
economic vulnerability of our industry.
BackgroundThe commercial harves�ng of shrimp dates to the mid-1700s and is one of America’s oldest
seafood sectors. The U.S. domes�c shrimp industry experienced rapid growth throughout most of
the 20th Century, rising in prominence to become one of the na�on’s largest marine commodi�es byvolume and value. In the past 40 years, dockside revenues for U.S. landed shrimp have exceeded$500 million annually, with more than a billion in value-added sales suppor�ng many thousandsof sector-dependent business and jobs. Nearly all of this ac�vity derives from commercial
opera�ons in the U.S Gulf of Mexico and South Atlan�c region. These shrimping families represent
the founda�on of the local cultural fabric and basis of localized economies.
During this same period, shrimp have emerged as the na�on’s most popular seafood, accoun�ng forthe largest percentage of seafood market share and per capita consump�on. Most of this recent
growth, however, has been driven by imported shrimp.
From ini�al produc�on trials in the 1960s, the global shrimp aquaculture industry has grown to an
economic juggernaut, with an annual volume approaching 5 million tons. This produc�on derives
primarily from countries of the Asian-Paciﬁc Rim, and for decades the primary importer has been
the Unites States. The amount of shrimp imported to the U.S. rose from 225 million pounds in1980 to more than 2 billion pounds in 2021. The value of these imports exceeded $7.8 billion
dollars in 2022.
Status
The inﬂux of imported shrimp and the resul�ng commodi�za�on of the global shrimp market has
proven especially problema�c for domes�c harvesters. Despite rising costs for fuel and labor, theprice of Gulf shrimp, for example, has not increased since 1980. For the past 40 years, the average
dockside price of Gulf shrimp (all species and grades combined) has ranged from $1.50-$2.00 per

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

pound. Adjusted for inﬂa�on, this stagna�on equates to a 70% reduc�on in the real price ofshrimp paid to domes�c harvesters since 1980. As the proﬁtability of domes�c shrimp harves�ng
has decreased, increases in shrimp demand have been serviced by imports - and the share ofdomes�c landings in the U.S. shrimp market has dwindled from 90% to less than 10%. As a result of
these forces, the U.S. now has less than 40% of the shrimp harves�ng vessels it had just 20 years
ago. The remnant ﬂeet, which for years has operated on increasingly thin margins, is now at athreshold that will prove devasta�ng in the absence of interven�on. Last year, and this year, manyof our vessels could no longer aﬀord to operate, and will remain in port during much of the season.
Recent ar�cles from seafood news media have conveyed the crisis with headlines like Brink ofCollapse and Verge of Extinction. The value of the shrimp ﬁshery is not purely economic but
cultural and personal as well. Genera�ons of people have carried forth this industry and its richhistory. The connec�on of this industry to food on the table is not readily understood by the
consumers who should be made aware of its importance. We feel that the American market
demand for good quality shrimp is suﬃcient to support our wild caught shrimping industry ifmechanisms are in place to give domes�cally harvested product priority access to the American
consumers.
Recommendations
At the height of our crisis, we are heartened to see that the Dra� Na�onal Seafood Strategy alreadyhighlights several issues of tremendous importance to our industry. We are par�cularly encouraged
to see an emphasis on fair trade and domes�c markets under Goal 3, and the focus on seafood
security under Goal 4.
We agree that a viable Na�onal Seafood Strategy (to quote the Dra� Plan) should address
important issues such as:“…the resilience of coastal ﬁshing communities; the ﬁnancial viability of the seafoodindustry; the eﬀects and opportunities of international trade; and the importance of
seafood (to) food security…”
To this extent we strongly encourage that three cri�cal issues be fully addressed in the ﬁnal
revisions to the Na�onal Seafood Strategy.
1.

Expand the capacity for seafood import inspec�on and enforcement

The Dra� Plan recognizes the need to “…decrease our reliance on foreign ﬁsheries that are at
greater risk of overﬁshing, Illegal, Unreported, and Ungulated (IUU) ﬁshing, and forced labor”.
We contend that the ﬁnal document should also include foreign aquaculture as an addi�onal
source of these concerns. There are many well-documented cases of IUU and labor issues inforeign aquaculture. Foreign shrimp farming con�nues to be challenged by environmental
degrada�on and the use of harmful substances. In comparison, domes�c shrimp are highlyregulated and free from banned chemicals and an�bio�cs.
We encourage NOAA to speciﬁcally acknowledge and endorse the more than 20 goals andobjec�ves called for by the Food and Drug Administra�on (FDA) in their February 2023 report:“Activities for the Safety of Imported Seafood”. We request that NOAA Fisheries acknowledge
this report in the revised plan and reiterate the call for increased capacity and training for
seafood import inspec�on agents, increased border surveillance, public awareness of
consump�on risk, and more rapid and eﬀec�ve response to seafood import viola�ons.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

2.

Develop new programs to improve domes�c seafood security

It is commendable that the issue of food security has been included in the Dra� Plan. Indeed,
an increasing na�onal focus on food security has grown from supply chain vulnerabili�es
exposed by the Covid-19 pandemic. American consumers are coming to grips with howdependent they have been on foreign sources especially in �mes of interna�onal stress. Goingforward, seafood must be included in this emerging na�onal focus of food security. We
encourage NOAA Fisheries to acknowledge in the Na�onal Seafood Strategy the need forprograms and policies for seafood that are similar to those implemented for agricultural
security under the U.S. Farm Bill. There are many poten�al approaches, including domes�cprice supports, tax incen�ves, increased fuel credits and ins�tu�onal purchases of domes�cseafood commodi�es that should be implemented on a con�nuing basis to ensure ongoingna�onal food security.
Beginning in 2020, the Agricultural Marke�ng Service (AMS) branch of the United States
Department of Agriculture (USDA) increased its purchase and distribu�on of food products by$159.4 million. This expansion included the largest ins�tu�onal purchase of American
seafood in our na�on’s history. Embedded in the seafood purchase was the ﬁrst-ever inclusionof wild-caught American shrimp, never before considered eligible for the USDA/AMS program.
From 2021 to 2022, a total of $50 million in cash from USDA was infused into the shrimping
industry, and 7.6 million pounds of domes�c shrimp taken out of inventory and distributedna�onwide. We request that NOAA Fisheries speciﬁcally acknowledge this ini�a�ve in therevised plan. Expanded ins�tu�onal purchases are vital to securing domes�c seafood security
and sustaining our domes�c shrimp sector.

3.

Reevaluate the distribu�on seafood import du�esSec�on 32 of the Agricultural Adjustment Act of 1935 authorizes the federal government toredistribute public funds in support of agricultural prices and markets. In the context ofseafood imports, the law allows for the collec�on of trade du�es to provide ﬁnancial
assistance to domes�c shrimp producers that may be nega�vely aﬀected by imports ofseafood products.
The two billion pounds of foreign shrimp imported annually account for the largest volume of
any U.S. imported seafood commodity. The U.S. Department of Commerce has worked throughthe Interna�onal Trade Commission (ITC) to impose an�-dumping du�es on shrimp imports
from six countries (Brazil, Ecuador, China, India, Thailand, and Vietnam). These import du�eshave resulted in almost a half billion dollars in government collec�ons from 2010-2020. Yet
the businesses for which these du�es are collected to protect rarely see direct support fromthis program.
Although seafood import du�es do support the domes�c industry indirectly by funding
government opera�ons (NOAA Fisheries) and targeted research (Saltonstall-Kennedy), we callon your oﬃce to revisit the original intent of Sec�on 32 and to iden�fy more direct andequitable ways to allocate these funds across the industry, including harvesters. Withoutsome realignment and interven�on, there will be no domes�c shrimp sector to protect.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

We understand these recommenda�ons come with a substan�al commitment of �me and eﬀort by
NOAA Fisheries and other federal agencies. Our organiza�ons have spent decades on the front lineof these issues, and we are prepared to con�nue working with federal agencies and ourcongressional delega�ons to achieve much needed progress.
Our overriding request is that the 3 issues outlined above be fully addressed in the ﬁnal versionof the Na�onal Seafood Strategy. Please let us know when and where we can expect to receive
feedback from your oﬃce. Responses can be sent to the email addresses below.
NOAA Fisheries has an opportunity to signal its commitment and support to one of the na�on’s
oldest seafood sectors. In doing so, your oﬃce will provide hope to the many coastal communi�es,
business, families, and individuals who depend on domes�c seafood for their heritage andlivelihood.
We thank you again Dr. Rubino for the opportunity to provide our collec�ve input to this important
document and we look forward with great an�cipa�on to working with you and your oﬃce.
With apprecia�on,
Organization Signees
Capt. George P McShea, Jr. - aosusa@sbcglobal.net
Apostleship of the Sea of the United States
Crystal Truong - crystaltruong4@yahoo.com
Galveston Area Vietnamese Shrimp Fleet
Nuoi Bui - nuoivanbui@gmail.com
Gulf Vietnamese Commercial Fishermen Associa�on
Lieutenant Governor William “Billy” Nungesser - ltgov@crt.la.gov
Louisiana Department of Culture, Recrea�on, and Tourism
Samantha Carrol - scarroll@crt.la.gov
Louisiana Seafood Promo�on and Marke�ng Board
Acy J Cooper - acycooper@louisianashrimp.org
Louisiana Shrimp Associa�on
Acy J Cooper - acycooper@louisianashrimp.org
Louisiana Shrimp Task Force
Thuy Vu - tweecte@yahoo.com
Palacios Area Vietnamese Shrimp Fleet
Capt. Kyle Kimball - pashrimpersassocia�on@gmail.com
Port Arthur Area Shrimpers Associa�onCapt. James B Robertson- jim@strategictowingservices.com
Port Arthur Interna�onal Seafarers’ CenterPublic comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Huger McClellan - Huger2ndSC@gmail.com
McClellanville Watermen’s Associa�onJohn Williams - john@shrimpalliance.com
Southern Shrimp Alliance
Very Reverend Sinclair Oubre, JCL, AFNI - sinclair.oubre@stellamarismail.org
Stella Maris Diocese of BeaumontAndrea Hance - andreahance@texasshrimpassocia�on.com
Texas Shrimp Associa�on

Other Signees
Earnest “Earnie” Aparicio - ernieaparicio@hotmail.com
Anchor Seafood
Chris Londrie - chris.londrie@texasgoldshrimp.com
Co-PakDung Bui - dungthibui@gmail.com
Intracoastal Seafood
Devan Phan - annahphan@gmail.com
Palmer Foods
Ken Garcia - kengarcia09@yahoo.com
Quality Seafood
Gary Graham - glgshrimp@embarqmail.com
Teal Trawlers LLC

CC: Congressional delega�ons of Texas, Louisiana, Mississippi, Alabama, Florida, Georgia, South
Carolina, and North Carolina.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Southern Shrimp Alliance
P.O. Box 1577 Tarpon Springs, FL 34688
955 E. MLK Dr. Suite D Tarpon Springs, FL 34689
727-934-5090 Fax 727-934-5362

March 24, 2023
TO:

Janet Coit, Assistant Administrator for Fisheries, NOAA
Michael Rubino, Senior Advisor for Seafood Strategy, NOAAFROM: John Williams, ExecuHve Director, Southern Shrimp AllianceRE:

NOAA Fisheries DraK NaHonal Seafood Strategy

The Southern Shrimp Alliance (SSA) appreciates the opportunity to present these comments on
the NOAA Fisheries DraK NaHonal Seafood Strategy. SSA also appreciated the opportunity toreceive and provide inputs on a presentaHon of this Strategy by Mr. Rubino at the March 16,2023, meeHng of the Gulf of Mexico Fishery Management Council’s Shrimp Advisory Panel on
which several SSA representaHves sit, including me. I note that some of the comments made atthat Shrimp AP meeHng by SSA representaHves are further elaborated in these comments.
General Comments
Shrimp is the most popular seafood consumed in the U.S. Urner Barry reports that in 2020, U.S.
shrimp consumpHon rose to 5.0 pounds per capita, a 25 percent increase over the previous ﬁve
years, and in 2021 and 2022, rose sHll further to record highs at 5.8 pounds and 5.7 pounds,
respecHvely 1. According to NOAA’s Fisheries of the United States, total U.S. seafood (ﬁsh andshellﬁsh) consumpHon per capita in 2020 was 19.0 pounds 2. From these ﬁgures, we canconclude that shrimp accounts for more than 30 percent of all seafood consumed in the U.S.
According to NOAA's foreign fishery trade and commercial landings databases, the total U.S.
supply of shrimp to the U.S. market in 2021 was nearly 2.2 billion pounds, of which only 8.7
percent (188.7 million pounds) was landed by the U.S. Gulf and South AtlanHc shrimp ﬁsheries,_______________

1
2h"ps://www.urnerbarry.com/PDF/Consul8ng/shrimp_inventory_fcst.pdf
h"ps://www.ﬁsheries.noaa.gov/resource/document/ﬁsheries-united-states-2020

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

while 91.3% (1.98 billion pounds) were imported. 3, 4 From these ﬁgures, we can conclude thatapproximately 27.4 percent (602 million pounds) of all seafood consumed annually in the U.S. isimported shrimp.
While precise esHmates can be elusive, numerous federal and non-proﬁt studies indicate that asubstanHal porHon of shrimp imports consumed in the U.S. is produced in IUU ﬁsheries andusing forced or child labor in ﬁsheries, processing faciliHes, the producHon of feed used byshrimp farms, and in the operaHons of those farms as well.
Further, the results of FDA’s tesHng of farm-raised shrimp imports from naHons that are thelargest suppliers of shrimp imports to the U.S. conﬁrm that a signiﬁcant percentage of such
shrimp is contaminated with residues of FDA-banned anHbioHcs used on those farms to preventor treat disease outbreaks, increase stocking densiHes, and increase growth rates. The humanhealth threats associated with those anHbioHc residues in shrimp imports are both on theindividual level – such as in the case of aplasHc anemia – and on the global human populaHon
level – as in the case of contribuHng to anH-microbial resistance – something that many world
health experts have idenHﬁed as the greatest threat to human health in the coming decades.
We must also point out that in addiHon to being abhorrent abuses of human rights, threats tohuman health, and violaHons of ﬁshery conservaHon objecHves, these serious and illegal
deﬁciencies in the standards and pracHces by which some signiﬁcant percentage of shrimp
imports consumed in the U.S. is produced provide those foreign shrimp producers – whether inwild capture ﬁsheries, in processing faciliHes, or on shrimp farms – with a substanHal
compeHHve advantage in the U.S. market over shrimp produced in our domesHc shrimp
ﬁsheries.
As is well documented by NOAA’s own staHsHcs, ex vessel prices for U.S caught shrimp, U.S.
shrimp landings, U.S. shrimp ﬁshing eﬀort, and the number of acHve vessels in the U.S. shrimp
ﬂeet have all fallen to record lows in recent years since the massive and conHnued growth in
U.S. shrimp imports over the past two decades that was fueled by the development and rapid
expansion of shrimp farming in the major shrimp exporHng naHons.
This reality has today reached existenHal proporHons for the domesHc shrimp industry. Recent
surges in shrimp imports have ﬂooded the U.S. market and overwhelmed U.S. inventories to thepoint that shrimp processors can no longer purchase shrimp from U.S. shrimp ﬁshermen. As a
direct result, a substanHal number of U.S. shrimp vessels are currently unable to ﬁsh at all andremain Hed to the dock. Those that go ﬁshing have found that they cannot sell their shrimp at a
proﬁt, if at all. Many believe that we are on the precipice of the collapse of this iconic Americanﬁshery – once the most valuable in the enHre U.S. and today sHll the most valuable in the Gulf
of Mexico.
________________
3
4h"ps://www.ﬁsheries.noaa.gov/na8onal/sustainable-ﬁsheries/foreign-ﬁshery-trade-datah"ps://www.ﬁsheries.noaa.gov/foss/f?p=215:200:32165188631007:Mail::::2

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Consequently, no U.S. ﬁshery has a more signiﬁcant stake in NOAA’s NaHonal Seafood Strategy
than the domesHc shrimp industry. For these reasons, SSA strongly supports the clear focus of
this NaHonal Strategy on protecHng and advancing U.S. seafood producHon, including shrimp,
the most sustainable and safe seafood in the world.
SSA membership comprises shrimp ﬁshermen, processors, and the associated shoresideenterprises and ﬁshery-dependent communiHes throughout the Gulf and South AtlanHc
regions. Working on their behalf since its founding 20 years ago, SSA has shared many of thesame purposes and prioriHes - along with the goals and the strategies to achieve them - as are
reﬂected in this NOAA NaHonal Strategy. We strongly support this overall Strategy and lookforward to working with NOAA to implement it. However, we must stress that there are several
very important objecHves and acHons outside of NOAA’s scope that other federal agencies andCongress must pursue to address the U.S. shrimp industry’s current and long-term needs, andwe plan to conHnue our work with those other agencies and Congress as well. We certainly
encourage NOAA to do the same.
GOAL 1: Sustain or increase sustainable U.S. wild capture produc<on
On its face, this Goal states a fundamental shrimp industry priority, and it sets forth speciﬁcscience, management, and habitat protecHon objecHves and strategies for ﬁshery sustainability
that are shared by the shrimp industry - not just in words but in acHons.
SSA regularly partners with NOAA and non-federal scienHsts to generate the best scienHﬁc
informaHon available and parHcipates extensively in the federal ﬁshery management process
through the Regional Councils, the Advisory Panels, and the agency’s rulemaking process tosustainably manage our shrimp stocks, to minimize our bycatch to the extent pracHcable, and toprotect sensiHve marine habitats.
SSA looks forward to conHnuing its partnerships and collaboraHons with NOAA and its partner
agencies in implemenHng this Goal through the following prioriHes, among others:-

EssenHal to the eﬀecHve assessment of shrimp stocks and the management of theﬁshery to minimize bycatch and protect sensiHve habitats is the collecHon and analysisof data that provides precise measures of shrimp ﬁshing eﬀort. The agency mustcomplete its work with the Gulf Council and shrimp industry to implement a new
system.

-As noted in the Strategy itself, “new ocean uses” compeHng with the shrimp industry forspace present a new challenge to the Goal to “sustain or increase sustainable U.S. wild
capture produc9on” of shrimp, as well as to the goals of “Maximizing ﬁshing
opportuni9es and sustainable seafood produc9on…”. Therefore, NOAA must conHnue
developing and applying spaHal suitability modeling in collaboraHon with the shrimp
industry and, as appropriate, with its partner agencies to deconﬂict such new ocean uses
as oﬀshore aquaculture and oﬀshore wind energy development with the shrimp
industry. We note that the availability of precise measures of shrimp ﬁshing eﬀort arealso an essenHal element of this modeling.
3

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

GOAL 2: Increase sustainable U.S. aquaculture produc<onOnce again, SSA shares the perspecHve reﬂected in this stated Goal of the Strategy:“Suppor9ng gradual, diverse, and regionally-appropriate growth of the domes9c
industry will depend on an eﬃcient, strategic, and science-based regulatory approachthat considers and mi9gates impacts on protected resources, essen9al ﬁsh habitat, andmarine ecosystems.” (emphasis added)
SSA has engaged extensively to ensure that future oﬀshore aquaculture development follows
that necessary science-based approach. As noted above, SSA has collaborated with NOAA’s
NaHonal Centers for Coastal Ocean Sciences (NCCOS) in its spaHal suitability modeling and thedevelopment of its Aquaculture Opportunity Areas (AOA) Atlas for the Gulf of Mexico. SSA is
also providing extensive inputs addressing ecosystem and shrimp industry impacts to NOAA’s
ongoing development of a ProgrammaHc Environmental Impact States (PEIS) for AOAs in the
Gulf. 5 And, while serving as a Steering Commikee Member, it brought the shrimp industry’s
perspecHves and experHse to the Meridian InsHtute’s noteworthy workshop addressing thefuture of U.S. marine aquaculture.6
SSA again looks forward to conHnuing its partnerships and collaboraHons with NOAA and its
partner agencies in implemenHng this Goal through the following shrimp industry priority:-

The agency’s implementaHon of this Goal must prioriHze the sustainability of thisindustry to no less of a degree than it prioriHzes the sustainability of wild captureﬁsheries – with respect to potenHal ecosystem and habitat impacts and with respect todeconﬂicHng oﬀshore aquaculture operaHons with the ﬁshing industry both in the ocean
environment and in the seafood marketplace.

GOAL 3: Foster access to domes<c and global markets for the U.S. seafood industry
Of the goals of this Strategy to which the domesHc shrimp industry most closely relates intoday’s circumstances of a completely import-dominated U.S. market are the following:“A thriving, well-regulated domes9c seafood industry—capable of compe9ng at home
and abroad—will translate into greater global seafood supply and food security fromsustainable U.S. ﬁsheries. It will also decrease our reliance on foreign ﬁsheries that are at
greater risk of overﬁshing, IUU ﬁshing, and forced labor.” (emphasis added)“Promote fair seafood trade by comba9ng IUU ﬁshing and related harmful ﬁshingprac9ces around the world…..”
5h"ps://www.shrimpalliance.com/wp-content/uploads/2023/03/SSA-Comments-AOA-PEIS-no8ce-of-intent-721-22-.pdf
6h"ps://www.dropbox.com/s/niiuoivqzvruxl0/U.S.%20Marine%20Aquaculture%20Workshop%20Synthesis_Spring%202022.pdf?dl=0

4

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Since its founding, SSA has fought to combat unfair and illegal trade through the imposiHon ofanH-dumping duHes now in place for shrimp imports from China, India, Thailand, and Vietnam
and by working with Congress and federal agencies to develop, strengthen, and implement
policies and programs to prevent the importaHon of seafood produced in IUU ﬁsheries or withthe use of forced or child labor, with the use of illegal anHbioHcs, or imported through any
fraudulent means such as product mischaracterizaHon and mislabeling. Together with its
commitment to achieving the highest level of sustainability for any shrimp ﬁsheries in theworld, SSA’s extraordinary investment in combanng unfair and illegal seafood trade literally
deﬁnes the organizaHon.
Which brings us to the Strategy’s addiHonal and pivotal stated goal to “put more U.S. seafood
back on U.S. plates.” This, along with the focus of the enHre Strategy on increasing U.S. seafood
producHon and strengthening the resilience of the domesHc seafood-producing sector in partby taking acHons that level the playing ﬁeld with imports, could not resonate more with thedomesHc shrimp industry. The agency has it absolutely right in this Strategy.
That said, the non-proﬁt Seafood NutriHon Partnership (SNP) has advanced an iniHaHve thatwould establish a NaHonal Seafood Council and provide that Council with $25 million ofCongressional appropriaHons each year for ﬁve years for a naHonal seafood markeHng campaign(Eat Seafood, America) to promote seafood consumpHon in the U.S. 7
As described by SNP on their website and in many posts, the campaign will promote an increasein U.S. seafood consumpHon by promoHng - the human health beneﬁts of eaHng seafood - thesustainability of seafood, especially as compared to other meat proteins (beef, pork, chicken) and the many US jobs an increase in U.S. seafood consumpHon would create. The unfortunate
problem is, however, this markeHng campaign and the $125 million in taxpayer funds would be
used to promote U.S. consumpHon of both domesHc seafood producHon AND seafood imports.
For convenience here, using the oKen-cited staHsHc that roughly 90 percent of seafood
consumed in the U.S. is imported, that means, eﬀecHvely, that the campaign might use $112.5
million of U.S. taxpayer dollars to promote the U.S. consumpHon of seafood imports over those
ﬁve years, assuming their expenditures were proporHonal to that 90 percent ﬁgure. Contrary to
SNP’s claims, seafood imports are oKen neither sustainable nor healthy, and they oKen
compete unfairly—if not illegally—against U.S. ﬁsheries and U.S. jobs in many ways we havereferenced in these comments and elsewhere (e.g., IUU ﬁshing, forced labor, productmisrepresentaHon/fraud, substandard conservaHon standards, etc.).
If we consider just the InternaHonal Trade Commission's 2021 Report indicaHng thatapproximately 11 percent of U.S. seafood imports were derived from IUU ﬁshing in 2019, thatwould mean that the SNP campaign might proporHonately end up spending $12.4 million of
taxpayer funds over those ﬁve years on promoHng the consumpHon in the U.S. of seafood
derived from IUU ﬁshing. 8____________________
7
8h"ps://www.seafoodnutri8on.org/eat-seafood-america/h"ps://www.usitc.gov/press_room/news_release/2021/er0318ll1740.htm

5Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Given the extensive and much appreciated commitment and investment by NOAA in combanng
IUU ﬁshing, forced and child labor in the seafood supply chain, and all other forms of illegal
seafood imports, we expect that NOAA and the AdministraHon broadly would never support
spending U.S. taxpayer dollars on promoHng the U.S. consumpHon of seafood imports.
Indeed, we must recognize the extraordinary scope of authoriHes and programs to prevent
illegal seafood imports that NOAA’s Oﬃce of InternaHonal Aﬀairs, Trade, and Commerce isdevoted to implemenHng and enforcing in collaboraHon with other Federal agency partners,
such as the Seafood Import Monitoring Program (SIMP), the High Seas DriKnet Fishing
Moratorium ProtecHon Act, the Marine Mammal ProtecHon Act, among others.
Indeed, given all of the deﬁciencies in the standards and pracHces associated with seafood
imports idenHﬁed to date, the clearly arHculated purposes and goals and strategies of thisNOAA NaHonal Seafood Strategy to promote and increase U.S. wild and aquaculture producHon,
to “decrease our reliance on foreign ﬁsheries that are at greater risk of overﬁshing, IUU ﬁshing,
and forced labor,” and “to put more U.S. seafood back on U.S. plates” should ensure that NOAA
would never support or parHcipate in any acHvity such as the SNP campaign that would
promote the U.S. consumpHon of seafood imports.
Indeed, promoHng the U.S. consumpHon of seafood imports known to include seafood derived
from IUU ﬁsheries or produced using forced and child labor would be the anHthesis ofcombanng those illegal and abhorrent pracHces. Such support or parHcipaHon in the SNP
campaign would be strikingly inconsistent with NOAA’s NaHonal Seafood Strategy and the very
purpose and mission of its own Oﬃce of InternaHonal Aﬀairs, Trade, and Commerce. It would
represent a serious disservice to U.S. seafood consumers and their health, and a betrayal of thedomesHc wild capture and aquaculture producHon industries.
But wait….
The SNP website indicates that “The Eat Seafood, America! campaign is a collabora9ve eﬀort ofthe members of the Seafood4Health Ac9on Coali9on”. It then lists the members of thisCoali9on, which includes “NOAA Fisheries”. 9
Further, as reported by Cliﬀ White in his November 3, 2022, Seafood Source arHcle addressing
the departure from NOAA Fisheries of Deputy Assistant Administrator Paul Doremus:
While working in partnership with the Na9onal Seafood Council Task Force over the past
two years, Doremus played a key role in advoca9ng for federal funding for the Na9onal
Seafood Council, an industry-led eﬀort suppor9ng the Seafood Nutri9on Partnership(SNP) with its eﬀorts to promote seafood as a healthy food source, leveraging
recommenda9ons from NOAA’s Marine Fisheries Advisory Council.” (emphasis added) 10__________________
9h"ps://www.seafoodnutri8on.org/eat-seafood-america/h"ps://www.seafoodsource.com/news/premium/supply-trade/paul-doremus-leaving-noaa-joining-trident-notexpected-to-jeopardize-seafood-marke8ng-board-push10

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Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Indeed, while akending the 2022 Seafood Expo North America conference in Boston, SSA’s
representaHve heard ﬁrst-hand Mr. Doremus’s public expressions of strong support for the
SNP’s campaign to promote U.S. seafood consumpHon, including seafood imports,
notwithstanding the fact that at the very same conference, more senior NOAA oﬃcials spoke
extensively about the agency’s commitment to and investments in combanng IUU ﬁshing, theuse of forced and child labor, and the substandard conservaHon pracHces associated withseafood import supply chains.
SHll further, in that November 3, 2022, arHcle Mr. White quotes SNP’s President Linda Cornish as
follows:“Current NOAA Fisheries Assistant Administrator Janet Coit is a backer of the ini9a9ve,
Cornish said.”
Clearly, NOAA needs to reassess its policies and prioriHes. SSA calls on NOAA to rescind its
statements of support for spending federal taxpayer dollars on promoHng the U.S. consumpHonof seafood imports and support for proposed legislaHon and appropriaHons that would havethat result. SSA further calls on NOAA to cease and desist from any further parHcipaHon in the
SNP campaign so long as it conHnues to promote the U.S. consumpHon of seafood imports.
NOAA cannot adopt this NaHonal Seafood Strategy and at the same Hme support the objecHvesof or parHcipate in that campaign.
SSA notes that SNP and its campaign parHcipants sHll have the opportunity to reconsider andrevise its prioriHes to promote only the U.S. consumpHon of U.S. seafood produced in U.S. wild
capture ﬁsheries and U.S. aquaculture operaHons. Hopefully, with NOAA’s encouragement, they
will do so.
GOAL 4: Strengthen the en<re U.S. seafood sector
The U.S. shrimp market is ﬂooded with imported shrimp to the extent that it threatens the
future existence of the domesHc shrimp ﬁsheries. U.S. inventories are overwhelmed withshrimp imports. While the massive and conHnued growth in shrimp imports, especially farmraised, has a long history, today the oversupply of cheap farm-raised shrimp imports that haveoverwhelmed U.S. shrimp inventories are, in signiﬁcant part, a consequence of COVID-19
disrupHons. As referenced earlier in these comments, the domesHc shrimp industry also faces“new compe9ng uses” on both the ﬁshing grounds and in the working waterfronts, including
oﬀshore aquaculture and oﬀshore wind energy development. And, like many U.S. ﬁshingindustries, the U.S. shrimp industry is also experiencing an aging workforce and must akract
young ﬁshermen.
SSA strongly supports the goals and objecHves to strengthen the U.S. seafood sector andstrategies to achieve them set forth in this Goal of the NaHonal Strategy and looks forward toworking with NOAA to implement them.

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Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

March 16, 2023
Via online submission portal
Laura Diederick
NOAA Fisheries
1315 East-West Highway, 14th Floor
Silver Spring, MD 20910
RE:

Taylor Shellfish Company, Inc. Comments on Draft National Seafood Strategy

Dear Ms. Diederick:On behalf of Taylor Shellfish Company, Inc. (“Taylor Shellfish”), thank you for providing
an opportunity to comment on the Draft National Seafood Strategy, an outline of NOAA Fisheries’
direction for supporting a thriving domestic U.S. seafood economy.
Taylor Shellfish is a fifth-generation, family-owned company headquartered in Shelton,
Washington. The Taylor family has grown shellfish on Washington State shorelines since the1890s. The company currently cultivates a variety of shellfish species on thousands of acres oftidelands and bedlands throughout Washington State’s marine waters, including oysters, clams,
geoduck, and mussels.
Taylor Shellfish employs over 500 workers in Washington State who grow, process, sell,and serve the company’s shellfish. The company’s farms and employees are largely located in rural
areas, and Taylor’s farms help sustain and diversify these local economies.
Taylor Shellfish has a strong commitment to sustainable shellfish cultivation in all areas that
it farms, and it has received numerous recognitions for its sustainable practices. The company hasreceived independent, third-party sustainability certification from Food Alliance, and its clams,mussels, and oysters are considered “best choices” by the Monterey Bay Aquarium’s Seafood
Watch Program. Most recently, Taylor Shellfish was recognized by Seafood Source as one of the
top 25 seafood companies in North America leading in its sustainability and conservation practices. 1
I.

Taylor Shellfish Supports the Draft National Seafood Strategy

Taylor Shellfish strongly supports the aim of the Draft National Seafood Strategy to support
a thriving domestic U.S. seafood economy and enhance the resilience of the seafood sector in theface of climate change and other stressors. The Goals outlined within the Draft National Seafood
Strategy are critical to ensure that the United States continues to produce healthy, sustainable
https://www.seafoodsource.com/news/environment-sustainability/the-top-25-seafood-sustainabilityconservation?mkt_tok=eyJpIjoiTURaak56UTNNelV6TnpZeSIsInQiOiIwQldNZHFZOXlCV0J6Uk1UdHVtUDhDNGp
cL1RMY0RZR3VtOWdSQzJVWFBQWWh4TmN0Y2Y0bDJJZCtqcnBPZG5ocjJSOVJ6TlNLaFJ4TG5iVTdRS2JDek
RXdmoweGhlVDFTbWUrd0J5YmpGbTA1K2NzU21vN01sR1Uxa3UxMG9vM0cifQ%3D%3D&content%5Bb1a7c92
5-1ed6-4bc4-ab97-58e281440ce3%5D=30.

1

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

seafood and supports vibrant coastal communities now and into the future. We are hopeful thatNOAA’s actions and investments through the National Seafood Strategy will help strengthen theseafood sector and stimulate aquaculture development in the United States.
Taylor Shellfish also appreciates NOAA’s leadership on the Subcommittee on Aquaculture(“SCA”), National Science & Technology Council (“NSTC”), and encourages NOAA to continue
its work on the SCA and to ensure that the National Seafood Strategy and future implementation
plan are aligned with the SCA’s efforts, including: (1) National Strategic Plan for Aquaculture
Research, (2) Strategic Plan to Enhance Regulatory Efficiency in Aquaculture, and (3) Draft
Economic Development Plan. 2II.

Comments on Goals and Objectives

Taylor Shellfish offers the following comments and recommendations on Goals 2 and 4 of
the Draft National Seafood Strategy.
A. Goal 2. Increase Sustainable U.S. Aquaculture Production
The Draft National Seafood Strategy recognizes that growth of sustainable aquaculture is
one of only a few ways to increase the availability of domestic seafood. It further identifies “Marine
Aquaculture Management and Regulatory Efficiency” as a key strategy to support this growth byaccelerating progress on implementing an efficient, predictable, timely, and science-based
regulatory framework for marine aquaculture. Taylor Shellfish strongly supports this aim as a
critical element in meeting Goal 2.
In 1980, Congress passed the National Aquaculture Act in response to findings that thenation has potential for significant aquaculture growth, but that this growth is inhibited by many
scientific, economic, legal, and production factors. The Act was designed to address theselimitations, but instead these challenges have significantly worsened over the last 40-plus years, as
described in the Draft National Strategic Plan for Aquaculture Research 2021-2025, a Report by the
Science Planning Task Force of the SCA, NSTC Committee on Environment:
By value, nearly 90 percent of the seafood we eat comes from abroad, more than halfof it from aquaculture. The 90 percent figure includes seafood caught in the UnitedStates, processed abroad, and imported in the processed form back into the UnitedStates. Driven by imports, the U.S. seafood trade deficit had grown to $14 billion in
2016. 3

2

The SCA’s strategic plans are available on its website: https://www.ars.usda.gov/sca/.

Draft National Strategic Plan for Aquaculture Research 2021, A Report by the Science Planning Task Force
Subcommittee on Aquaculture, Committee on Environment of the National Science & Technology Council (2021)
https://www.ars.usda.gov/SCA/Documents/DRAFT_2021%20NSTC%20Subcommittee%20on%20Aquaculture%20Re
search%20Plan.pdf).

3

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Although NOAA has made great efforts to stimulate growth of domestic aquaculture
production through initiatives such as the Marine Aquaculture Policy and the National Shellfish
Initiative, 4 academic studies continue to show “developed countries may have depressed their
growth rates even further through regulatory regimes that do not utilize current knowledge and are
inefficient in other respects.” 5
Additionally, the National Ocean Council’s National Ocean Policy Implementation Plan
stresses “[t]he aquaculture industry will benefit from streamlined Federal permitting andcoordinated research efforts to support sustainable aquaculture.” 6 And NOAA’s FY 2023-2028
Aquaculture Strategic Plan identifies regulatory efficiency as “Goal 1” to expanding sustainablemarine aquaculture production in the country, with multiple objectives and strategies designed to
improve upon existing permit processes. 7
These federal laws and programs recognizing the importance of a robust aquacultureindustry are reinforced at the state and local level, including in Washington State where most of
Taylor’s farms are located. The legislative findings of Washington State’s Bush and Callow Acts
reinforce that it is “the policy of this state to encourage the development and expansion of shellfish
farming within the state and to promote the development of a diverse shellfish farming
industry….” 8 Moreover, the Washington State Shoreline Management Act, which strives to achieve
coordinated planning for the State’s shorelines, identifies aquaculture as a preferred, waterdependent use that can have long-term benefits and protect the resources and ecology of theshoreline. 9
Consistent with these legislative and policy directives, former Governor Christine Gregoirelaunched the Washington Shellfish Initiative in 2011 to encourage shellfish farming in the State.
The Washington Shellfish Initiative recognizes shellfish aquaculture is critically important to the
NOAA Marine Aquaculture Policy(http://www.nmfs.noaa.gov/aquaculture/docs/policy/noaa_aquaculture_policy_2011.pdf); NOAA National Shellfish
Initiative Fact Sheet.
(http://www.nmfs.noaa.gov/aquaculture/docs/policy/natl_shellfish_init_factsheet_summer_2013.pdf). Key strategies of
the National Shellfish Initiative include improving permitting processes to make them more transparent, predictable,
and efficient, and supporting innovative commercial culture and conservation techniques.
5
Abate et al., Stringency of environmental regulation and aquaculture growth: A cross-country analysis, Aquaculture
Economics & Management, 2016 Vol. 20, No. 2, 201-221, 219.
(http://www.tandfonline.com/doi/pdf/10.1080/13657305.2016.1156191). Taylor Shellfish is not opposed to efficientand science-based regulatory requirements. However, as recognized by multiple stakeholders, the current permitting
regime for commercial shellfish aquaculture in the United States is overly complex and inefficient, and this inefficiency
limits our country’s aquaculture potential, preventing economic growth, and endangering food security.
6
National Ocean Policy Implementation Plan, p. 3
(https://www.whitehouse.gov/sites/default/files/national_ocean_policy_implementation_plan.pdf).
7
NOAA Fisheries Aquaculture Strategic Plan FY 2023-2028, pp. 7-9 (https://media.fisheries.noaa.gov/202210/Strategic-Plan-102422-web.pdf).
8Wash. ESHB 2819 (2002 c 123 § 1).
9
RCW 90.58.020; WAC 173-26-241(3)(b).
4

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

State’s ecology, economy, and culture. 10 Shellfish help filter and improve the quality of marine
waters and are an important part of the solution to restore and preserve the health of endangeredwaters. 11 Washington State leads the country in the production of farmed clams, oysters, andmussels with an estimated total economic contribution of $184 million in 2010, and shellfish
growers directly and indirectly employ over 2,700 people in the State and are among the largest
private employers in some counties. 12 A key goal of Phase II of the Washington Shellfish Initiative
is to improve permitting processes to maintain and increase sustainable aquaculture. 13 Streamlining
permitting requirements is critical to increasing shellfish production in Washington State, as
shellfish farmers are subject to numerous federal, state, and local permitting requirements that canbe extremely costly and difficult to navigate.
Another key effort of the Washington Shellfish Initiative is the creation of the Shellfish
Interagency Permitting (“SIP”) Team—a multi-agency team that includes the U.S. Corps ofEngineers Corps (“Corps”) and is designed to address issues around the permitting process. The SIPTeam has identified numerous recommendations to improve efficiencies in the extensive andcomplex permitting process for shellfish farming activities in Washington State. 14
In an attempt to address some of these regulatory inefficiencies, Taylor Shellfish is working
with the National Marine Fisheries Service and U.S. Fish and Wildlife Service in development of a
Habitat Conservation Plan (“HCP”). Taylor has made significant investments in pursuit of an HCP
in hopes that it will both achieve better outcomes of sensitive species and habitat as well as assist
the company in overcoming complex regulatory challenges through a robust, science-based farmmanagement process. Taylor expects the HCP to not only foster its own operations but also
maximize benefits for the critical habitats and coastal communities in and around its farms.
B. Goal 4. Strengthen the Entire U.S. Seafood Sector
The Draft National Seafood Strategy also identifies the importance of building resilience inthe U.S. seafood sector and aims to strengthen the industry through support for communities toadapt and thrive in a changing ocean economy, modernization of seafood infrastructure, andencouragement of a growing and diverse seafood workforce. Taylor strongly supports this Goal,
which addresses key challenges facing the company as well as the broader seafood sector.
Washington Shellfish Initiative, p. 1 (http://pcsga.org/wprs/wp-content/uploads/2013/04/Washington-ShellfishInitiative.pdf).
11
Id.
12
Washington Shellfish Initiative – Phase II Policy Brief, p. 1
(http://www.governor.wa.gov/sites/default/files/shellfishoverview.pdf).
13
Washington Shellfish Initiative – Phase II Work Plan pp. 10-11(http://www.governor.wa.gov/sites/default/files/ShellfishWorkPlan.pdf).
14
Shellfish Interagency Permitting Team Phase I Report, May 5, 2016, pp. 7-8.
https://ecology.wa.gov/DOE/files/44/446c9a20-fe38-4a23-85ba-f25b87da05b8.pdf.
10

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Investments in rural coastal communities are necessary to the success of Taylor Shellfish
and other seafood farmers. Similar to the Draft National Seafood Strategy, Taylor Shellfish has
identified workforce development as a current and future need critical to the company’s ability tosupport its operations. Taylor currently struggles to fill positions on its farms and in its processing
facilities, and this challenge is expected to worsen as the company continues to grow. Further, arobust aquaculture industry must be increasingly diverse and attract new entrants.
Improvements in infrastructure, especially processing and port and dock facilities, are alsoessential to Taylor Shellfish and foundational to a strong and resilient Blue Economy. Aging andfailing infrastructure in our working waterfronts poses challenges to the company’s operations andinhibits growth. Funding assistance for undertaking essential upgrades and improvements to thesefacilities is frequently needed, and hence this is a highly effective means by which to strengthen theseafood sector.
Finally, the U.S. shellfish aquaculture sector lags behind other countries when it comes tofarming and processing technologies. Taylor Shellfish has benefitted immensely from visitingshellfish farming and processing facilities in other countries and importing equipment that is notavailable domestically. This equipment has helped Taylor improve processing efficiency andproduct quality as well as address labor shortages. Implementation of Goal 4 relative to seafood
infrastructure (perhaps within the details of the Draft Economic Development Plan) should include
opportunities for the aquaculture sector to benefit from farming and processing technology in otherregions of the world.
Taylor Shellfish thanks you for your consideration of these comments. Please do not hesitate
to contact us if you have any questions.
Sincerely,

Bill Dewey
Director of Public Affairs

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Robert Rohde
P.O. Box 2893
McKinleyville, CA 95519
March 2023
RE: NOAA’s National Seafood Policy is Biased Toward Exploitation
National Security
The US Department of Commerce, through its National Seafood Policy has again demonstrated
its bias toward fishery exploitation at the expense of US economic stability. The National
Oceanic and Atmospheric Administration (NOAA) Fisheries agency within the US Department ofCommerce intends to exploit our nations struggling fishery at the expense of national security.
Since 1977, salmon fisheries in the exclusive economic zone 3 to 200 miles off the coast of
Washington, Oregon, and California haven been managed under the Magnuson-Stevens Act andamendments. As a targeted commercial and recreation fish, Salmon are managed under the
Theory of Optimum Yield for fish food production and recreational opportunities.
The Theory of Optimum Yield is Prescribed based on the Theoretical Basis of Maximum
Sustainable Yield (MSY). “MSY is a theoretical concept that, for the purposes of the MagnusonStevens Act, is defined as the largest long-term average catch or yield that can be taken from astock or stock complex under prevailing ecological and environmental conditions and fisherytechnological characteristics, and distribution of catch among fleets (Pacific Coast Salmon
Fishery Management Plan, Pacific Fishery Management Council 7700 NE Ambassador Place,
Suite 101 Portland, Oregon 97220-1384).”“The map below illustrates the different organizations that work together to guide Pacificsalmon and steelhead fisheries management throughout their range. Each colored line
represents the migratory patterns of where Pacific salmon of a given region travel. These
colored paths show where the Pacific salmon begin their life cycle, the distances salmon can
travel along the West Coast as they mature, and where adult salmon may be caught (NOAA
Fisheries, West Coast Salmon and Steelhead Fisheries Management Map, NOAA.gov).”

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

This approach to fishery management is biased toward exploitation of the fish, rather than fish
population protection and management. So, since 1977 salmon fish populations have steadily
declined to threatened and endangered levels putting America at risk of seafood shortages,
economic decline, and national insecurity as China and other competing nations increase theirglobal presence.
If you are counting the number of fish, then you have caught too many fish already. I started
counting fish in the Klamath River watershed in 1992 as Natural Resources Manager for the
Karuk Tribe. The fish have been crashing since the gold mining era and the Department ofCommerce’s bias toward exploitation has allowed it to happen through poor incompetentmanagement.
All commercially viable stocks of fish have been severely impacted due to western exploitation
principles that have left the US and other partners in jeopardy of long-term seafood insecurity.
The National Seafood Policy is a whitewash of US fish management failures. The US
Department of Commerce no longer serves America’s best interest in managing our nation’s
fishery. To avoid further decline of America’s vital seafood and recreational opportunities the
Biden administration needs to transfer protection and management of our nation’s commercial
and recreational fishery to the US Fish and Wildlife Service, through executive order to avoid
continued and prolonged seafood shortages.
Background•“Until the end of last Ice Age, around 11,000 B.C., all peoples on all continents were still
hunter-gatherers (Diamond, 1999).”

Around 11,000 years ago, as glaciers began to recede toward the poles, a small group of people
who hunted and gathered, converted over to the use of irrigated agriculture and domesticatedanimals as their primary sources of food.
“Once people began to produce food and become sedentary, they could shorten the birth spacing
and produce still more people, requiring still more food (Diamond, pg. 29). This increase in humanscaused once previously abundant fish, wildlife and plants to disappear resulting in even more
people and has led to the overpopulation of the world.
This approach to living changed the natural balance of the world. Humans now had the ability
to exceed the carrying capacity of their environment. “Between the sixteenth and seventeenth
centuries the image of an organic cosmos with a living female earth at its center gave way to amechanistic world view in which nature was reconstructed as dead and passive, to be
dominated and controlled by humans (Merchant, pg. xvi).” The Scientific Revolution was
occurring at the same time that commercialism, industrialization, and domination of humans
over nature spread throughout the world. The US Department of Commerce still operates onPublic comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

these outdated and harmful management principals by promoting economic prosperity at theexpense of environmental sustainability that has dramatically reduced our nation’s food supply.
References••

Diamond, Jared, 1999. Guns, Germs, and Steel, The Fates of Human Societies. W.W.
Norton & Company, New York, New York.
Merchant, Carolyn, 1980. The Death of Nature, Women, Ecology and the Scientific
Revolution. Published by Harper Collins Publishers, 10 East 53rd Street, New York, NewYork.

Bycatch“For NOAA Fisheries, bycatch refers to “discarded catch of marine species and unobservedmortality due to a direct encounter with fishing vessels and gear. These unintentionally caught
animals often suffer injuries or die.” “Fisheries bycatch is a threat to marine
mammals worldwide. Bycatch occurs when marine mammals are incidentally caught in fishinggear (e.g., hooked, entangled, or trapped) or when they eat bait or catch. Bycatch of marine
mammals can occur during active fishing operations using mobile or fixed fishing gear, and it
also can result when fishing gear has been lost, discarded, or is otherwise no longer being used
to harvest fish (also known as marine debris) ((NOAA, What is Bycatch,https://www.fisheries.noaa.gov/insight/understanding-bycatch#what-is-bycatch? )Salmon that swim in territorial and international waters are considered as bycatch for some
types of commercial fishing, such as trawlers. At any point in their travels, west coast salmon
that originate from Washington, Oregon and California are unintentionally caught as bycatch,further diminishing the abundance of west coast salmon populations.
Removing bycatch as a management option would protect the fish from being caught
accidently. The US Fish and Wildlife Service is better suited to address the needs of the fish firstwith tempered harvest within the limits of full fishery abundance. NOAA Fisheries should beabandoned as an agency within the US Department of Commerce and their funds should
instead be redistributed to the US Fish and Wildlife Service to avoid long-term impacts to
American seafood supply in the face of totalitarian advancement.
Climate Change
Over billions of years Earth’s atmosphere has changed over time. Early Earth had large
quantities of carbon dioxide in the atmosphere. After millions of years, carbon dioxide
concentrations decreased while oxygen has increased allowing a Lower and Upper atmosphereto form. The burning of oil and gas builds up in the Lower Atmosphere and moves Earth back intime when carbon dioxide levels were much greater and the Lower Atmosphere was
uncomfortably hot and humid.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

The warming of Earth’s atmosphere tracks atmospheric carbon dioxide levels closely. As carbon
dioxide levels increase in the lower atmosphere so does atmospheric temperature, as shown
below:

Lower atmosphere temperature increases as carbon dioxide increases over time, from years
1880 to 2016.
The following website tracks the steady rise of carbon dioxide in the Earth’s Lower Atmospheresince 2005, and it is a useful website to show the public on a regular basis:
https://climate.nasa.gov/vital-signs/carbon-dioxide/
Land tends to heat quickly during the day and cool rapidly at night as earth rotates to the east.
The Earth’s surface absorbs the sun’s radiation during the day and radiates the warm air backinto the Lower Atmosphere as the sun disappears to the west. The absorbed radiation from thesun by the Earth’s surface is radiated back into the Lower Atmosphere, mixes with the colder air
above and creates air movement patterns that we experience on the Earth’s surface as Weather.
The Sun is the heat source that causes Weather and Climate on Earth. Weather is a local orregional experience over a short period of time, such as a sunny day. Climate is a feature of theatmosphere that is experienced over a long period of time. When scientists say that the Earth’s
Climate is changing, they are talking about changes that are occurring over a long-period oftime, not local or regional short-term weather conditions.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Climate and weather are affected by large concentrations of carbon dioxide, as shown in the
NOAA February 13, 2023 satellite image of carbon dioxide GOES-East (Band 16) below:“Since 1975, NOAA's Geostationary Operational Environmental Satellites (GOES) have provided
continuous imagery and data on atmospheric conditions and solar activity (space weather) (NOAA,
Satellite Information System. https://www.noaasis.noaa.gov/GOES/goes_overview.html).

Orange and yellow images paid for with tax dollars show the location of global warming gasses,(above). The public is unaware that these images are available for their use due to NOAA
institutional bias. These satellite images need to be presented to the public (such as throughthe National Weather Service) so that the public can learn to see the global warming problem
for themselves.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Here are the Eastern and Western NOAA Carbon Dioxide (CO2) Satellite images:
GOES-East
https://www.star.nesdis.noaa.gov/GOES/fulldisk_band.php?sat=G16&band=16&length=12&dim=0
GOES-Westhttps://www.star.nesdis.noaa.gov/GOES/fulldisk_band.php?sat=G17&band=16&length=12&dim=0
NOAA through the US Department of Commerce has violated the public trust by mismanaging
the public’s fishery resources and withholding critical imagery that can illustrate the magnitudeof the Global Warming Problem to the American people. NOAA Fisheries should be abandoned
as an agency that serves the American people, and replaced with an agency that cares more
about America’s national security than exploiting our vital marine fishery.
It is time to show the public the satellite images that illustrate global warming patterns so that
the American people can visualize the problem for themselves. The American people arecapable of responding to the challenge and work effectively with government to reduce theamount of carbon dioxide entering the atmosphere that could end our existence here on Earth.
Robert Rohde
Retired - USDA District Conservationist
Cc:

Jared Huffman
Dianne FeinsteinPublic comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

School for the Environment
University of Massachusetts Boston
100 Morrissey Blvd
Boston, MA 02125-3393

Dr Michael Tlusty
Associate Professor-Sustainability and Food Solutions
Graduate Program Director

March 16, 2023
To NOAA Fisheries:
Thank you for the opportunity to comment on the NOAA Fisheries Draft National Seafood Strategy. I
appreciate the effort you take to include the public in drafting this most important national strategy. My
comments are listed below. I have copied each point as on the draft, and provide both a comment, as
well as a suggested edit.
1. The U.S. seafood industry is facing unprecedented challenges.
Comment: This box is a passive approach to challenges and should be solutions focused.
Suggested edit: The U.S. seafood industry can innovate solutions in the face of unprecedented
challenges.
2. Climate change is rapidly altering species location, size, and composition. It is also intensifying storms
and impacts on infrastructure.
Comment: change this to focus on solutions.
Suggested edit: Climate change and intensifying storms are rapidly altering both species biology
and infrastructure challenges. Adaptive management and scenario modelling can predict best
future opportunities.
3. The coronavirus pandemic disrupted markets and trade, decreasing the economic viability of theseafood industry and limiting access to some seafood.
Comment: need to turn into an opportunity
Suggested edit: The coronavirus pandemic greatly disrupted markets and trade, while future
proofing links between domestic producers and markets can overcome this burden
4. New technologies and other ocean uses, such as offshore wind energy, will affect use of ocean spaceand potentially result in conflicts.
Comment: these new uses do not have to automatically result in conflict.
Suggested edit: New technologies and other ocean uses, such as offshore wind energy, will add
to blue economic solutions, and adaptive siting and management can ensure needs of all users
are met.
5. Significant labor shortages plus aging harvesting, processing, and distribution infrastructure affectproduction, safety, and cost effectiveness in the industry.
Comment: This is a given,

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Suggested edit: Significant labor shortages plus aging harvesting, processing, and distribution
infrastructure limit production, safety, and cost effectiveness and can be overcome by a strong
local innovation.
6. NOAA Fisheries’ National Seafood Strategy supports the growing importance of seafood in meeting
global needs
Comment: seafood is a known important component of food systems, and needs should be
identified
Suggested edit: NOAA Fisheries’ National Seafood Strategy supports the continued importanceof seafood in meeting global nutritional and food security needs
7. It is also critical to providing food to a growing global population.
Comment: it does more than just provide food
Suggested edit: It is also critical to providing food security and sovereignty to a growing global
population
8. To implement the Seafood Strategy, NOAA Fisheries will partner with state and other federal
agencies, the National Sea Grant College Program, Tribes, non-government organizations, fishermen,
seafood farmers, and other stakeholders to address the challenges facing the seafood sector, especiallywhen resources are limited.
Comment: This is getting to be an extensive list, and the question should it be short and efficientor longer and inclusive. I have edited it to be longer and inclusive, as it seems it is only missing
academia, consumers, and the broader public.
Suggested edit: To implement the Seafood Strategy, NOAA Fisheries will partner with state andother federal agencies, the National Sea Grant College Program, Tribes, academia, nongovernment organizations, fishermen, seafood farmers, consumers, and the broader public toaddress the challenges facing the seafood sector, especially when resources are limited.
9. GOAL 1: Sustain or increase sustainable U.S. wild capture production
Comment: “Sustain or increase” makes it seem that it is one or the other -it should be both. Also
sustain sustainable is a bit awkward. Earlier seafood is referred to as resilient, that word works
better here.
Suggested edit: GOAL 1: Sustain and increase resilient U.S. wild capture production
10. Fisheries Management. Maximize fishing opportunities and sustainable seafoodComment: Maximization of opportunity leads to harvest overshoot down from the optimallevel. Optimization is a better word use in this case.
Suggested edit: Fisheries Management. Optimize fishing opportunities and sustainable seafood

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

11. Supporting gradual, diverse, and regionally-appropriate growth of the domestic industry
Comment:. If regulations are sound, it does not preclude gradual growth. I would strike the term
gradual.
Suggested edit: Supporting diverse, and regionally-appropriate growth of the domestic industry
12. GOAL 3: Foster access to domestic and global markets for the U.S. seafood industry
Comment: At SENA, US fisheries were discussing the lack of access to domestic markets, so theysold internationally. This section should be about prioritizing access to US markets. All downstream issues (overfishing, IUU etc) stem largely from imports.
Suggested edit: GOAL 3: Prioritize domestic markets and foster access to global trade for the
U.S. seafood industry
13. Fair Trade. Promote fair seafood trade by combating IUU fishing and related harmful fishingpractices around the world and by expanding access to foreign markets for U.S. seafood.
Comment: Fair trade carries the connotation of a benefits to a community while IUU includes
both a social and ecological aspect (indentured workers and overfishing).
Suggested edit: Legal Trade. Promote fair, responsible, and equitable seafood trade bycombating IUU fishing and related harmful fishing practices around the world and by expanding
access to foreign markets for U.S. seafood.
14. Seafood as a Vital Part of the Blue Economy. Support the U.S. commercial fishing, marine
aquaculture, and seafood communities to adapt and thrive in a changing ocean economy and given newcompeting uses.
Comment: The “and given new competing uses” is awkward. Also need to include solutionsbased language.
Suggested edit: Seafood as a Vital Part of the Blue Economy. Support the U.S. commercial
fishing, marine aquaculture, and seafood communities to adapt and thrive in a changing ocean
economy and integrate with new ocean economies.

If you have further questions or require additional clarification, please contact me atSincerely,

Michael Tlusty, PhD

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Worldwide Office4245 North Fairfax Drive
Suite 100
Arlington, Virginia 22203-1606

MAIN TEL
MAIN FAX(703) 841-5300(703) 841-1283

nature.org

March 30, 2023

Janet Coit
Assistant Administrator
NOAA Fisheries
1315 East-West Highway
Silver Spring, MD 20910
Assistant Administrator Coit,
Please accept The Nature Conservancy’s (TNC) comments on NOAA Fisheries’ Draft National
Seafood Strategy (Draft Strategy). TNC is a non-profit organization whose mission is to conserve
the lands and waters on which all life depends. We are known for our science-based,collaborative approach to developing creative solutions to conservation challenges. Our on-theground and in-the-water conservation work is carried out across the states and territories of
the United States and in 79 countries around the world. This work is supported by more than
one million individual members. TNC shares many goals with NOAA Fisheries. Our organizations
have partnered on many science and management initiatives through cooperative agreements
and service on various agency advisory bodies. The cooperative efforts have designed andimplemented new technologies to enhance fisheries management and quantified theecosystem benefits of various habitats. While significant progress has been made, TNC
recognizes the critical and increasing need to improve and enhance science and management
capabilities in a changing climate.
Value of Vision
We appreciate NOAA Fisheries articulating its vision for a thriving domestic U.S. seafood
economy and enhancing the resilience of the seafood sector in the face of climate change andother stressors. A public vision provides us all with a common understanding of what is driving
the agency’s actions and investments. Soliciting input from fisheries science and management
partners helps to make that a common vision and shape future collaborative efforts. It also
provides a basis for evaluating progress, assessing gaps, identifying resource needs, and shaping
additional actions.
Connectivity Within the Strategy
The Draft Strategy lays out four important goals. Each is outlined at a high level and discussed
separately. In reality, the rationales for the goals and work within each overlap. Directly
recognizing these connections would strengthen the strategy and set the stage for an
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implementation plan that better harnesses the strengths of NOAA Fisheries’ talented staff andmaximizes collaborative efforts. For example, Goal 4 notes how the COVID-19 market
disruption highlighted systemic challenges. These disruptions and challenges are similar to
those caused by damaging storms noted as a challenge affecting access to and production ofseafood and subsistence fishing in Goal 1.
Connectivity Across Strategies and Policies
Similarly, the Draft Strategy makes no mention of how it fits within the ecosystem of otheragency strategies and policies beyond acknowledging such other documents exist. We
appreciate recent efforts by NOAA Fisheries to develop an Equity and Environmental JusticeStrategy (EEJ Strategy) and to update the National Saltwater Recreational Fisheries Policy. They
each provide useful visions to drive agency actions and collaborations. We also appreciate thatthe agency is drafting the NOAA Consultation Handbook to guide its implementation of theWhite House Guidance for Federal Departments and Agencies on Indigenous Knowledge as wellas the White House Memorandum on Uniform Standards for Tribal Consultation. These
documents underscore the importance of incorporating Indigenous knowledge andmeaningfully addressing the United States’ unique trust relationship with federally recognized
Tribes uniformly across federal agencies. There are issues that overlap the strategies andpolicies and it is not clear when reading each individually how that overlap will be addressed.
For example, Goal 1 seeks to “maximize fishing opportunities and sustainable seafood
production while ensuring the sustainability of fisheries through effective and efficientmanagement.” How will this maximization goal be addressed in accordance with the equity
goals of the draft EEJ Strategy to meet the differing needs of communities, respect Tribal
rights, and provide for individual and community-based subsistence fisheries? How will it
address the needs of both recreational and commercial sectors? How will it address theecosystem interconnectedness of different fisheries within a region? How will Tribal
consultation – and according feedback – be factored into this maximization goal?
Similarly, Goal 1 references challenges to subsistence and Tribal fishing but there is noreference to improving the incorporation of local and Indigenous knowledge into the agency’s
science enterprise. This was central to NOAA Fisheries’ Draft Equity and Environmental JusticeStrategy and its absence here is notable.
The issues within these strategies overlap. Articulating them separately without specificallyaddressing the relationship across strategies runs the risk of creating silos that fail toappropriately integrate science and management approaches. This could yield implementationplans that miss opportunities to address community needs, leverage expertise, andunnecessarily duplicate efforts.
Active Role
We appreciate that NOAA Fisheries values collaboration. The Draft Strategy would be improvedby articulating NOAA Fisheries’ active role in such collaborations and not using a framing thatmerely supports such work. For example, Goal 1 appropriately notes the need for fisheries
management to adapt to climate change and thrive in a changing ocean economy. However,2

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

the Draft Strategy positions NOAA Fisheries’ role in that work as supportive. This does notreflect NOAA Fisheries’ role in facilitating, encouraging, funding, and requiring action to address
climate change. This is a regular and growing part of NOAA Fisheries’ work. NOAA Fisheries
agreed with recommendations for improvements on these issues made by the Government
Accountability Office in its report Opportunities Exist to Enhance Climate Resilience. The charge
to innovate and accelerate this work is often noted by agency officials at meetings including of
the Council Coordination Committee and recent East Coast Scenario Planning sessions, and inbudget proposals. Additionally, the recently released Ocean Climate Action Plan (OCAP)
outlines a very active role for NOAA Fisheries to advance these efforts. The language in the newstrategy should better reflect NOAA Fisheries’ active role and responsibilities to advance thiswork.
Data Modernization

We appreciate that the Draft Strategy notes that advances in sampling technologies and data
modernization call for an evolution in science and management frameworks. However, Goal 1
does not articulate a vision for fisheries science that fully embraces data modernization andcould be read as expecting things to mostly continue as is. This runs counter to the discussions
during the Next Generation Data Acquisition Plan process about the need to innovate what
data is collected, how it is collected, and how it is managed.
The advancements in science to enhance management will not be fully successful without also
modernizing NOAA Fisheries data collection and data management. This foundational work will
enhance the quantity and quality of data used by communities to engage in fisheries
management and habitat conservation and restoration by facilitating better integration, more
timely utilization, and greater accessibility to the full suite of ecosystem data. Better, fasterdata will be critical to effective management in a changing climate.
Ocean Health

The OCAP emphasizes that “a healthy and resilient ocean is the foundation of climate action.”
We agree and we’d note that to have a healthy seafood sector we need to have a healthy
ocean. However, the Draft Strategy does not reflect this important foundation or how it will be
addressed. We recognize that the Draft Strategy was released before the OCAP and its
commitment that related public-facing documents will emphasize it and that members of the
Ocean Policy Committee will include a focus on ocean health and stewardship in all of theiractivities. We’d recommend that this be addressed as you finalize the Draft Strategy and be
fully incorporated into the activities of the subsequent implementation plan.
Inclusive Implementation Plan Process

The Draft Strategy provides a very high-level vision to guide the agency’s actions andinvestments. It is concise by design and meant to provide direction over time. An importantcomplement to this will be the anticipated development of an a more detailed implementation
plan. The Draft Strategy notes that it will be informed by public comment and advice frompartners. Putting the Draft Strategy out for comment will undoubtedly provide valuable
feedback for the agency about its high-level vision. We encourage you to provide for an
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inclusive public process – including regular, meaningful, and robust consultation with federallyrecognized Tribes and Alaska Native Corporations – as work on implementations plansproceeds.
Conclusion

Thank you for consideration of these comments on the NOAA Fisheries draft strategy. We lookforward to working with you as the agency continues to refine the draft strategy and develop
the implementation plan.
Sincerely,

Stephanie Bailenson
Water Policy Team Lead
The Nature Conservancy

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Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

NOAA Fisheries
Re: NOAA Fisheries Draft National Seafood Strategy
Submitted online via - NOAA Fisheries Draft National Seafood Strategy

The West Coast Pelagic Conservation Group (WCP) appreciates the opportunity to submit the following
comments on the NOAA Fisheries Draft National Seafood Strategy (Draft Strategy). WCP is composed ofcommercial fishermen and processors. Presently, WCP’s primary focus is a collaborative survey with theSouthwest Fisheries Science Center (SWFSC) utilizing a commercial vessel paired with the NOAA
research vessel FSV Reuben Lasker. Our members harvest, process, and market all major species of
seafood on the west coast and Alaska. Our processors service over one thousand fishermen and ourfishermen and processors employ over 3500 people. Our members have the five largest fish processing
plants from San Francisco to the Canadian Border and sell and distribute fresh and frozen seafood fromevery major west coast fishery across the U.S. and worldwide.
WCP hereby supports and incorporates by reference those written comments submitted to NOAA
Fisheries on the Draft Strategy, contributed by the Responsible Ocean Development Alliance (RODA) andthe Washington Dungeness Crab Fishermen’s Association (WDCFA) and additionally reference generaldata in the “NOAA technical memorandum NMFS-NE: 291 source document; “Synthesis of the Science
Report”1.
WCP is excited to see a draft NOAA Fisheries “draft for the National Seafood Strategy Plan2. (NOAA Plan)
We believe the timing to unveil this plan could not have been better. The US commercial fishing industry
is facing what a long-time Washington State Pacific Fishery Management Council member (PFMC)
publicly stated, in a PFMC meeting, to be the “biggest threat to commercial fishing I have seen in mycareer.” This statement was issued regarding Offshore Wind (OSW) development. As happy as we are to
see the NOAA Plan, we are as equally distressed to be in a pitched battle to preserve our legallyauthorized and purchased privileges under the Magnuson-Steven Conservation Plan, and other federal
and state fishery sustainable management plans. These are ranked as the best in the world.
We are in strong agreement with some of the strategic constructs of the NOAA Plan and quote several
examples to emphasize the argument to promote U.S. seafood and fishing.
Purpose:1
2

Fisheries and Offshore Wind Interactions: Synthesis of Science (noaa.gov)
Natl-Seafood-Strategy-Final-Draft-Public-Comment.pdf (noaa.gov)

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

The National Seafood Strategy outlines our direction for supporting a thriving domestic U.S. seafood
economy and enhancing the resilience of the seafood sector in the face of climate change and otherstressors.
• U.S. seafood continues to be produced sustainably.
• The U.S. seafood sector contributes to the nation’s climate-ready food production and tomeeting critical domestic nutritional needs• U.S. seafood production increases to support jobs, the economy, and the competitiveness of the
U.S. seafood sector.
Strategy Framework:“The National Seafood Strategy focuses on NOAA Fisheries’ work to sustainably manage marine fisheries
and produce seafood responsibly, based on sound science.”• GOAL 1: Sustain or increase sustainable U.S. wild capture production.
• GOAL 4: Strengthen the entire U.S. seafood sector.
WCP believes the above are laudable objectives and purposed as such could help promote U.S. Wild
Capture seafood. However, the following statement in the NOAA Plan is not worked out as forecast.
Seafood as a Vital Part of the Blue Economy. Support the U.S. commercial fishing, marine aquaculture,and seafood communities to adapt and thrive in a changing ocean economy and given new competinguses.
The above underlined language governed by the Bureau of Wind Energy Management (BOEM)
guidelines simply cannot work. Actually, none of the stated laudable NOAA Plan objectives and goals
that are in the NOAA Plan will be realized without changes to the planned development of OSW. OSW
plans have begun the destruction of all major commercial fishing, fishing industry infrastructure, and thefishing industry supply chain. The speed and extent of that destruction depends on the total number andlocale of all wind farms. What will be the OSW cumulative impacts to our fisheries? There are no plans
through the BOEM NEPA process to study cumulative impacts either to fishing or the California Current
Ecosystem (CCE). The CCE is one of the four most productive3 Eastern Boundary Upwelling Systems(EBUS) in the world.
The destructive results to fisheries which we believe will reduce US commercial fishing to buy direct
small-scale operations may pale in comparison to the impacts the removal of a portion of the winddriven energy that creates upwelling and promotes the hydrological dynamics for CCE ecosystemservices. Perhaps the largest impact will be phytoplankton and algae generation which is the foundation
for the entire CCE food-web. The CCE is one of the greatest carbon sequestration mechanisms 4 on theplanet. One only has to think of the outcomes to salmon on the Columbia River system after the dams
were constructed. CCE ecosystem functionality loss could make the Columbia River results appear to beof minor consequence.
The four major EBUS include the California Current off the west coast of North America, theHumboldt Current off western South America, the Iberian/Canary Current off northwest Africa,
and the Benguela Current off southwest Africa (Garcia-Reyes et al., 2015). These ecosystems are
extraordinarily productive when wind-driven upwelling infuses nutrients toward surface watersthat fuel phytoplankton bloom.
Frontiers | State of the California Current Ecosystem in 2021: Winter is coming? (frontiersin.org)
3

4

The Ocean Is Still Sucking Up Carbon—Maybe More Than We Think

The Ocean Is Still Sucking Up Carbon—Maybe More Than We Think - EosPublic comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

It is said BOEM is allowing some BOEM designed Programmatic Environmental Impact Statements(PEISs) in the New York Bight and the Gulf of Mexico. BOEM has refused to do any on the West Coast.
Nor are they willing to construct some experimental a small scale wind turbine farm to study thephysical impacts of the turbines and the reduction of wind-driven energy to ecosystem systems. It
should be noted that the PFMC and some E-NGO groups have recommended PEISs.
Recently a staff person for BOEM stated BOEM was not tasked to avoid fishery conflicts. Maybe they
were not tasked but people in the fishing industry have heard time and again from BOEM anddevelopers how they wish to work with the fishing industry to mitigate losses. After multiple discussions
with developers and BOEM is difficult to comprehend how mitigation could occur.
There can be no continuation of fisheries when important fishing areas are occupied by mammoth
turbines and suspended cables. Any reduction of harvest or loss of a fishery sector will be a threat tocontinuance of the processing plants. These plants have invested in multi-species portfolios for
economic and employment stability. Loss of processors or processing capacity would impact the entire
supply chain including fishermen and markets.
Industrialization of the ocean will have multiple-dimensional impacts; in the atmosphere, on the ocean
surface, in the water column, and on the seafloor. There is little credible ecosystem services orsocioeconomic research and no planned EIS’s until the construction is ready to begin. Leases are sold atfull value early in the BOEM development process and the money is not refundable. Not doing an EIS
after leasing and money exchange is thought by the fishing industry to be business allowance of apredetermined outcome. No leases have been rescinded to date, and the EISs we have seen sidestep
meaningful study of both socioeconomic and ecosystem impacts. In short, the BOEM environmental
review process is a travesty with a “lease first, ask limited questions later” mandate.
Nothing in the BOEM or OSW process measures the world need for food or US food security, and therole seafood can play in staving off a dearth of sufficient food supply and inadequate nutritional intake.
Covid demonstrated that food supply chains are not inviolate. UN estimates predict a much greater foodshortage in the near future. OSW will eliminate a sustainable, highly nutritious, low-carbon food supply
if we allow OSW to continue the present path it is on.
In addition to the above we will also state that there does not seem to be a plan or analysis as to thetransmission of OSW or the cost of the electricity at the point of sale.
We believe what we have stated is within the boundaries of what most of the fishing community has
experienced and believes true. We can’t successfully run fishing businesses if it is impossible to harvest
the resources.
Solution:
1. Experimental windfarms backed by more on-the-water research.
2. Extensive computer modeling of OSW impacts to ecosystem services and the entire food web
including ESA listed and MMPA protected species.
3. Cement these together with clinical analytic study s be a mandate before we go any farther in
OSW development.

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

What we have instead is stone age, witch doctor medicine. The OSW “cure” for climate change may
be worse than the “disease”. We know if this convoluted process it isn’t restructured before we go
farther we are likely to go through another Columbia River experience.
This has been a short comment of The NOAA Seafood Strategy. We hope NOAA Fisheries can bring someof our concerns forward at a high level and we can begin the dialogue to reshape this process rather
have it dictated to our fishing communities. The price to get this wrong is too high and the present data
too sketchy not to reevaluate the present path we have been forced to go down.
Thank you,
Sincerely.

Mike Okoniewski, Fisheries Consultant & Secretary West Coast Pelagic Conservation Group
C.c. Greg Shaughnessy, COO Ocean Gold Seafood and VP West Coast Pelagic Conservation Group-Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

West Coast Seafood Processors Association
P.O. Box 1127
Astoria, OR 97103(503) 227-5076

March 31, 2023
NOAA Fisheries
1315 East-West Highway
Silver Spring, MD 20910
Submitted online via – NOAA Fisheries Draft National Seafood Strategy
RE: Draft National Seafood Strategy – WCSPA Comments
To Whom It May Concern:
On behalf of the West Coast Seafood Processors Association (WCSPA), I submit the following
comments on NOAA’s Draft National Seafood Strategy. WCSPA represents shoreside seafood
processing companies and related businesses located in California, Oregon, Washington, andAlaska. Our member companies also have plants and seafood distribution facilities in Texas, Hawaii,
Nevada, Utah, Arizona, and Florida. WCSPA members process the majority of Pacific hake (whiting)and non-whiting groundfish (rockfish, sole, sablefish) landed on the U.S. West Coast, in addition to
Dungeness crab, pink shrimp, salmon, albacore tuna, and other important commercial species.
WCSPA processing companies range from “mom and pop” operations to some of the largest
seafood companies in the United States, employing thousands of workers in harvesting, processing,transporting, and distributing seafood across the country and throughout the world. We are
essential workers, we are food producers, and we contribute greatly to our Nation’s food security.
WCSPA appreciates the opportunity to submit comments on NOAA’s Draft National Seafood
Strategy. In addition to the comments provided below, WCSPA signed a letter written by the
Responsible Offshore Development Alliance (RODA) and submitted as part of the record ofcomments on the Draft National Seafood Strategy. The comments and recommendations provided
herein are intended to supplement the comments submitted in the RODA letter and offer
perspectives more unique to U.S. seafood processors.
General Comments
U.S. wild capture commercial fisheries are managed to ensure sustainability and adhere to all
National Standards set forth in the Magnuson-Stevens Fisheries Conservation and Management Act(MSA). Fisheries management follows strict laws for sustaining stocks, conserving biodiversity(protecting habitat, marine mammals, and endangered species), and protecting the Nation’s living
marine resources. Moreover, robust U.S. laws mandate that fisheries and seafood production
follow workplace safety and protection rules, that seafood is safe for consumers to eat, and thatassociated environmental impacts are minimized and mitigated (such as with clean water).
Companies utilize internal controls and audits, backed by third-party verification, to maintainproduct traceability and integrity of their supply chains. For all of these reasons, successfully
implementing the National Seafood Strategy will require NOAA Fisheries to explicitly

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acknowledge the outstanding merits of the U.S. fishing and seafood industry and defend ourindustry against unwarranted threats.
Fishermen and seafood processors not only face changing environments, global supply chain
vulnerabilities, and potential loss of access to fisheries, but they must also contend with increasing
regulatory costs and burdens that threaten their viability and competitiveness with other nations.
NOAA Fisheries should include action items to address and counter these threats and stressors
when implementing the National Seafood Strategy.
We support NOAA’s vision outlined in the Draft Seafood Strategy and NOAA’s intent to enhance theresilience of the seafood sector in the face of climate change and other stressors. The fishingindustry is on the front lines of the climate change crisis, and U.S. reliance on imported seafood hascome at a climate cost. However, it is clear that the most significant threat the fishing and seafoodindustry faces is offshore wind development and its potential to produce devastating impacts on
fisheries, fishing communities, and fisheries ecosystems. We feel strongly that NOAA must more
explicitly identify and address the threat of offshore wind development to the fishing/seafoodindustry in its National Seafood Strategy.
The Draft Seafood Strategy is incorrect when it suggests that offshore wind will “potentially result in
conflicts.” Offshore wind, and other potential new ocean uses, will result in significant conflicts for
the U.S. seafood industry. NOAA’s Seafood Strategy must acknowledge this reality and establish
clear action items to protect the U.S. fishing/seafood industry and strengthen our ability to provide
nutritious food for the Nation. The Seafood Strategy should also strive to ensure that our sciencedriven fisheries management process is not compromised. We acknowledge and appreciate thework being conducted by NOAA’s National Centers for Coastal Ocean Science (NCCOS) in developinga spatial modeling tool that can help in identifying areas on the outer continental shelf potentiallysuitable for offshore renewable energy developments. However, in determining suitable sea spacefor offshore wind development, areas which are important to our commercial, recreational, tribaland subsistence fisheries should be deemed unsuitable for offshore wind development. NOAA
Fisheries should adopt and advance this position in the National Seafood Strategy.
Moreover, given some recent, significant marine mammal mortality events on the East Coast, we
remain extremely concerned that the impacts of offshore wind development on protected species
could become a major problem on the West Coast. Any negative impacts to West Coast humpback
distinct population segments (DPSs) will wreak havoc on West Coast fisheries. By way of example, in
May of 2022, NOAA sent a letter to the Bureau of Offshore Energy Management (BOEM) expressing
concerns about offshore wind siting on the East Coast and recommending that offshore wind sites
should be moved further offshore to protect migratory North Atlantic Right Whales, one of themost endangered large cetaceans and the focus of coastwide conservation efforts. To ourknowledge, BOEM never responded to NOAA’s letter.
Under Federal law, every ocean stakeholder group must work to protect conserve and protect
marine mammals, in some cases losing economic opportunities to do so, yet BOEM appears to havefree reign to build wind fields despite no clear understanding of the impacts of survey andconstruction activities on the marine environment. Once these large areas of our oceans areindustrialized and developed for offshore wind, it will be too late to remedy the damage.

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Concerns about the impacts of offshore wind development must be addressed as NOAA’s toppriority, and certainly to ensure any possibility of advancing the goals and objectives laid out in the
Draft Seafood Strategy.
Comments on the Seafood Strategy Framework
Goal 1: Sustain or Increase Sustainable U.S. Wild Capture Production
Fisheries Science. Federal fisheries surveys and resulting long-running datasets are integral to ourunderstanding of the marine environment (including impacts of climate change) and the foundation
for stock assessments which are the cornerstones of our fisheries management processes.
Disruptions to those surveys, or long-running datasets, result in less certainty for stock assessments
and other tools utilized in setting harvest guidelines for our fisheries. We strongly support NOAA’s
formal recognition of fisheries science as a top priority, given the need to increase and expand
surveys in a changing climate while facing increasing costs to do so.
NOAA’s National Seafood Strategy should identify and require specific commitments and actions
the Agency will undertake to better deliver this core function, including steps to ensure that
Federal fisheries surveys are conducted regularly and sustained. NOAA should explicitly include acommitment in the Seafood Strategy to increase scientific surveys to meet growing needs forecosystem and climate resilience.
Fisheries science must be a cornerstone of the National Seafood Strategy, and actions must be
identified to ensure its longevity and integrity. We are extremely concerned that the siting andlocation of offshore wind projects will interfere with NOAA’s scientific and research surveys, one of
the most critical elements of our fisheries management system. BOEM has not conducted any sortof Environmental Impact Statement (EIS) to examine the impacts of offshore wind development on
the West Coast marine environment, our critical upwelling ecosystems, and the migration of fishand marine mammals. The U.S. fishing and seafood industry is counting on NOAA to protect theenvironment as well as our access to healthy marine resources for U.S. consumers throughout theoffshore wind development process.
Fisheries Management. In the Seafood Strategy, we urge NOAA Fisheries to state how the Agency
will provide resources to support efforts to uphold the National Standards in the MSA, defend useof the best available science, and assist Regional Fishery Management Councils in the developmentof more flexible management actions to adapt to changing conditions.
The role of NOAA and impacts on industry and the marine environment from offshore winddevelopment are major concerns for the fishing/seafood industry on both coasts. NOAA is the lead
Agency for managing marine resources, and the impacts of offshore wind activities on thoseresources and on the stakeholders that depend on them are not well understood. Difficult as it may
be under the current regulatory and political framework, NOAA must firmly inject science andcommon sense into the currently-rushed approach to offshore wind energy development.

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Goal 2: Increase Sustainable U.S. Aquaculture Production
WCSPA recommends that the National Seafood Strategy: 1) clarify how NOAA will work with other
Agencies, the seafood industry, and other stakeholders to identify aquaculture’s impacts on marine
life and habitats and how negative impacts will be avoided; 2) address challenges created by new
ocean space allocation issues and changing environmental conditions; and 3) identify the impacts ofaquaculture development on existing seafood markets and include measures to proactively address
any conflicting interests of market sectors.
Goal 3: Foster Access to Domestic and Global Markets for the U.S. Seafood Industry
West Coast seafood producers face extraordinary challenges in the domestic and global
marketplace, including – among other things – tremendous trade uncertainty in recent years, thestrength of the dollar against most foreign currencies, and competition from low-cost seafood
producers from nations that are not subject to environmental safeguards and labor protections like
U.S. fisheries. In addition, joining these challenges is the sharp uphill battle recently created by the
COVID-19 global pandemic, including the near worldwide shutdown of the foodservice industry,
which generally accounts for a majority of seafood consumption, on top of the logistical difficulties
we currently face throughout the global supply chain.
Communication and Promotion. NOAA is well-positioned as an authoritative source of sciencebased and factual public outreach about the availability, sustainability, and nutritional value of
seafood harvested in the United States. The Seafood Strategy should include specific actions for
NOAA and NMFS to take to accomplish this goal, including investing in public outreach to bolster
consumer confidence in U.S. seafood and communicating the 2020-2025 U.S. Department ofAgriculture (USDA) Dietary Guidelines for Americans that support eating more seafood.
In the Seafood Strategy, NOAA should increase public and inter-Agency outreach on seafood’srole in meeting U.S. dietary needs. Towards this end, the Seafood Strategy should clearly articulate
how NOAA will improve upon existing government market support programs. NOAA should actively
partner with the USDA to provide more effective and timely support for its domestic foodmarketing and seafood purchase programs.
U.S. Market Development. As noted above, NOAA’s National Seafood Strategy must articulate
how NOAA will work effectively with the USDA and the seafood industry to communicate theoutstanding merits of seafood to U.S. consumers so domestic markets will further develop andprovide vital outlets for seafood producers. Toward this end, more seafood should be included in
the USDA’s National School Lunch Program (NSLP). The Seafood Strategy should also incorporate
regular input from domestic seafood producers so NOAA can better understand the domestic
market and related access challenges.
Fair Trade. While the volume of U.S. seafood produced from waters the West Coast and PacificNorthwest are large, it is a relatively small part of a global supply chain that encompasses large
volumes of competing wild and farmed species, many of which see comparatively small production
costs due to less stringent management and production efforts. The success of America’s fisheries
and seafood production systems, therefore, depends on the success of U.S. trade officials in
facilitating fair global seafood market access.

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Similar to the National Seafood Strategy, NOAA Fisheries should advance a National Trade Policy
for the seafood industry, through which NOAA Fisheries could work with the International Trade
Administration (ITA) and the Office of the United States Trade Representative (USTR) in designingand implementing a targeted plan for pursuing free and fair trade.
Illegal, Unreported and Unregulated (IUU) fishing degrades marine ecosystems, and forced labor isan affront to human decency. These practices in any part of global seafood production hurt
American producers by undercutting U.S.-harvested seafood in U.S. and global markets. Our
companies are held to high sustainability and other standards. Those standards should be more
broadly applied to fisheries around the world in ways that directly target bad actors and do not
impose undue burdens on lawful U.S. seafood trade.
WCSPA supports the National Seafood Strategy objective to combat IUU fishing. The Strategy
should include items that make full use of current authorities and programs to fight IUU fishing andexploitative labor practices worldwide, and in particular to leverage the cross-sector collaborationand governmental coordination functions called for in the Maritime SAFE Act. Current authorities
also allow agencies to address cases of domestic seafood fraud, and the Plan should ensure these
foreign IUU fishing and fraud enforcement programs are fully resourced. WCSPA recognizes thatNOAA Fisheries faces pressure to do more domestically to combat foreign IUU fishing, such as
expanding the Seafood Import Monitoring Program (SIMP). If the National Seafood Strategy
addresses SIMP, WCSPA strongly recommends that it remain focused on only a few of the highestrisk categories. Given its administrative complexity, high costs, risks to lawful seafood trade, andlack of effectiveness in identifying IUU fish, we strongly oppose expanding SIMP.
Goal 4: Strengthen the Entire U.S. Seafood Sector
WCSPA supports this goal and emphasizes the need to integrate the National Seafood Strategy
with the Federal government’s strategy for enhancing food security and creating resilient foodsupply chains.
Seafood as a Vital Part of the Blue Economy. NOAA’s Seafood Strategy must explain, in detail, how
NOAA will invest in and help fishing and seafood-dependent communities “thrive” as competinguses for ocean space increase and erode access to sustainable fisheries. Specifically, the Seafood
Strategy must explain how NOAA will bolster fishing community support and promote access tosustainable fishing, based on fully articulated values of seafood-based economies, while other
Federal Agencies like BOEM seek to develop offshore industries with little to no assessment andconsideration of impacts to fisheries and marine ecosystems.
The Seafood Strategy should state that before actions are taken to displace fisheries from ocean
space, NOAA and other agencies managing the action (i.e., BOEM) must proactively identify the fullrange of economic impacts (e.g., losses to jobs, income, reinvestment, tax revenue, etc.) andcommit to avoid and mitigate those impacts.
In addition, the Seafood Strategy should state how NOAA can help drive government investment toBlue Economy communities in the form of technologies, infrastructure, and market access, thereby
increasing their long-term ability to compete in seafood markets.

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Seafood Infrastructure. WCSPA supports the objective of modernizing U.S. seafood infrastructureand supply chain components to advance the resilience of fishing and seafood communities andregional food economies. In the Seafood Strategy, NOAA should identify every opportunity tobetter understand the U.S. seafood supply chain – from harvest to consumer – and work with thefishing/seafood industry to identify infrastructure needs at the local level. NOAA can then best
understand how to use its authorities and/or work with states and partner agencies to increasetechnical assistance and direct grant programs for vessel modernization and recapitalization, port
facilities, processing and storage facilities, and programs for modernizing seafood storage andshipment.
To support resilient coastal communities, WCSPA urges NOAA to include specific items in the
Seafood Strategy advancing partnerships with coastal communities to improve resilience andfortification for coasts and coastal infrastructure. In addition, we recommend NOAA focus on theinfrastructure capacity and modernization needs of seafood-dependent communities, particularly
those in rural locations. We recommend close consultation with local fishermen, seafood
processors, and community leadership to identify priority community resilience and infrastructure
projects.
Workforce Development. WCSPA strongly supports this objective. The best way to attractcommercial fishermen and seafood producers is to clearly facilitate economic success and further
signal to the national economy that domestic seafood is a national priority.
The Seafood Strategy should state how NOAA Fisheries will help minimize industry cost, burden,
risk, and uncertainty – and how it will help ensure that seafood jobs are in demand, pay well, andattract investments. It should explain how NOAA will work collaboratively with other agencies,
educators, and seafood employers to expand workforce development, training, and extension
programs, which are needed to instill valuable and unique fishing and seafood processing skillsets.
Toward this end, we recommend NOAA Fisheries work with the USDA to enhance supply chainsfor seafood production. By way of example, the USDA Rural Development administers a Meat andPoultry Processing Expansion Program (MPPEP) to provide grants to help eligible processors expand
their capacity. USDA Rural Development designed the MPPEP to encourage competition andsustainable growth in the U.S. meat processing sector, and to help improve supply chain resiliency.
A similar grant program for seafood processors would help strengthen the entire U.S. seafood
sector and enhance opportunities for coastal seafood communities and regional food economies.
As lack of workforce continues to be one of the major issues plaguing the seafood processing
industry, automated fish processing machinery is needed to supplement lack of hand filleters while
increasing throughput, but often requires multimillion dollar investments that are often
unattainable. Funds to support seafood processors could be used to offset significant capital
expenditures on cutting edge fish processing machinery.

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Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

Thank you for the opportunity to provide comments on the Draft National Seafood Strategy.
Ultimately, it remains incumbent on NOAA Fisheries to lead and effectively partner with many otheragencies to implement this Strategy through an interagency approach, with NOAA Fisheries at thehelm. We look forward to the opportunity to work with NOAA Fisheries to implement the National
Seafood Strategy.
Sincerely,

Lori Steele
Executive Director

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WASHINGTON DUNGENESS CRAB FISHERMEN’S ASSOCIATION

P.O. Box 2678, Westport, WA 98595

March 31, 2023
RE: NOAA Fisheries Draft National Seafood Strategy
My name is Larry Thevik I am the President of the Washington Dungeness CrabFishermen's Association, (WDCFA), headquartered in Westport, Washington.
The Dungeness crab fishery is sustainable and is the most valuable single species
fishery on the West Coast. The Dungeness crab fishery is the lifeblood of coastal
fishing communities coast wide.
WDCFA incorporates by reference the comments of RODA (Responsible Offshore
Development Alliance) in a letter dated March 31, 2023 on NOAA Fisheries Draft
Seafood Strategy. The RODA letter is thoughtful, thorough and the subject matterdiscussions and policy statements are applauded and echoed by WDCFA.
The subject matter discussion on new technologies and potential industrialized
alternative use of ocean space in the RODA letter, and more broadly, is especiallyconcerning to WDCFA. Alternative use of Ocean Space that would carry broad
negative impacts on fisheries displacement, ocean health and resources is afoundational constraint to a successful and robust seafood strategy.
Beyond displacement of fisheries and consequent negative socio economic impacts
by proposed Floating Off Shore Wind projects (FOSW), off of the West Coast thepotential for cumulative negative impacts on marine species, resources, oceanhydrology, ecosystem effects, especially on the dynamics of ocean health andproductivity, are barely understood or been seriously examined and/or studied by
BOEM. There is no question that use conflicts and cumulative ecosystem effects
and impacts will be consequences of FOSW projects and will carry even greater
impact from multiple FOSW projects developed along the entire west coast. Whatis less known is how large and how far reaching those impacts will be? A seafood

Public comments on NOAA Fisheries draft National Seafood Strategy received during public comment period: 2/14/23-3/31/23.

strategy to strengthen the seafood industry that does not include a thoroughanalysis of those potential impacts is bound to fall far short of professed goal..
It is now known and partially modeled that large turbine arrays will have effects on
ocean hydrodynamics. It is not known what ecosystem effects may follow. There
are no existing FOSW projects or experience with projects of scales proposed andpotential impacts anywhere off of America's coasts or worldwide. Unintended
negative consequences of human endeavors not well thought are numerous and weneed look no further than the long-term unforeseen negative impacts from
Colombia River hydroelectric projects on iconic Pacific Northwest Salmon
populations for proof of that.
Specific to the Dungeness crab fishery, in addition to socio-economic effects ofpotential displacement of the fishery from FOSW, there are several other concerns.
The potential effects of EMF (Electro Magnetic Field) from transmission cables
on benthic species including shellfish behavior is not well known. There areconflicting reports on effects.
Some reports indicate significant behavior
modification to adult male Brown crab off of Scotland. Other species and forage
may be affected by suspended cables. A better understanding of EMF effects
seems an obvious need before industrializing and crisscrossing ocean and benthic
space with power transmission cables at scales proposed. If Marine mammal
migration is altered by individual or repeated projects, migrating mammals
including ESA listed populations may alter course and lead to increased
cooccurance with crab gear, potential increased entanglements and consequent
added spatial and time constraints on the crab fishery. Of a more foundational
concern: What will the cumulative effects of multiple FOSW build outs be on
ocean currents and the dependence on shoreward movement from ocean currents
for the pelagic larval and megalope stage of the Dungeness Crab life cycle? Crabs
at this stage depend on current transport to shallower waters to survive in the earlystages of Dungeness crab development.
There is a complex crossover between effects and response to climate change,
warming waters, harvest access, marketability, resource viability and increasing
Harmful Algal Blooms (HABs) and consequent biotoxin events and impacts fromhypoxia. There is an increasing need to understand the dynamics and provide
response to interruptions to fisheries seasonality and activity from these events.
Under Goal 4 in the strategy "Strengthen the entire US seafood sector" the strategy
must recognize the potential vulnerability of many domestic fisheries to theimpacts from these episodic but significant sector destabilizing natural events.
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resources to respond to these events and "Strengthen" ability to survive these
events should be recognized as a need in the Strategy. Additionally a reexamination of NOAA's definition of fishery failures, policies, and processes toprovide more immediate and effective fishery disaster relief would help
"Strengthen" the strategy and help fishers survive such events to "fish anotherday".
Similarly the impacts, and potential impacts from invasive species such as Green
crab warrant mention as vulnerabilities to a successful fisheries strategy andwarrant additional scrutiny and resources to prevent "weakening" seafood industry
resilience strategies for affected fishing sectors.
WDCFA appreciates the opportunity to comment on the Draft National Seafood
Strategy and asks that our comments be reviewed and considered along with
RODA's expressed concerns in additional refinements to the Strategy.
Respectfully,
Larry Thevik
Washington Dungeness Crab Fishermen's Association WDCFA