ADF&G Releases Second Disaster Relief Draft Spend Plan with Changes to Eligibility Criteria and Payment Tiers

ADF&G RELEASES SECOND DISASTER RELIEF DRAFT SPEND PLAN WITH

CHANGES TO ELIGIBILITY CRITERIA AND PAYMENT TIERS

On November 9, 2020, the Alaska Department of Fish and Game (ADF&G) released

its second “Section 12005 CARES Act Relief for Fisheries Participants Second Draft

Spend Plan” which will distribute $49 million in fisheries disaster relief funds to

eligible participants from the commercial fishing, seafood processing, charter fishing,

aquaculture and subsistence sectors. ADF&G’s second draft spend plan allocates

over a quarter of the funds – 27 percent - to the charter sector. Commercial fishing

vessel owners who are not processors will receive 35 percent of the allocation.

Seafood processors, including numerous commercial fishing vessels that freeze,

participate in dive fisheries or direct market their catch, will receive 32 percent of the

disaster relief funds.

The second draft spend plan makes some changes to the October draft spend plan

which include an extended time period for calculating revenue declines, eligibility for

a small number of commercial fishermen who reside in states outside of Alaska, and

changes to the tiered payment system. Eligible commercial fishermen must have one

of the following permits or licenses: (1) a 2020 CFEC commercial vessel license; (2) a

2020 CFEC Commercial fishing permit; (3) a 2020 NOAA Fisheries License Limitation

Permit; (4) a 2020 NOAA fisheries IFQ permit and/or (5) NOAA fisheries crab

rationalization IFQ permit. Eligible applicants will receive 1 share per permit.

Payment amounts are unknown until all applications are received and the total

number of shares counted to determine the value of a single share.

Eligible applicants must have fished in 2018 and 2019 and must certify that they

have experience a greater than 35% loss in fishery revenue from January 1, 2020 to

November 30, 2020 as a direct or indirect result of COVID-19 relative to average

gross fishing revenue the past five years for same time period. Those applicants who

did not fish all five years can use average gross revenue for their years in operation.

Applicants must also certify that if they received other pandemic related aid,

including unemployment, grants, or loans that won’t be repaid, the sum of fishery

revenue + pandemic aid (not including loans to be repaid) must not exceed average

annual revenue from 2015 to 2019. Self-certification will be sufficient to verify the

losses, but applicants must attest that they have and will retain records documenting

the losses.

One of the changes to eligibility requirements is that commercial fishermen who are

residents of other states may apply, but only if they have a business license issued by

Alaska Department of Commerce, Community and Economic Development. It is

unclear if this change will help non-resident commercial fishermen. In June, the

state of Alaska excluded most commercial fishermen from the Alaska Cares Act

grant program by requiring a state business license. Alaska exempts most

commercial fisheries businesses from the state business license requirement. As a

result, most commercial fishermen were not eligible for the AK CARES grants until

the state expanded program eligibility in August.

Many commercial fishermen, including freezer vessels, many dive operations, direct

marketers and some tender vessels will apply for relief funds allocated to the

processing sector. Processors must hold a 2020 processing permit issued by Alaska

Department of Environmental Conservation and processing vessels must be

homeported in AK. Eligible processors must have a minimum average annual

wholesale value revenue of $30,000 from 2015-2019. The spend plan establishes

seven tiers based on average wholesale revenues to determine payment amounts.

For example, processors with revenues between $30,000 and $75,000 receive one

share, and processors with revenues between $75,000 and $500,000 receive 2

shares. At the top end of the scale, processors with larger revenues of between $20

million and $50 million would receive 6 shares, and processors with revenues above

$50 million would receive 7 shares.

The second draft plan is available at:

https://www.adfg.alaska.gov/static/home/news/hottopics/pdfs/cares_act_spending

plan_110920.pdf

ADF&G is allowing a public comment period through 5:00 p.m. November 15, 2020.

Fishermen can send comments to dfg.com.caresact@alasak.gov.

ADF&G's Second Spend Plan Maintains Disproportionate Allocation of CARES Act Fishery Relief Funds to Charter Sector

ADF&G’S SECOND SPEND PLAN MAINTAINS DISPROPORTIONATE ALLOCATION OF CARES ACT FISHERY RELIEF FUNDS TO CHARTER SECTOR

On November 9, 2020, the Alaska Department of Fish and Game (ADF&G) released its second “Section 12005 CARES Act Relief for Fisheries Participants Second Draft Spend Plan” which will distribute $49 million in fisheries disaster relief funds to eligible participants from the commercial fishing, seafood processing, charter fishing, aquaculture and subsistence sectors.  ADF&G’s second draft spend plan allocates over a quarter of the funds – 27 percent ($13.2 million) - to the charter sector. Commercial fishing vessel owners who are not processors will receive 35 percent ($17.2 million) of the allocation. The seafood processing sector, which includes both shore-based processors and numerous commercial fishing vessels with processing permits that freeze, participate in dive fisheries or direct market their catch, will receive 32 percent ($15.7 million) of the disaster relief funds.  There are well over 500 seafood processors permitted in Alaska, and most of the permit holders are community-based commercial fishing vessels.  The spend plan allocates most of the remaining funds to the aquaculture and subsistence sectors while leaving an unexplained omission of $1 million from the plan.

ALFA and other fishery stakeholders have repeatedly requested that the Department use the approach of other major fishing states such as Massachusetts, which evaluated 2020 fishery market trends and other fishery data while developing its spend plan and allocated its funds by sector using NOAA Fisheries’ formula for distributing the CARES Act funds to each coastal fishing state. Other coastal state spend plans also attempted to allocate fishermen’s funds fairly by identifying the number of license holders and businesses in each sector. 

NOAA Fisheries allocated $50 million to Alaska based on multi-year revenue information from commercial and charter fishing sectors, aquaculture businesses, and processing/seafood sectors showing that nearly 60 percent of Alaska’s fishery revenue derived from seafood processors.  Commercial fishermen generated 35.2 percent of the state’s fishery revenue, and charter operators generated the remaining 5.5 percent.  ALFA requested that ADF&G should use these percentages as a primary basis for allocating disaster relief funds between the sectors.  

Instead, ADF&G’s spend plan explains that the agency increased the charter allocation to 27 percent to mitigate losses caused by travel restrictions and health mandates.  This approach deprives commercial fishermen who hold processor permits and shorebased processors from access to over $10 million in CARES Act relief funds allocated to Alaska’s processing sector under NOAA’s formula.  ADF&G ignores the fact that many Alaska-based processors have also incurred significant expenses in order to operate under the state’s health mandates and travel restrictions, and despite precautions, some have shut down due to COVID-19 outbreaks.  The ADF&G spend plan does not provide any explanation for the state’s assumption that the charter sector experienced more cumulative economic harm than commercial fisheries and seafood processors.

Alaska’s fisheries produce more seafood volume than all the other states combined - nearly 60 percent of all commercial fishery landings in the United States by volume, and one-third of the nation’s commercial fishery economic value.   The seafood industry is second only to oil and gas in terms of state jobs, making it important to utilize the limited funds in a way that fairly allocates relief.  ADF&G’s allocation does not reflect the relative importance of the seafood sector, which employs more workers than any other industry in Alaska.  Available data from the McDowell Group’s 2017 report, “The Economic Value of Alaska’s Seafood Industry” identify a total of 16,500 Alaska residents and 9,400 home-ported fishing vessels that, combined with non-resident fishermen, generated $1.7 billion in ex-vessel value in 2016.  The state’s seafood processing industry employs 26,500 Alaska residents and generated a wholesale value of $4.2 billion in 2016.  

In contrast, according to a 2019 NOAA Fisheries report measuring economic contributions from the charter fishing sector, “the saltwater recreational charter fishing sector is small relative to the commercial seafood sector,” contributing a total economic output of $166 million, or 4 percent of the $4.4 billion total fishery economic output to Alaska’s economy.  Most saltwater charter businesses are concentrated in portions of Southeast and Southcentral Alaska.  This means that funds which would otherwise provide relief to processors and the numerous commercial fishing vessels with processor permits that operate in rural coastal fishing communities throughout the state will instead accrue to charter businesses concentrated in just a few communities – or even to residents of other states. 

ADF&G’s initial draft spend plan allowed charter operators residing in other states to apply for relief funds but excluded non-resident commercial fishermen.  The second plan now allows commercial fishermen who are residents of other states to apply, but only if they have a business license issued by Alaska Department of Commerce, Community and Economic Development (DCCED).  Alaska exempts most commercial fishing businesses from the DCCED business license requirement.  As a result, the second plan effectively excludes non-resident commercial fishermen from the program – but includes non-resident charter businesses.

Most major coastal fishing state spend plans reflected an evaluation of data showing the relative economic contributions of the sectors or the number of affected businesses and workers.  Their spend plans evaluated changes in the ex-vessel values of their fisheries and compiled data identifying of the total number of eligible participants by sector.  But Alaska’s spend plan uses hypothetical examples based on “back of the napkin math” to illustrate how the state will calculate direct payments rather than using readily available data to assess the number of total shares or estimate payment amounts.

ADF&G is allowing a public comment period through 5:00 p.m. November 15, 2020.  ALFA encourages commercial fishermen, processors and community members to comment on this unfair allocation.  The second draft plan is available at: https://www.adfg.alaska.gov/static/home/news/hottopics/pdfs/cares_act_spendingplan_110920.pdf 

Fishermen can send comments to dfg.com.caresact@alasak.gov.  

An updated summary of eligibility requirements and other spend plan components for fishermen and processors is available on ALFA’s COVID-19 page.   

Bycatch Becoming Massive Issue in BSAI and GOA: First Halibut, Now Sablefish, Soon Crab

November 6, 2020

Ten harvester groups from Alaska urged NOAA Fisheries Administrator Chris Oliver to consider “area closures, payback provisions, and even hard cap inseason closure authority ”to reduce the overharvest of sablefish bycatch in the Bering Sea and Gulf of Alaska.

For the second year in a row, the Bering Sea trawl fishery caught more sablefish as bycatch than their allocation allowed -- by 484% this year, after a 356% overage last year. Together, that amounts to over 11 million pounds in the last two years alone.

Peggy Parker
SeafoodNews.com
1-781-861-1441
peggyparker@urnerbarry.com

U.S. Department of Agriculture repeals Roadless Rule protections on Tongass National Forest

On October 29, 2020, the U.S. Department of Agriculture published its final rule exempting the Tongass National Forest from the 2001 Roadless Area Conservation Rule (“Roadless Rule”).  The State of Alaska petitioned the Forest Service to remove Roadless Rule protections in order to increase the amount of acreage available for old-growth clearcutting by two federal timber sale purchasers.  The two timber companies would like access to currently roadless areas so that they can clearcut some of the remaining stands of high volume old-growth forest from the southern portion of the Tongass National Forest.   

In order to supply these two companies, the Tongass National Forest timber sale program incurs a substantial net loss each year, as shown in a September 2020 report by Taxpayers for Common Sense.  Over the last five years, timber sale revenues averaged $590,000 per year.  In 2019, the timber sale program generated a loss of $16.1 million.  Over the past 40 years, the Tongass National Forest lost $1.7 billion, or $44 million per year on average.  Planned timber sale volumes could cost taxpayers nearly $190 million over the next five years. These costs combined with the agency’s raw log export economic model have caused concern that current forest management primarily benefits Chinese economic interests rather than that of local businesses.

The Department of Agriculture’s decision removes Roadless Rule protections for over 9 million inventoried roadless acres on the Tongass National Forest.  ALFA’s comments on the Roadless Rule DEIS explained that the exemption the Tongass National Forest from the 2001 will be a disaster for Southeast Alaska because the Roadless Rule currently protects many salmon producing watersheds from roadbuilding and industrial scale clearcutting.  The no-action alternative was the only option for sensibly and sustainably saving some salmon for subsistence, sport and commercial fishing.  Thousands of fishermen, southeast Alaska residents and other Americans provided individual comments on the Roadless Rule.  Nearly all commenters requested that the Forest Service take no action on the rulemaking and leave the Roadless Rule in place in the region.

The U.S. Department of Agriculture ignored public comments and expert comments from fisheries scientists who identified the physical and biological diversities of southeast Alaska’s salmon producing watersheds as “globally unique,” warranting comprehensive protections that assure no net loss of watershed condition.  The scientists explained that timber extraction activities, along with climate change, pose the greatest risks to salmon productivity.  Also, 21st century salmon science research shows that sustainable populations rely on a “portfolio effect” which requires available habitat across multiple areas and ecosystems to ensure diversity and buffer against ongoing shifts in watershed productivity.  In addition, new and effective, science-based standards are necessary to protect salmon in areas zoned for timber uses. 

The harvests of “forest fish” - pinks, sockeye and coho salmon during the summer of 2020 were some of the lowest in Southeast Alaska since Alaska became a state in 1959 and reflect recent trends that suggest serious population declines.  Long-term drought conditions and marine “heat waves” are likely contributors to the run failure.  There is increasing concern throughout Alaska that freshwater habitat conditions, particularly summer stream temperatures and low flows, may have a more significant role that initially thought in contributing to declines of Southeast Alaska salmon and salmon declines throughout the entire state, warranting more precautionary management of freshwater habitat.  However, the Forest Service believes that the warming climate will not affect salmon populations in Southeast Alaska for at least another two decades – in 2040.

There are no further opportunities for the public to comment on or object to the decision.  Many of ALFA’s members participate in multiple fisheries, including salmon fisheries that rely on Southeast Alaska’s forest fish.  During the second week of October, ALFA petitioned the Department of Agriculture to initiate a “Salmon Conservation Rulemaking” that requests a scientific review of existing standards for fish habitat and ALFA will continue to press the agency to correct existing deficiencies with the current Forest Plan.

Taking a Stand for the Tongass and Salmon

Below please find the petition from Alaska Longline Fishermen’s Association regarding salmon conservation rule making.

ALFA Petition for Salmon Conservation

Seafood Companies Sue Federal Government: Claim Trump Administration Plays Favorites with Tariff Relief Money

The Trump administration was taken to court on 21 October by three seafood-related companies that claim the federal government’s trade policies has harmed their businesses.

Texas-based Houston Seafood Company, LLC along with Gulf Marine Product Co., Inc. and Ningbo Trading Company, LLC, both based in Louisiana, filed the suit in the U.S. District Court for Southern Texas.

Read full article at Seafood Source:

https://www.seafoodsource.com/news/supply-trade/seafood-companies-sue-federal-government-claim-trump-administration-plays-favorites-with-tariff-relief-money?utm_source=marketo&utm_medium=email&utm_campaign=newsletter&utm_content=newsletter&mkt_tok=eyJpIjoiTXpOaE1XUXpZV1EzWTJOaiIsInQiOiJRWnB3THVmR3hJOXo5R21zNG9cL3JGeXQzSU40VVdLOGJONHFwUWpFamRKbjkxT0xialJwNkJUNDZPRG92ZHN4NUxkeXBBVTFBaXk0S2RJQVVvTUU4dVRwVGpKdjNZXC9EWEF1N3JWZktXNlB1SDRDeEdKZUpROXZ1VUVpZzFNTVpwIn0%3D

Why Fishermen Worry about Climate Change

https://www.fisheries.noaa.gov/feature-story/central-gulf-alaska-marine-heatwave-watch?utm_medium=email&utm_source=govdelivery

Sea surface temperatures (SST) in the Central Gulf of Alaska have remained in heatwave conditions (SST elevated above the 90th percentile for more than 5 consecutive days) since the 13th of  September. Overall the SST has oscillated in and out of heatwave conditions throughout the late Spring and Summer, and now into Fall. For the past 90 days there have been three periods with heatwave conditions (SST elevated above the 90th percentile for more than 5 consecutive days), July 14th through August 3rd and August 14th through August 30th, and September 13 through the present. In the short cooler periods between heatwave conditions in this time period the mean daily sea surface temperatures in the Central Gulf of Alaska continued to remain above the 1982-2012 mean.

Follow link above to read more, from NOAA.

Landslide Survey

A team of researchers, led by the Sitka Sound Science Center, are conducting a survey to ensure all Sitkans are adequately connected for improved community resilience. After the survey, they will share the anonymized findings with Sitka.

To take the survey or more information, follow link below.

https://bit.ly/SitkaLandslideNetwork

ADF&G Disaster Relief Spend Plan Allocates Disproportionate Share of Cares Act Funds to Charter Sector

On October 5, 2020, the Alaska Department of Fish and Game (ADF&G) released its “Section 12005 CARES Act Relief for Fisheries Participants Draft Spend Plan” which will distribute $50 million in fisheries disaster relief funds to eligible participants from the commercial fishing, seafood processing, charter fishing, aquaculture and subsistence sectors.  ADF&G’s draft spend plan allocates nearly a third of the funds – 32 percent - to the charter sector. Commercial fishing and seafood processing sectors will also each receive 32 percent of the disaster relief funds.

ALFA had requested that the Department use the approach of other major fishing states such as Massachusetts, which evaluated 2020 fishery market trends and other fishery data while developing its spend plan and allocated its funds by sector using NOAA Fisheries’ formula for distributing the CARES Act funds to each coastal fishing state. Other coastal state spend plans also attempted to allocate fishermen’s funds fairly by identifying the number of license holders and businesses in each sector. 

NOAA Fisheries allocated $50 million to Alaska based on multi-year revenue information from commercial and charter fishing sectors, aquaculture businesses, and processing/seafood sectors showing that nearly 60 percent of Alaska’s fishery revenue derived from seafood processors.  Commercial fishermen generated 35.2 percent of the state’s fishery revenue, and charter operators generated the remaining 5.5 percent.  ALFA requested that ADF&G should use these percentages as a primary basis for allocating disaster relief funds between the sectors.  

Instead, ADF&G’s spend plan explains that the agency increased the charter allocation to 32 percent to mitigate losses caused by travel restrictions and health mandates.  This approach diverts funding mostly from the seafood processing sector, which otherwise would have received $30 million in disaster relief funds instead of the $16 million allocated to the sector under the ADF&G plan. This approach ignores the fact that many Alaska-based processors have incurred significant expenses in order to operate under the state’s health mandates and travel restrictions, and despite precautions, some have shut down due to COVID-19 outbreaks.  Alaska processors support many resident workers and are essential for our fishermen and many have also experienced significant revenue declines.

Alaska’s fisheries produce more seafood volume than all the other states combined - nearly 60 percent of all commercial fishery landings in the United States by volume, and one-third of the nation’s commercial fishery economic value.   The seafood industry is second only to oil and gas in terms of state jobs, making it important to utilize the limited funds in a way that fairly allocates relief.  ADF&G’s allocation does not reflect the relative importance of the seafood sector, which employs more workers than any other industry in Alaska.  Available data from the McDowell Group’s 2017 report, “The Economic Value of Alaska’s Seafood Industry” identify a total of 16,500 Alaska residents and 9,400 home-ported fishing vessels that, combined with non-resident fishermen, generated $1.7 billion in ex-vessel value in 2016.  The state’s seafood processing industry employs 26,500 Alaska residents and generated a wholesale value of $4.2 billion in 2016.  

In contrast, according to a 2019 NOAA Fisheries report measuring economic contributions from the charter fishing sector, “the saltwater recreational charter fishing sector is small relative to the commercial seafood sector,” contributing a total economic output of $166 million, or 4 percent of the $4.4 billion total economic output to Alaska’s economy.  ADF&G management reports identify 686 active saltwater businesses, split evenly between Southeast and Southcentral Alaska, which employ roughly 1,222 guides.  This means that funds which would otherwise provide relief to processors in rural coastal fishing communities throughout the state will instead accrue to charter businesses concentrated in just a few communities.  According to the McDowell Group, seafood processing is an “economic foundation of many rural communities” employing 15% of rural workers and over 21,200 rural Alaska residents.

ADF&G’s spend plan differs from the approach of other major fishing states in that it does not provide any data showing the relative economic contributions of the sectors or the number of affected businesses and workers.  Most major coastal states evaluated changes in the ex-vessel values of their fisheries and compiled data identifying of the total number of eligible participants by sector to inform their spend plans.  The ADF&G spend plan also does not explain why ADF&G assumes that the charter sector experienced more cumulative economic harm than commercial fisheries and seafood processors. 

ADF&G is allowing a public comment period through 6:00 p.m. October 19, 2020.  ALFA encourages commercial fishermen, processors and community members to comment on this unfair allocation.  ADF&G’s press release and information for submitting comments is available here:

http://www.adfg.alaska.gov/index.cfm?adfg=pressreleases.pr&release=2020_10_05

 A summary of eligibility requirements and other spend plan components for fishermen and processors is available on ALFA’s COVID-19 page. 

State of Alaska releases dedicated CARES Act draft spend plan for public review

Below is ADFG's draft spend plan for the $50M for fisheries dedicated CARES money. Public comment is due October 19. 

Note that NOAA proposed allocating 5.5% of funds to the charter sector. ADFG proposes allocating 32% to the charter sector (including non-resident). This is an increase of $13.25M for the charter sector.

NOAA proposed allocating 59.3% to processors, dealers, wholesalers, and distributors. ADFG proposes allocating 32% to the seafood processing sector. 

ADFG proposes allocating 1% to aquaculture and 3% to subsistence. 

ALFA will be providing comments but we urge all members to also voice their concerns. 

Press release:  http://www.adfg.alaska.gov/index.cfm?adfg=pressreleases.pr&release=2020_10_05

NOAA Allocations (scroll down) https://www.fisheries.noaa.gov/feature-story/commerce-secretary-announces-allocation-300-million-cares-act-fundinghttp://www.adfg.alaska.gov/static/home/news/hottopics/pdfs/cares_act_spendingplan_100520.pdf

ADFG Draft Plan