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Glenn Merrill, Assistant Regional Administrator
Sustainable Fisheries Division, Alaska Region NMFS
P.O. Box 21668
Juneau, AK 99802-1668
Submitted via http://www.regulations.gov
NOAA-NMFS-2021-0074
Dear Mr. Merrill:
Thank you for the opportunity to comment on the Draft Environmental Impact Statement (DEIS) for a proposed amendment to the BSAI Groundfish FMP that would implement abundance-based management for halibut prohibited species catch (PSC) limits.1 I submit the following comments on behalf of The Boat Company and Alaska Longline Fishermen’s Association (ALFA). The Boat Company and ALFA both promote conservation while operating in and advocating for Southeast Alaska’s coastal fishing communities that significantly depend on access to the halibut resource for commercial fishing, sport fishing and subsistence.
ALFA is a commercial fishing organization that represents and advocates for community-based, small commercial fishing businesses. ALFA represents commercial fishing vessel owners, deckhands, and business members from nearly every community in southeast Alaska who participate in, or otherwise support and benefit from the commercial fishing economy.2 ALFA’s members have also historically participated in Bering Sea fisheries, including residents of Bering Sea communities. ALFA has received national and statewide recognition for its work to rebuild fish stocks, address food security in Alaska and beyond, improve fishery monitoring and to protect fish habitat and ensure the socio-economic viability of coastal communities.
The Boat Company operates multi-day conservation and wilderness tours in Southeast Alaska aboard its two larger vessels, the 145’ M/V Liseron and the 157’ M/V Mist Cove. Visitors on these vessels participate in a variety of activities as part of their visit that include environmental education, kayaking, hiking, beachcombing as well as sport fishing from smaller vessels. For many clients, the opportunity to fish for halibut is a highlight of their Alaska experience.
Submitted via Aqua.RegPlan@noaa.gov.
September 17, 2021
Kristine Cherry
Chair, Regulatory Efficiency Task Force
National Oceanic and Atmospheric
Administration 1315 East-West Highway, Room
14461
Silver Spring, MD 20910-3282
Re: Comments on A Strategic Plan to Enhance Regulatory Efficiency in Aquaculture, 86 FR 48973
Dear Ms. Cherry:
Please accept the following comments on behalf of the groups listed below regarding the National Science and Technology Council’s Committee on Environment’s Subcommittee on Aquaculture’s Regulatory Efficiency Task Force’s “A Strategic Plan to Enhance Regulatory Efficiency in Aquaculture” (“Report”).
Industrial ocean fish farming – also known as marine finfish or offshore aquaculture – is the mass cultivation of finned fish in marine waters, in net pens, pods, cages and other confinements. These are essentially floating feedlots in our ocean, which can have devastating environmental and socio-economic impacts. Other forms of aquaculture can also be destructive to habitat and water quality when poorly sited and scaled. We have been closely tracking – and are entirely opposed to – the current Administration’s dedication of significant resources and ongoing push to quickly and recklessly develop and expand potentially destructive and unnecessary forms of the aquaculture industry in the United States.
The Report reinforces our deep concerns with the government’s promotion of marine aquaculture in all its forms, without sufficient regard for the wide-ranging environmental, public health, and socio-economic impacts.
Because we are entirely opposed to open water marine finfish aquaculture, we urge you to cease all plans for expansion of this industry in United States’ waters, as enough money and resources have been frivolously expended on such endeavors for many years, even in the face of massive public opposition.
Before delving into comments regarding the details of the Report, further below, the following are general concerns about the task force’s stated focus and purpose.
We are concerned by the title of the document. Enhancing “regulatory efficiency” essentially means reducing transparency, and shortcutting adequate notice, comment, and review of policies related to aquaculture. This is troubling; the United States does not yet have a regular permitting plan for marine aquaculture, as it has been widely opposed and unpopular, and thus it has not been advanced through Congressional legislation nor agency regulations. Also, federal agencies lack specific authority to permit marine aquaculture. To be focused on “streamlining” permitting and approval processes for development and expansion of marine aquaculture is incredibly premature and irresponsible.
Another notable issue is the lack of discussion regarding matters such as climate change, and impacts especially for Black, Indigenous, People of Color (BIPOC) communities. There is no acknowledgment of how offshore marine aquaculture may harm or disrupt cultural and historic practices related to natural resources and wildlife, nor any discussion about how streamlining various processes might further skew the balance of power in food production away from rural, coastal, and indigenous communities, and toward corporatization.
Following are comments specific to matters in the Report:
I. The Report ignores the range of risks and impacts of offshore aquaculture in the United States.
The Report makes clear that the federal government’s current focus is on efficiency and streamlining for aquaculture industry participants, and vastly expanding the aquaculture industry in the United States without much consideration of other industries that could be negatively impacted. Indeed, the relevant stated charge of the task force was to “identify Federal agency and partner opportunities for 1) improving efficiencies in aquaculture permitting and authorization programs using existing Federal authorities...[and] 3) refining and disseminating tools for aquaculture regulatory management.”1 The task force’s very first goal and objective clearly expresses how the overarching goal is the expansion of aquaculture. Goal 1 is to “Improve Efficiencies in Aquaculture Permitting and Authorization Programs,” while Objective 1.1 is “Expand the range of aquaculture activities authorized under general permits and through programmatic consultations.”2 The task force is putting the cart before the horse, at significant risk to public health, the environment, and the economy, particularly for coastal and fishing communities.
What must come first – well before any policy streamlining – is an acknowledgement and thorough review of the socio-economic, public health, and environmental concerns associated with marine aquaculture generally, and open water marine finfish aquaculture more specifically. Yet, the Report ignores these important issues. Failure to include these critical aspects as part of building a national offshore aquaculture program renders the Report meaningless and essentially a promotional piece for marine aquaculture.
Globally, many countries with marine finfish aquaculture programs have suffered extensive
1 Report at i.
2 Id. at 5.
environmental, socio-economic, and public health problems associated with the industry. As detailed below, these impacts are varied and widespread, and often do not come to light until years after the damage has been done. The task force should heed the lessons learned in other
countries and commit to researching and preventing these types of harms prior to any commercial permitting of marine finfish aquaculture facilities in the United States, or discussion of streamlining for permitting and policies.
Marine finfish aquaculture routinely results in a massive number of farmed fish escapes that adversely affect wild fish stocks. In January 2020, 73,600 salmon escaped from a net pen during a storm in Mowi, Scotland, marking the third major escape in the area since October 2019.3 A series of storms in Norway resulted in approximately four million escaped fish in a single year.4 A November 2020 fire in Tasmania, Australia resulted in the escape of 50,000 salmon and an accident nine days later during a net-clearing operation caused the escape of another 130,000 fish.5 In a notorious August 2017 incident, an industrial net pen operation maintained by Cooke Aquaculture Pacific, LLC in Washington state failed and allowed for what was originally reported as 160,000, but later found to be approximately 300,000, farmed Atlantic salmon to escape into Puget Sound. Long after the escape, many of these non-native, farmed fish continued to thrive and swim free – some were even documented as far north as Vancouver Island, west of the Strait of Juan de Fuca, and south of Tacoma, traveling at least 100 miles from the farm. Escaped fish increase competition with wild fish for food, habitat, spawning areas and mates.6 Moreover, reliance on the sterility of farmed fish to prevent interbreeding is never 100% guaranteed; therefore, the “long-term consequences of continued farmed [fish] escapes and subsequent interbreeding . . . include a loss of genetic diversity.”7 Finally, escaped farmed fish might spread a multitude of parasites and diseases to wild stocks, which could prove fatal when transmitted.8
On the topic of parasites and diseases, we have significant concerns over the pervasive use of
3 Escape calls high energy salmon sites into question, The Fish Site (Jan. 20, 2020),
https://thefishsite.com/articles/mowi-reports-mass-salmon-escape-from-colonsay.
4 O.H. Diserud, et al., Escaped farmed Atlantic salmon in Norwegian rivers during 1989-2013, 76 ICES Journal of Marine Science 1140 (2019), https://academic.oup.com/icesjms/article/76/4/1140/5289588. 5 Cliff White, Huon reports AUD 128 million loss, addresses JBS takeover bid, SeafoodSource, Aug. 27, 2021, https://www.seafoodsource.com/news/business-finance/huon-reports-aud-128-million-annual-loss-addresses jbs-takeover-bid
6 Lynda V. Mapes, Seattle Times, Despite agency assurances, tribes catch more escaped Atlantic salmon in Skagit River (Dec. 1, 2017), available at https://www.seattletimes.com/seattle-news/environment/despite-agency assurances-tribes-catch-more-escaped-atlantic-salmon-in-skagit-river/.
7 Fisheries and Oceans Canada, Newfoundland and Labrador Region, Stock Assessment of Newfoundland and Labrador Atlantic Salmon (2016), available at http://waves-vagues.dfo-mpo.gc.ca/Library/40619655.pdf (“Genetic analysis of juvenile Atlantic Salmon from southern Newfoundland revealed that hybridization between wild and farmed salmon was extensive throughout Fortune Bay and Bay d’Espoir (17 of 18 locations), with one-third of all juvenile salmon sampled being of hybrid ancestry.”); see also Mark Quinn, CBC News, DFO study confirms 'widespread' mating of farmed, wild salmon in N.L. (Sept. 21, 2016),
https://www.cbc.ca/news/canada/newfoundland-labrador/farmed-salmon-mating-with-wild-in-nl-dfo-study 1.3770864.
8 Jillian Fry, PhD MPH, David Love, PhD MSPH, & Gabriel Innes, VMD, Johns Hopkins University, Center for a Livable Future, “Ecosystem and Public Health Risks from Nearshore and Offshore Finfish Aquaculture” at 6-7 (2017), https://clf.jhsph.edu/publications/ecosystem-and-public-health-risks-nearshore-and-offshore-finfish aquaculture.
pharmaceuticals and other chemicals for prevention and treatment of outbreaks in marine finfish aquaculture facilities. The use of these chemicals creates environmental and public health concerns. It is known that large concentrated populations of animals are more susceptible to pests and diseases due to confined spaces and increased stress. In response, the agriculture and aquaculture sectors administer a range of chemicals – and in the open ocean, residues of these drugs are discharged and absorbed into the marine ecosystem. For example, the marine finfish aquaculture industry often treats sea lice with Emamectin benzoate (marketed as SLICE®), which has caused “widespread damage to wildlife,” including “substantial, wide-scale reductions” in crabs, lobsters and other crustaceans.9 In Nova Scotia, an 11-year-long study found that lobster catches plummeted closer to marine finfish aquaculture facilities.10 In addition, the use of antibiotics in marine finfish aquaculture facilities is contributing to the public health crisis of antibiotic resistance. In farmed fish, there may still be antibiotic and other chemical residues by the time they reach consumers, and they can also leach into the ocean, contaminating nearby water and marine life. In fact, up to 75% of antibiotics used by the industrial ocean fish farming industry are directly absorbed into the surrounding environment.11
Another serious concern is the direct discharge of untreated toxins, including excess food, waste, antibiotics, and antifoulants associated with industrial ocean fish farms. Releasing such excess nutrients can degrade water quality around the farm and threaten surrounding plants and animals. Dilution is not the solution to pollution – it all goes somewhere. Massively developing and expanding an industry with direct discharges into our marine waters is creating a new form of marine pollution with certain serious future consequences.
These factory farms can also physically impact the seafloor, and change marine ecology by attracting and harming predators and other species that congregate around fish cages. These predators – such as birds, seals, and sharks – can easily become entangled in lines and pens,
stressed by acoustic deterrents, and more easily captured and killed. For example, an industrial ocean fish farm caused the death of an endangered monk seal in Hawaii, which was found entangled in the net.12 Also, in August 2018, Cooke Aquaculture entangled an endangered Humpback whale in large gillnets, which were cast to recapture escaped farmed fish from a Canada facility.13 These are merely two of many unfortunate entanglements.
Large populations of farmed fish will require an incredible amount of fish feed, which carries its own environmental, public health, and human rights risks.14 Most industrially farmed finfish,
9 Rob Edwards, The Sunday Herald, Scottish government accused of colluding with drug giant over pesticides scandal, (June 2, 2017),
http://www.heraldscotland.com/news/15326945.Scottish_government_accused_of_colluding_with_drug_giant_over pesticides_scandal/.
10 I. Milewski, et al., (2018), Sea Cage aquaculture impacts market and berried lobster catches, Mar Ecol Prog Ser 598: 85-97, available at https://www.int-res.com/articles/meps2018/598/m598p085.pdf. 11 United Nations, “Frontiers 2017: Emerging Issues of Environmental Concern” at 15 (2017), https://www.unep.org/resources/frontiers-2017-emerging-issues-environmental-concern. 12 Caleb Jones, USA Today, Rare Monk Seal Dies in Fish Farm off Hawaii (Mar. 17 2017), available at https://www.usatoday.com/story/news/nation/2017/03/17/rare-monk-seal-dies-fish-farm-off-hawaii/99295396/. 13 Terri Coles, CBC News, Humpback whale freed from net meant for escaped farm salmon in Hermitage Bay (Aug. 14, 2018), https://www.cbc.ca/news/canada/newfoundland-labrador/whale-caught-gill-net-cooke-aquaculture 1.4784732.
14 See generally, Changing Markets Foundation, Until the Seas Run Dry (2019), available at
like salmon, are carnivorous and require protein in their feed. This often consists of lower trophic level “forage fish,” some of which are at risk of collapse. The Food and Agriculture Organization (FAO) estimates that one-fifth of the combined world-capture of wild marine fish is processed into fish meal/fish oil (FMFO), the majority of which is used to feed farmed fish.15 Aquaculture facilities are also relying more on genetically engineered non-marine ingredients such as corn and soy, as substitute protein sources, which do not naturally exist in a fish’s diet. Use of these ingredients can lead to increased, widespread environmental degradation, more demand on natural resources, and a less nutritious fish for consumers. Moreover, the fish-feed industry is a global contributor to human trafficking and slavery.16 There are very few requirements for the industry to include traceability of ingredients or sourcing methods in fish feed, allowing these serious problems to continue.
Finally, permitting commercial, marine finfish aquaculture in the United States could bring formidable economic harm to our coastal communities, food producers (on land and at sea), and other marine-reliant industries. Members of the wild-capture fishing industry have collectively voiced their trepidations over attempting to coexist with the marine finfish aquaculture industry, stating that “this emerging industrial practice is incompatible with the sustainable commercial fishing practices embraced by our nation for generations and contravenes our vision for environmentally sound management of our oceans.”17 These massive facilities could also close off and essentially privatize large swaths of the ocean that are currently available for numerous other commercial purposes, including fishing, tourism, and shipping. Given what we know about economies of scale, and the business models of modern agriculture and terrestrial food production, we can only expect a similar trend at sea: that is, the marine finfish aquaculture industry could easily push out responsible, smaller-scale seafood producers and others. This dynamic equates to an alarming imbalance of power, and allows corporations to dominate business structures, production methods, and management policies within the industry. Giving corporations disproportionate influence over food production also severely limits consumer choices.18 Additionally, this means we are essentially swapping one industry for others – without a meaningful increase in jobs or boost to the economy – just a shift from smaller scale and independent to industrialized and corporate. This also often equates to shifting power away from people who have experienced historic discrimination,
http://changingmarkets.org/wp-content/uploads/2019/04/REPORT-WEB-UNTILL-THE-SEAS-DRY.pdf (concluding that using wild fish to feed farmed fish “raises concerns of overfishing, poor animal welfare and disruption of aquatic food webs; it also undermines food security in developing countries, as less fish is available for direct human consumption”).
15 Global Banking & Finance Review, Aquaculture's Profitability is at
Stake, https://www.globalbankingandfinance.com/aquacultures-future-profitability-is-at-stake/. 16 Tickler, David ,et al. (2018) Modern slavery and the race to fish, Nature Communications 9: 4643, available at https://www.nature.com/articles/s41467-018-07118-9.
17 Open letter to Members of the U.S. House of Representatives and Senate, Dec. 4, 2018, re: Opposition to marine finfish aquaculture in U.S. waters, available at http://foe.org/DecFishFarmingSignOnLetter/. 18 See generally, Undercurrent News, World’s 100 Largest Seafood Companies
(Oct. 7, 2016), https://www.undercurrentnews.com/report/undercurrent-news-worlds-100-largest-seafood companies-2016/; Tom Seaman, Undercurrent News, World’s top 20 salmon farmers: Mitsubishi moves into second place behind Marine Harvest (June 29, 2016),
https://www.undercurrentnews.com/2016/06/29/worlds-top-20-salmon-farmers-mitsubishi-moves-into-second place-behind-marine-harvest/; Aslak Berge, Undercurrent News, These are the world’s 20 largest salmon producers (July 30, 2017), http://salmonbusiness.com/these-are-the-worlds-20-largest-salmon-producers/.
including indigenous Tribes.
II. There are significant legal and conflict-of-interest concerns with streamlining regulations and permitting of marine aquaculture.
There is a significant conflict-of-interest risk within the National Oceanic and Atmospheric Administration (NOAA), which is the self-proclaimed lead federal agency on policy formulation and regulation of domestic aquaculture. However, in addition to its regulatory efforts, NOAA also has prioritized the explicit goal of promoting and expanding marine aquaculture production in the United States. For 2019, NOAA Fisheries stated:
A high priority objective in the Department of Commerce strategic plan is “increasing marine aquaculture production.” Supplementing U.S. wild-caught fisheries, a healthy marine aquaculture industry has the potential to greatly increase our overall U.S. seafood production and reduce the seafood trade deficit. In 2019, we will give our full support to growing a healthy U.S. marine aquaculture industry. Our first step will be to address the bureaucratic hurdles an applicant faces in the federal permitting process.19
The Report confirms our concerns that the Administration is charging full-steam ahead with promoting this potentially disastrous industry without exercising due diligence to fully understand the risks and impacts of permitting commercial facilities in United States’ waters. In fact, the dearth of environmental, public health, and other socio-economic concerns mentioned in the Report seems to confirm that the Administration is already displaying harmful outcomes from a conflict of interest - a work plan that sacrifices even basic regulation, enforcement, and transparency, to achieve rapid and easy industry growth and profitability. Such swift development of marine aquaculture will be achieved at the expense of our ocean ecosystems, coastal and fishing economies, and public health.
As noted above, the first objective of this Report, “[e]xpand the range of aquaculture activities authorized under general permits and through programmatic consultations,” clearly shows that the overarching goal of this report is to encourage unfettered offshore aquaculture expansion, with no regard to the environmental, health, or socioeconomic impacts.
The legality of using general permits for such efforts has been, and is currently being, challenged on various fronts. In fact, earlier this year, the U.S. Court of Appeals for the Ninth Circuit affirmed a lower court ruling revoking a Clean Water Act general permit used to authorize the vast majority of commercial shellfish aquaculture in Washington state.20 The District Court had found the Nationwide Permit unlawful, including for failing to adequately evaluate cumulative
19 NOAA Fisheries, Priorities and Annual Guidance 2019 at 1, available at
https://media.fisheries.noaa.gov/dam-migration/noaa-priorities-2019-final-march-2019.pdf. 20 Center for Food Safety, Court of Appeals Backs Environmentalists: Federal Greenlight of Industrial Shellfish Aquaculture Unlawful, Feb. 11, 2021, https://www.centerforfoodsafety.org/press-releases/6264/court-of-appeals backs-environmentalists-federal-greenlight-of-industrial-shellfish-aquaculture-unlawful.
impacts to the environment from the tens of thousands of acres of aquaculture. Using general permits for open water marine aquaculture is especially problematic, as each space - each environment - is unique. Even areas off of the same states, for example Florida, can be dramatically different from north to south – with varying species, currents, temperatures and more – all significant for siting of facilities. General permits are an unacceptable means of streamlining development too, because it allows for less notice, comment and thoughtful process from multiple agencies and stakeholders for these facilities. Given the potential for extensive and possibly permanent damage resulting from offshore marine aquaculture, general permits should not be used.
Finally, offshore aquaculture is not a resilience strategy for climate change, rather the practice could be extremely detrimental to people and the planet in light of a changing climate. Beginning in 1980, climate change has contributed to an increase in risk of hurricanes and other tropical cyclones.21 Intensity of storms is also increasing, as was clearly demonstrated by Hurricane Ida that hit the United States Gulf Coast on August 29, 2021 at 150 mph, and then proceeded up to the northeast where it also caused considerable damage, flooding and deaths. These storms can impact different areas over a wide geographic range. Real concerns remain on how offshore aquaculture facilities will secure equipment under the force of a major, or series of major, storms. Global climate models consistently project a significant increase in sea surface temperatures, which would drive an increase in destructive tropical storms with high-intensity winds, extreme rainfall, and high storm surge, all of which could impact aquaculture operations. The increasing frequency of extreme precipitation events is also compounding coastal flooding risk, when storm surge and heavy rainfall occur together.22 As climate change continues, the intensity of tropical storms is projected to continually increase, making hurricanes and other storms more and more destructive.
Climate change also exacerbates the possibility of disease spread. Fish are vulnerable to changes in their aquatic habitat, especially, in the case of net pens, where they cannot move away.23 Climate change increases the risk of pathogen prevalence and/or virulence and host susceptibility (immunosuppression) and transmission.24 Planning to streamline permitting for marine aquaculture is a wasteful use of resources at this time, as offshore aquaculture facilities, and the fish they contain will be highly vulnerable to a changing climate.
III. If it moves forward, the task force must devote significant resources to researching the potential socio-economic, public health, and
environmental problems associated with industrial offshore aquaculture and transparency.
21 Hiroyuki Murakami, et al., Detected climatic change in global distribution of tropical cyclones, PNAS (May 4, 2020), https://www.pnas.org/content/117/20/10706.
22 See generally Tom Knutson, Global Warming and Hurricanes: An Overview of Current Research Results, Geophysical Fluid Dynamics Laboratory, last revised Aug. 9, 2021, https://www.gfdl.noaa.gov/global-warming and-hurricanes/.
23 Food and Agriculture Organization of the United Nations, Impacts of Climate Change on Fisheries and Aquaculture, at 526 (2018), http://www.fao.org/policy-support/tools-and-publications/resources details/en/c/1152846/.
24 Id.
To promote only sustainable and responsible aquaculture development and production in the United States, the task force must devote sufficient resources to studying and understanding the risks and impacts of the industry for the environment, society, and the economy. This includes both thorough and separate review of all forms of aquaculture. Not all aquaculture is the same, and finfish facilities, in particular, pose very different threats and consequences than others.
However, the Report focuses on a utopian view of streamlined aquaculture, including, but not limited to, improving efficiencies (rather than traceability, health, or quality) for drug approvals, biologics, and feed ingredients; developing surveillance strategies and emergency response plans for “priority” pathogens (rather than natural prevention or mitigation of all pathogens); the movement, import, and export of aquaculture product; and improving efficiency of siting, permitting, and authorizing of operations in at least two marine areas.
In fact, the only section of the Report dedicated to the risks we highlight is “Objective 1.4: Improve aquaculture-specific outreach on the NPDES program and continue to provide information on the water quality risks associated with aquatic animal production” and the only other mention of these risks is a passing mention of the need for science-based tools to “to site and manage aquaculture facilities, identify strategies to minimize, and avoid negative impacts to protected species and habitats, reduce the risk of invasive species introductions, minimize use conflicts, and evaluate risks associated with disease and genetic risk interactions between farmed and wild populations.”25
Thus, it is very clear that the task force, and federal agencies involved, are prematurely pushing forward with streamlined permitting of an industry about which very little is being studied. The process also raises questions about the task force interplay with National Environmental Policy Act (NEPA) requirements.
Additionally, if the task force moves forward, ongoing transparency is required. This means noticing meetings, encouraging and soliciting public input, and allowing for a meaningful comment period with any future plans. Failing to disclose and notice any work of the task force in the name of efficiency is problematic, as marine aquaculture affects public resources, meant to be used and managed for the benefit of the public, not just special interests.
We are alarmed that the Report lacks meaningful discussion of, or planning for, the risks and impacts discussed above. We urge the task force to prioritize and incorporate such information.
As we discussed in our previous comments on the Draft Outline for a Workplan for a Federal Aquaculture Regulatory Task Force (FARTF) dated November 8, 2019, we again strongly recommend placing a hold on the task force actions, and any related activity, to improve regulatory efficiency and predictability, until the following action items are implemented:
25 Report, at 26.
Goal 1. Comprehensively analyze the risks and impacts of commercial aquaculture in the United States.
Objective 1.1: Conduct socioeconomic research to discover the impacts that aquaculture would have on marine-reliant industries, coastal economies, and land-based crop production Objective 1.2: Compile and analyze the range of environmental harms of commercial-scale aquaculture (shellfish, finfish and plants)
Objective 1.3: Research environmental and public health impacts of veterinary drugs and other chemicals used in aquaculture
Objective 1.4: Implement proper mitigation and alleviation strategies, including consideration of alternatives to marine aquaculture, like recirculating systems on land, and elimination of marine finfish aquaculture production from the national strategic plan.
We also urge the task force to require that all research carried out pursuant to its work be entirely independent, to ensure that there is no conflict of interest or bias in the analysis and conclusions.
We look forward to engaging further in this process at every available opportunity. Sincerely,
Recirculating Farms
Marianne Cufone, Executive Director
mcufone@recirculatingfarms.org
North American Marine Alliance
Rosanna Marie Neil, Policy Counsel
rosanna@namanet.org
Alaska Longline Fishermen’s Association
Linda Behnken, Executive Director
alfafishak@gmail.com
Alliance of Communities for Sustainable Fisheries
Alan Alward, Co-Chair
netflea@charter.net
Center for Biological Diversity
Jaclyn Lopez, Florida Director
jlopez@biologicaldiversity.org
Center for Food Safety
Meredith Stevenson, Associate Attorney
mstevenson@centerforfoodsafety.org
9
Commercial Fishermen of Santa Barbara
Tim Mulcahy, Fisherman
fvcalogera@yahoo.com
Duna Fisheries, LLC
Amanda Grondin, Owner/Operator
ajgrondin@gmail.com
Food & Water Watch
Zach Corrigan , Sr. Staff Attorney
zcorrigan@fwwatch.org
Friends of the Earth
Hallie Templeton, Legal Director & Senior Campaigner htempleton@foe.org
F/V Arminta
Greg Friedrichs, Commercial Fisherman
dunafish@me.com
Greenhorns
Severine Fleming, Director
severine@greenhorns.org
Healthy Gulf
Raleigh Hoke, Campaign Director
raleigh@healthygulf.org
Mangrove Action Project
Alfredo Quarto, Program & Policy Director/Co-Founder mangroveap@olympus.net
Morro Bay Commercial Fishermen’s Organization Tom Hafer, President
somethingsfishy@charter.net
Oceanic Preservation Society
Courtney Vail, Campaigns Director
courtney@opsociety.org
Olympic Environmental Council
Darlene Schanfald, Secretary
darlenes@olympus.net
10
Pride of Bristol Bay
Stephen Kurian, Owner
steve@prideofbristolbay.com
SalmonState
Elizabeth Herendeen, Marketplace Manager
elizabeth@salmonstate.org
San Diego Fishermen’s Working Group
Pete Halmay, President
peterhalmay@gmail.com
Seaweed Commons
Severine Fleming, Director
severine@greenhorns.org
Slow Food USA
Ed Yowell, Chair, Food and Farming Policy Steering Committee eayowell@outlook.com
Suncoast Waterkeeper
Justin Bloom, Founder and Board Vice-Chair
bloomesq1@gmail.com
Western Fishboat Owners Association
Tim Mulcahy, Fisherman
fvcalogera@yahoo.com
Wild for Salmon
Steve Kurian, Owner
steve@wildforsalmon.com
Wild Salmon Nation
Johnny Fishmonger, Executive Director
wildsalmonnation@gmail.com
USDA - Office of Communication
WASHINGTON, Sept. 9, 2021 – The U.S. Department of Agriculture (USDA) today announced it will soon publish Requests for Applications (RFAs) for new grant programs - the Pandemic Response and Safety (PRS) Grant program and the Seafood Processors Pandemic Response and Safety Block Grant program - to support agricultural stakeholders who haven’t yet received substantial federal financial assistance in responding to the COVID-19 crisis. These grant programs will provide assistance to small businesses in certain commodity areas, including small scale specialty crop producers and processors, shellfish, aquaculture and other select producers, meat and other processors, distributors, farmers markets, seafood facilities and processing vessels. Today USDA released grant forecasts for these new programs to help potential applicants determine their eligibility and to prepare to apply for funding. Approximately $650 million in funding is available for the PRS grants and $50 million is available for SPRS. All of these new programs are funded by the Pandemic Assistance provided in the Consolidated Appropriations Act of 2021.
“As the economy continues to gain strength after the Biden Administration’s historic vaccination and economic relief efforts, USDA is working with agricultural and food businesses to ensure they have the resources and tools to thrive in 2021 and beyond,” said Agriculture Secretary Tom Vilsack. “The funding associated with USDA Pandemic Assistance is meant to serve as a bridge from disruptions associated with the pandemic to longer-term investments to help build back a better food system. Financial relief to these essential producers, distributors, processors and other small agricultural businesses is a critical to get our food system back on track.”
For the PRS grants, eligible entities are detailed in the Pandemic Response and Safety Grant Program forecast, USDA-AMS-TM-PRS-G-21-0011. Eligible entities should visit the PRS grant portal at usda-prs.grantsolutions.gov for complete information on the program, including how to obtain a free of charge DUNS Number from Dun & Bradstreet (D&B) BEFORE applying for this program. On September 23, USDA will issue another announcement indicating that entities may submit their applications through the grant portal; entities will need their DUNS number to submit an application.
For the Seafood PRS grants, USDA will allocate block grant funding to U.S. states and territories based on a formula that considers economic activity as demonstrated through commercial fisheries landings. Eligible entities are state agencies as detailed in the Seafood Processors Pandemic Response and Safety Block Grant Program forecast, USDA-AMS-TM-SPRS-G-21-0012. The state agency will then provide funds to seafood processing facilities and processing vessels. Seafood processors and processing vessels should apply directly through their State agency; seafood processors and processing vessels should not apply through PRS and should instead contact their state agency for financial assistance once USDA awards funds to states. A listing of state contacts will be made available on the USDA website. Tribal government owned eligible entities may apply directly to USDA, details of which will be developed through tribal consultation in conjunction with Office of Tribal Relations.
Updated information regarding the PRS and Seafood PRS programs will be available on the Agricultural Marketing Service (AMS) website: www.ams.usda.gov.
Any grant application submitted after the due date will not be considered unless the applicant provides documentation of an extenuating circumstance that prevented their timely submission of the grant application. Read more in AMS Late and Non-Responsive Application Policy (PDF, 431 KB).
USDA touches the lives of all Americans each day in so many positive ways. In the Biden-Harris Administration, USDA is transforming America’s food system with a greater focus on more resilient local and regional food production, fairer markets for all producers, ensuring access to safe, healthy and nutritious food in all communities, building new markets and streams of income for farmers and producers using climate smart food and forestry practices, making historic investments in infrastructure and clean energy capabilities in rural America, and committing to equity across the Department by removing systemic barriers and building a workforce more representative of America. To learn more, visit www.usda.gov.
Press Release
August 18, 2021
On August 9th, 2021, the Marine Stewardship Council (MSC) recertified the North Pacific fixed gear sablefish fishery as sustainable according to the MSC’s rigorous guidelines, and extended that certification to the Northern Southeast Inside’s sablefish fishery for the first time.
"This recertification rightly acknowledges the hard work of Alaska fixed gear fishermen and fishery managers to maintain healthy fisheries in balance with marine ecosystems," said Bob Alverson, Director of Fishing Vessel Owners Association (FVOA). The client for MSC halibut and sablefish is “Eat on the Wild Side” a non-profit of the FVOA and Deep Sea Fishermen’s Union (DSFU). “MSC certification requires continued improvement in best fishing and management practices and our sablefish fisheries met all identified criteria."
The Marine Stewardship Council uses its ecolabel and fishery certification program to contribute to the health of the world's oceans by recognizing and rewarding sustainable fishing practices, influencing the choices people make when buying seafood, and working to transform the seafood market to a sustainable basis. The MSC first certified the North Pacific fixed gear sablefish fisheries on April 18, 2006.
"The addition of the NSEI sablefish fishery to the MSC certification makes solid sense both ecologically and from a marketing perspective," said Linda Behnken of the Alaska Longline Fishermen's Association (ALFA). "Sablefish are highly migratory, with significant mixing between open ocean and 'inside' stocks. The only difference is that one stock is carefully managed under the federal system and one even more conservatively by the State of Alaska-both merit the MSC label and the label's marketing benefits."
Seafood Producers Cooperative (SPC), a processing and marketing cooperative located in Sitka Alaska, requested FVOA and ALFA work with the MSC to expand sablefish certification to include the Northern Southeast Inside fishery. SPC provided essential information required during the certification review, facilitating the successful outcome of the process.
"This was a strong team effort by FVOA, DSFU, ALFA and SPC to secure appropriate MSC marketing benefits for our fixed gear members and the fleet generally," said Jeff Reynolds, General Manager of SPC. "The domestic demand for sablefish, which is an exceptional deep water fish, is growing and customers deserve to know that the fixed gear fishery is sustainably managed throughout Alaska. The MSC label provides that level of confidence both in the US and overseas."
For more information contact: Bob Alverson, FVOA, roberta@fvoa.org, (206) 283-7735
Linda Behnken, ALFA, alfafishak@gmail.com, 907-738-3615
Becky Martello, SPC, BMartello@spcsales.com, 907-738-2605
Jim Johnson, DSFU, jj.deepseafishermensunion@gmail.com,
(206) 783-2922
Posted by KCAW Staff | Jul 13, 2021
Salmon Nation, an organization geared towards protecting the unique and diverse ecosystems of wild salmon from Alaska to Northern California, is offering 20 fellowships as part of their Salmon Stories initiative. Salmon Stories is a collection of personal narratives from across the bioregion that share why the fight for wild salmon is about more than fish. Co-creator of Salmon Nation, Ian Gill, joins host, Brooke Schafer to discuss the goals of the organization and how people can get involved with Salmon Stories.
These stories will be shared publicly in Fall 2021. To get more information about Salmon Nation and their fellowship opportunities visit their website.
First published on Marine Fish Conservation Network website
By Linda Behnken and Kevin Scribner, MFCN Policy Council co-chairs
For the two of us, climate change is top of mind. It impacts the way we do business, the way we think about the ocean resources we depend on, the way we see our communities surviving into the future. We’re going to have to adapt; we’ve already had to adapt. Climate change is affecting every point on Earth, including Southeast Alaska and the Pacific Northwest, where we live and work. Warming water temperatures, ocean acidification, intensified storms, rising sea levels, ocean heat waves, salinity alterations, and slowing ocean currents are some of the climate change impacts occurring off shores around the globe.
Each of these factors have profoundly impacted the habitats that support the resources we depend on, throughout the marine ecosystem. And small-scale, community-based fishermen are often disproportionally exposed to climate change impacts because we are place-based. To restore ocean health and ensure our seafood businesses will be able to persist, resource governance in the ocean is going to have to operate in new, adaptive, resilience-focused ways.
The time is now to take action.
The Magnuson-Stevens Fishery Conservation and Management Act (MSA) was passed in 1976, when climate change wasn’t even a buzzword, let alone an acknowledged generational threat. In fact, the MSA does not contain specific provisions to account for or address climate change in fisheries management. Updating the law to include criteria for incorporating climate change data into scientific assessments, and a methodology for doing so, will create a more complete picture of the environmental conditions affecting ocean fisheries.
We know that natural disasters like hurricanes, ocean heat waves, and harmful algal blooms occur more frequently and with greater intensity. In some regions, destabilized seasons are the norm rather than the exception. Fisheries managers must be given the tools and mandates to plan for these uncontrollable events when adopting management measures, such as annual catch limits, season dates, or other management provisions, including emergency actions that adjust existing measures during the fishing season in response to unpredicted environmental events.
Small scale fishermen have long been advocates for ocean health. We are storytellers for the ocean because our stories and our communities’ stories depend on a healthy ocean. Mechanisms must also be developed that will provide coastal communities and fishery-dependent businesses the means to better predict, and recover from, economic losses attributable to climate-related environmental changes and acute and unanticipated environmental events. Folding support for communities and the critical working waterfront into fisheries management is critical if small-scale fisheries are going to survive. Likewise, sustaining small scale fisheries is critical if coastal communities and the ocean resources they champion are to thrive.
Adapting fisheries management to climate change is no longer optional; it is inevitable. We need a proactive management approach that can quickly adapt to the reality of our changing oceans and fisheries. The Magnuson-Stevens Act should be amended to provide guidance to the Secretary of Commerce, NOAA, and the eight regional fishery management councils for adapting conservation and management measures to unpredictable and evolving ocean conditions and ensuring fisheries management decisions support the health and abundance of fish stocks. The law should also provide a mechanism that allows fishery managers to quickly implement regulations or interim measures to prevent overfishing and increase the resiliency of fish stocks and fishing communities in the face of environmental emergencies, including those attributed to climate change.
The two of us have worked hard over the past year with our colleagues at the Marine Fish Conservation Network to create and advance some targeted legislative actions that could bring these important new policies to bear. Specifically, we are urging Congress to undertake the following actions:
Fishery management plan requirements should be amended to include a determination of the impacts of climate change on the fishery and establish conservation and management measures to respond to those impacts. Fishery management plans should establish criteria for determining when an emergency attributable to climate change is affecting the fishery or fishing community, such as rapid declines in fish populations, sudden changes in fish distribution, or changes in environmental conditions that could affect fish stocks or fish habitat.
The Secretary of Commerce should have the ability to enact emergency regulations or interim measures during a fishing season or fishery management cycle to prevent or reduce overfishing and promote resilience of fish stocks during climate change emergencies. Under such a framework, relevant regional fishery management councils would be consulted prior to setting regulations or interim measures; any measures taken should not exceed the annual catch limit for the fishery and should maximize fishing community participation in the decision-making process and the access of fishing communities to available harvest.
All stock assessments should include known impacts of climate change on the fishery and assess the stock’s vulnerability to these changing conditions. Stock assessments should also offer recommendations for addressing climate change impacts on the fishery and identify any additional research needed to better understand the impacts.
A process should be established that, at the request of a fishery management council, allows the Secretary of Commerce to determine if a fishery extends beyond the jurisdiction of the council currently managing it and, in coordination with the relevant councils, determine the best council or councils to prepare a new or joint fishery management plan.
These improvements are sure to make a difference. For the sake of the long-term health and productivity of U.S. fisheries and fishing communities, we cannot afford to fail.
About the Authors:
Linda Behnken, a commercial fisherman, is Executive Director of the Alaska Longline Fishermen’s Association. Kevin Scribner, a former fisherman, is the founder of Forever Wild Seafood and serves on the Slow Food USA Food and Farm Policy Committee. They serve as co-chairs of the Marine Fish Conservation Network’s Policy Council
Tiare Buoys / Marine Stewardship Council
Published Jun 29, 2021
American shoppers cruising down the seafood aisle — even those hundreds of miles away from a working coastline — are increasingly concerned about the health of the ocean.
The decline of fish populations and ocean health is the sixth highest environmental concern worldwide, but Americans prioritize it even higher — ranking ocean health as their third highest environmental concern, according to 2020 survey conducted by independent research and strategy consultancy, Globescan.
Read whole article here: https://grist.org/article/consumers-are-demanding-more-sustainable-seafood-and-its-working/
This summer, SHIP and our partners in the commercial fishing industry are launching Skipper Science — an innovative program that will bring your lived experiences and observations of climate change from the fishing grounds to decision makers. Skipper Science uses cutting edge technology that allows you to record observations and data on your smartphone — from the wheelhouse. Plus, when you participate, you’ll be entered to win cash prizes!
Register Here to Participate in the Skipper Science Program
When you participate in the Skipper Science Program, you will:
Be entered to win cash prizes!
Join fishermen across the State of Alaska who want to strengthen a collective voice in policy and management decisions in our fisheries;
Demonstrate the wealth of knowledge fishermen have to contribute to the scientific and policy community;
Be part of the Alaska community working on climate adaptation, responses and solutions;
Have your voice heard!
Register Here to Participate in the Skipper Science Program
The Skipper Science Smart Phone App - How it works:
The Skipper Science app provides a platform for fishermen to document physical and biological phenomena they observe while fishing through either an iOS or Android operating system smartphone or tablet. Using the app, skippers will document observed environmental changes and anomalies through words, photos, waypoints and other data and information avenues. Participating fishermen will receive quick and easy training, consistent individualized support and technical assistance with data collection throughout the summer.
Read more here: http://alaskasalmonhabitat.org/2021/06/new-skipper-science-program-kicks-off-this-summer-with-on-the-water-climate-observations/
March 17, 2020
To: The Honorable Gina McCarthy, White House National Climate Advisor
The Honorable Ali A. Zaidi, Deputy White House National Climate Advisor
As scientists with backgrounds in natural resources, climate change, forest carbon, biodiversity natural resource economics, and medicine we write to express our strong support for the Biden Administration’s development of Nationally Determined Contributions (NDCs) for the upcoming United Nations COP26. We request that the NDCs comply with Article 5 of the Paris Agreement by protecting the nation’s carbon dense mature forest ecosystems (“carbon reservoirs”) in a strategic natural carbon reserve on federal lands. To begin this process, we ask specifically that all old-growth forests and roadless areas on the Tongass National Forest in southeast Alaska be a central part of the administration’s NDC commitments and the first entry into the strategic carbon reserve system for protecting remaining older forests on federal lands nationwide 1.
The 16.8 million-acre Tongass National Forest is the crown jewel of the national forest system and is the recognized national champion in storing the equivalent of some 8% of all US forest carbon 2. The Tongass is one of the world’s last remaining relatively intact temperate rainforests that supports a robust tourism and fishing economy, including the provision of abundant salmon, deer, and cultural resources for Indigenous Peoples 3. Because of its northern coastal distribution, the Tongass is likely to function as a “climate sanctuary 4,” in contrast to interior Alaska that is experiencing one of the fastest rates of climate change on the planet 5. Protecting climate sanctuaries like the Tongass is a crucial step toward maintaining the nations’ most important ecosystem services and biodiversity increasingly at-risk.
The Tongass is also the only national forest where industrial logging of old-growth forests continues apace despite overwhelming public and tribal opposition. Tongass logging and road building costs the American taxpayer some $600 million over two decades 6. Despite these costs, the Trump Administration recently rescinded 9.3 million acres of roadless area protections that would allow road building and logging of some 186,000 acres of the largest, oldest trees. Such targeted logging would, according to one estimate, result in the equivalent emissions of ~10 million vehicles on Alaska’s roadways 7, a clear defiance of the warnings to humanity from thousands of scientists 8 regarding escalating climate and biodiversity calamities. In sum, we have precious little time before ecosystems and the climate are pushed beyond the point of no return that according to a recent United Nations report 9 will impact all citizens on the planet, including the grim prospect of contributing to more global pandemics as wild areas are increasingly developed and more zoonotic diseases released 10.
We urge that you demonstrate global leadership on the importance of including the nation’s remaining carbon dense, natural, and intact areas in a system-wide reserve network that would begin with the Tongass in the NDCs. Doing so, would also demonstrate progress towards the administration’s commitment to protect 30 percent of all lands and waters by 2030.
Sincerely (*affiliations for identification purposes only),
Dominick A. DellaSala, Ph. D Chief Scientist, Wild Heritage Talent, OR
James R. Karr, Ph. D, Emeritus Prof. University of Washington, Seattle, WA
Dennis Murphy, Ph. D, Prof. Ecology, Evol., Conservation Biology University of Nevada, Reno, NV
Thomas T. Veblen, Ph. D, Distinguished Prof., University of Colorado, Boulder, CO
James R. Strittholt, Ph. D
President/Ex Director, Conservation Biol. Inst. Corvallis, OR
Malcolm L. Hunter, Jr. Ph. D University of Maine, Orono, ME
Richard T. Holmes, Ph. D. Emeritus Prof. Dartmouth College
Hanover, NH
Barry R. Noon, Emeritus Prof.
Colorado State University, Ft. Collins, CO
Kai M.A. Chan, Prof., lead author IPBES Connecting Human & Natural Systems
William J. Ripple, Ph. D
Endowed Chair and Distinguished Prof.
University of British Columbia, Vancouver
Jason A. Koontz, Ph. D
Professor of Biology
Co-Chair Environ. Studies Program Augustana College, Rock Island, IL
Jon Grinnell, Ph. D
Francis Morley Chair in Biology
Oregon State University, Corvallis, OR
Reed F. Noss, Ph. D, President
Florida Institute for Conservation Science Melrose, FL
Brian Linkhart, Ph. D, Professor Dept. Organismal Biology & Ecology
St. Peter, MN Colorado College, Colorado Springs, CO
Timothy A. Pearce, Ph. D
Curator: Carnegie Museum Natural Hist. Pittsburg, PA
Gregory M. Huey, R.E.P
William L. Baker, Ph. D, Emeritus Prof. Program Ecology, University of Wyoming Laramie, WY
William D. Anderson, Jr., Ph. D, Emeritus Prof.
Environ. Project Lead
U.S. Army Garrison, Kwajalein Atoll
Mitchell M. Johns, Ph. D, Emeritus Prof. College of Agriculture
California State University, Chico, CA
Robert L. Beschta, Ph. D. Emeritus Prof. Forest Ecosystems and Society
Oregon State University, Corvallis, OR
Don M. Waller, Ph. D, Emeritus Prof. University of Wisconsin
Madison, WI
John Robinson, Ph. D
J.L Tweedy Chair in Conservation Wildlife Conservation Society Bronx, NY
James Quinn, Ph. D, Emeritus Prof. Rutgers University, NJ
Michael W. Fox, BVetMed, Ph. D Consultant Veterinarian, Minneapolis, MN
Bobb Carson, Emeritus Prof. Earth & Environmental Sciences Lehigh Univ., Bethlehem, PA
Terry L. Root, Ph. D
Senior Fellow Emerita Stanford Woods Insti. Environ. Stanford University, CA
David F. Whitacre, Ph. D, Wildlife Treasure Valley Math/Sci Center Boise, ID
Jessica Pratt, Ph. D, Assoc. Prof. University of California, Irvine
Robert Summerfelt, Ph. D, Emeritus Prof. Dept. Natural Resource Ecology & Mgmt. Iowa State University, Ames
Grice Marine Biology Laboratory College of Charleston, SC
John Ratti, Ph. D
University of Idaho, Moscow, ID
Bruce G. Baldwin, Ph. D, Professor Integrative Biology & Curator Jepson Herb. University of California, Berkeley, CA
Philip Myers, Ph. D, Emeritus Prof. University of Michigan, Ann Arbor, MI
Garry Rogers, Ph. D, President Agua Ria Open Space Alliance, Inc. Humboldt, AZ
John W. Schoen, Ph. D, Wildlife Ecol. Anchorage, AK
Gretchen B. North, Ph. D, Prof. Biol. Occidental College, Los Angeles, CA
Gary D. Grossman, Ph. D
Fellow Am. Fisheries Soc., Linnean Soc. Athens, GA
David Karowe, Ph. D, Prof. Biol. Sci. Western Michigan University, Kalamazoo, MI
Stephen T. Tettelbach, Ph. D, Emeritus Prof. Long Island University, NY
Faisal Moola, Ph. D. Assoc. Prof.
Dept. Geograp., Environ., Geomatics, Guelph, CAN
Robert T. Heath, Ph. D, Dir. Emeritus Water Resources Research Inst.
Kent State University, OH
Paula M. Schiffman, Ph. D, Prof. Biol. California State University, Northridge
Carlos Carroll, Ph. D
Klamath Center for Conserv. Research Orleans, CA
Peter B. Moyle, Ph. D, Emeritus Prof. University of California, Davis
Robert M. Pyle, Ph. D
Xerces Society, Gray’s River, WA
Robert Huber, Ph. D, Biol. Sci. Bowling Green State University, OH
Roger A Powell, Ph. D
Dept. Applied Ecology
North Carolina State Univ. Ely, MN
Gary K. Meffe, Ph. D, Conserv. Biol. University of Florida, Gainesville
Scott Hoffman Black, M.S Executive Director, Xerces Society Portland, OR
Philip D. Cantino, Ph. D
Dept. of Environ. & Plant Biol. Ohio University, Athens
Thomas L. Fleischner, Ph. D
Executive Director, Natural History Inst. Prescott, Arizona
M. Henry H. Stevens, Ph. D, Assoc. Prof. Director Ecology, Evol., and Environ. Biol. Miami University, OH
F. Stuart Chapin, III Ph. D, Emeritus Prof. Institute of Arctic Biology, Univ. Fairbanks Fairbanks, AK
Darlene Chirman, MS Ecology University of California, Davis, CA
Thomas M. Power, Prof. Emeritus
Economics Dept. University Montana, Missoula
Melissa Savage, Ph. D, Emerita Prof. University of California, Los Angeles
Wayne D. Spencer, Ph. D, Chief Scientist Conservation Biology Institute, Corvallis, OR
March Lapin, Ph. D, Associate Prof. & Ecologist Middlebury College, VT
Craig W. Benkman, Ph. D, Prof. Zoology & Phys. University of Wyoming, Laramie
Richard Bradley, Ph. D, Assoc. Prof. Emeritus Evolution, Ecology, & Organismal Biology The Ohio State University, Columbus
John Harte, Ph. D, Ecosystem Sciences University of California, Berkeley, CA
Amy Moas, Ph. D
Senior Climate Campaigner, Greenpeace Washington, D.C
Karen Holl, Ph. D, Prof. Enviro. Studies University of California, Santa Cruz
Erik Asphaug, Ph. D University of Arizona, Tempe
Hartwell Welsh, Ph. D, Wildlife Ecologist Arcata, CA
Edward Huang, Ph. D, Principal California Institute of Environ. Design Arcadia, CA
Jay H. Jones, Ph. D, Prof. Biology & Biochem. University of La Verne, La Verne, CA
W Scott Armbuster, Ph. D University of Alaska, Fairbanks University of Portsmouth, UK
Monica Bond, Ph. D, Principal Scientist Wild Nature Institute, Concord, NH
Michael S. Swift, Ph. D, Emeritus Assistant Prof. Biology
St. Olaf College, Northfield, MN
John M. Marzluff, Ph. D, Prof. Wildlife Science
University of Washington, Seattle, WA
Jim Boone, Ph. D Ecology
Desert Wildlife Consultants, LLC Las Vegas, NV
Pepper W. Trail, Ph. D
Rogue Valley Audubon Society Ashland, OR
Bitty Roy, Ph. D, Emerita Prof. University of Oregon, Eugene, OR
Roger Sabbadini, Ph. D, Emeritus Prof. Biology, San Diego State Univ., CA
Curtis Bradley, M.S., Senior Sci. Center for Biological Diversity Tucson, AZ
Chad Hanson, Ph. D, Ecologist
John Muir Project, Big Bear City, CA
Ken Carloni, Ph. D, Forest Ecologist President, Umpqua Watersheds, Inc. Roseburg, OR
Franz Baumann, Ph. D Visiting Research Professor New York University, NY
Mary Edwards, Ph. D, Professor Geography & Environmental Sciences University of Southampton, UK
Janet Marsden, Ph. D
Syracuse University, Syracuse, NY
Rob Mrowka, MS, Retired Biologist Center for Biological Diversity Franklinville, NY
Russ K. Monson, Ph. D, Emeritus Prof. Dept. Ecology & Evolutionary Biology University of Arizona, Tempe
Fred M. Rhoades, Ph. D, Biology Western Washington University Bellingham, WA
Dan Gavin, Ph. D, Professor
Dept. Geography, University of Oregon Eugene, OR
Shaye Wolf, Ph. D, Climate Sci. Dir.
Center for Biological Diversity, Oakland, CA
Rich Nawa, MA, Staff Ecologist
Klamath Siskiyou Wildlands Center, Ashland, OR
Cindy Haws, M.S., President Umpqua Natural Leadership Sci. Hub Myrtle Creek, OR
John Bailey, Ph. D, Emeritus Prof. Colorado State University, Belgrade, MT
Maya Khosla, M.S., Wildlife Biologist Rohnert Park, CA
Evan Frost, M.S., Conservation Biologist Wildwood Consulting LLC
Ashland, OR
David Johns, JD, Ph. D
Hatfield School of Government Portland State University, Portland, OR
Roger Rosentreter, Ph. D, Botanist Boise State University
Boise, ID
James Catlin, Ph. D Emeritus
Wild Utah Project, Salt Lake City, UT
Timothy Ingalsbee, Ph. D, Ex. Dir. Firefighters United for Safety, Ethics, Ecology (FUSEE), Eugene, OR
Ceal Smith, M.S, Res. Policy Analyst Alaska Institute for Climate and Energy Homer, AK
Michael Goodchild, Ph. D, Emeritus Prof. University California, Santa Barbara, CA
Frank Lance Craighead, Ph. D Ex. Director, Craighead Institute Bozeman, MT
Judith Well, Ph. D, Ecologist Rutgers University, NJ
Travis D. Marsico, Ph. D, Prof.
Curator, Arkansas State Univ. Herbarium Arkansas State University, AR
Ken Driese, Ph. D, Program Director University of Wyoming, Laramie, WY
Paul Schaeffer, Assoc. Prof. Biology Miami University, Oxford, OH
Theodora Tsongas, Ph. D
Oregon Physicians for Social Responsibility Portland, OR
Catherine Thomasson, MD
Physicians for Social Responsibility, Portland, OR
David J. Cowen, Distinguished Emeritus Prof. Assoc. Member National Academy of Sciences Columbia, SC
Zach Brown, Ph. D, Tides Institute Gustavus, AK
Winston P. Smith Ph. D. Principal Res. Sci. Retired: Inst. of Arctic Biol., Univ. Fairbanks, AK
John Talberth, Ph. D, Pres. & Senior Economist Center for Sustainable Economy
West Linn, OR
John R. Cannon, Ph. D
Conservation Biologist, Front Royal, VA
Jon Evans, Ph. D, Prof. Biology The University of the South Sewanee, TN
1 https://www.seattletimes.com/opinion/a-strategic-natural-carbon-reserve-to-fight-climate-change/2https://www.researchgate.net/publication/225169208_Effects_of_Management_on_Carbon_Sequestration_in_Forest_Biomass_in_Southeast_Al aska
3 DellaSala, D.A. 2011. https://islandpress.org/books/temperate-and-boreal-rainforests-world
4 DellaSala, D.A., et al. 2015. https://www.fs.fed.us/pnw/pubs/journals/pnw_2015_dellasala001.pdf
5 https://www.adfg.alaska.gov/static/lands/ecosystems/pdfs/sp10_14.pdf
6 https://nam04.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.taxpayer.net%2Fenergy-natural-resources%2Fnew-report- taxpayers-losing-hundreds-of-millions-of-dollars-on-tongass-timber-sales-over-last-two- decades%2F&data=04%7C01%7Coped%40seattletimes.com%7Cce2fce3e14fe4a4ca76708d895697bdb%7Cfc2b8476b7f0473d82fbe0a89fd9985 5%7C0%7C0%7C637423627615324626%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWw iLCJXVCI6Mn0%3D%7C2000&sdata=YXnxLis3y%2F9tuHbEE5SmImv2bewfFSoSywXPvJj7f6M%3D&reserved=0
7 https://forestlegacies.org/wp-content/uploads/2019/12/tongass_carbon_2019_12_16.pdf
8 https://www.scientificamerican.com/article/the-climate-emergency-2020-in-review/
9 https://www.unep.org/resources/making-peace-nature
10 https://newrepublic.com/article/157361/public-health-depends-healthy-planet
