The Email

EMAIL SUBJECT: Docket Number EPA–R10–OW–2022–0418 

Dear Administrator Regan and Regional Administrator Sixkiller, 

Bristol Bay, Alaska, is home to a $2.2 billion annual salmon fishery that provides more than 15,000 jobs and supplies 50 percent of the world's sockeye salmon. But Bristol Bay is more than just home for the largest wild sockeye salmon runs in the world. It's also a lifeline for the people of Bristol Bay and all those who depend on its immense cultural and economic value. The science is clear. If built, Pebble Mine would permanently poison Bristol Bay's waters and imperil the greatest wild salmon fishery left on Earth. 

The majority of Alaskans and millions of Americans support EPA action to end the threat of Pebble. We want to see Bristol Bay protected for good. It's time for the EPA to expedite the 404(c) process and finalize protections this year. The EPA's action must protect several critical Bristol Bay subwatersheds: the North Fork Koktuli, South Fork Koktuli, and Upper Talarik Creek—all of which support the productivity of Bristol Bay's wild salmon and are under threat from Pebble and large-scale mines like it. 

I urge you to listen to the communities of Bristol Bay when shaping protections for this region. And I urge you to move swiftly and finish this process quickly. 

Please finish the job and ensure that Bristol Bay's pristine lands and waters are protected in perpetuity.

YOUR NAME HERE 

Learn More 

The movement for intersectional environmentalism advocates for both the protection of people and the planet while identifying ways in which injustices happening to marginalized communities and the earth, are interconnected. Human injustice takes the form of disproportionate impact due to natural disasters, exposure to pollution, and inadequate access to healthy food. Intersectional environmentalism argues that those who are least responsible for yet most impacted by climate change, deserve a voice in how humankind forms a more equitable relationship with our planet (learn more).

With more than a third of all man-made greenhouse gas emissions generated by food systems (source), solving earth's climate crisis is inextricably connected to fostering healthier and more resilient food supply chains. The natural products industry is largely tasked with finding solutions that rapidly transform and reduce the impacts of the food system. Research shows that dynamic, startup brands with a clear vision and an entrepreneurial mission committed to fulfilling an unmet need are best equipped to unlock market potential in the consumer packaged goods sector. These so-called “insurgent brands” have historically met changing consumer (and in some cases environmental) needs more quickly than major brands (learn more). Put more simply, to solve earth's climate crisis, the food system must change and creative startups are the companies most likely to find success fomenting this change. And yet the natural products industry where these startups thrive remains woefully non-representative and fundamentally lacking in intersectionality. A demographic study conducted by the Natural and Organic Industry Benchmarking Survey showed that while the movement for women in leadership positions has gained traction – with women now representing 43% of leadership positions and 32% of board positions - representation for non-white business leaders languishes far behind. Across ALL non-white demographics, business leaders represent a mere 16%; black and indigenous leaders having the least representation with a combined 3% share (source). Diverse leaders are less likely to access capital, trade, PR & media coverage and network access (source) which are all critical success factors for emerging brands. Diverse leaders are also more commonly victims of unethical business practices, purposeful exclusion from trade organizations, and perhaps most disturbingly, open and often shameless infringement of intellectual capital and brand ownership that goes without reprimand (example). 

It’s time for more than introspection. And it’s time that diversity and inclusion didn’t just mean diverse photographs for advertising or hiring low level staff people. Our constituency, the consumer, deserves more. Segmentation studies by New Hope suggest 27% of the natural and organic products market consumer base is made up of BIPOC people (source). As millennial and Gen Z purchasing power grows, so too will that share of the market. The most recent census reflects a rapidly diversifying America (source). Gen Z is expected to make up 20.2% of the US population by 2022, or 68.2 million tweens, teens, and young adults ages 9 to 24. As the third-largest cohort, Gen Z is the most racially, ethnically, and sexually diverse generation in history (source). They are also the most well-educated, and environmentally conscious (source), two demographic indeces with historically high engagement with natural, organic and specialty foods. We have seen a majority of demand from diverse and young audiences in the real world where Pescavore customers are looking for better, transparent and ethical options from real and diverse people, not corporations. Our inclusive approach is unlocking revenue and excitement in a sector that the seafood industry has historically struggled to engage (source). To expand consumer base while delivering product/market fit that unlocks new market opportunity - a representative body, and one with diverse leadership up the org chart, must be part of the fabric of the brand, the products, and the culture.

The natural products industry stakes its claim in creating a better world so it accordingly bears a responsibility to deliver equal access and opportunity to diverse leaders and intersectional brands. This access to opportunity should not only live only within separate trade organizations, comprised mostly or exclusively of BIPOC people. Brown vs. the Board of Education and other seminal cases from the Civil Rights movement have already taught us that separate is not equal. Leading from the front means integrated, diverse teams in gender, orientation, ethnicity, age, and professional background. To deliver its promise, leaders within the Natural Foods Industry including decision makers and those with the power to create the future must unlearn systematic racism, acknowledge disparity, and amplify BIPOC leaders. Not only is representation and inclusion rational and just, it also delivers the types of dividends that are essential to maximizing value and profits (source):

Fish stocks play a vital role in food security, providing nutrition and a source of income for billions of people. The livelihoods of 10-12 percent of the world’s population – that’s over 870 million people – depend on fisheries and aquaculture. And over three billion people worldwide rely on food from the ocean as a significant source of animal protein. Accordingly, fisheries are a pillar of the global economy (source). With important nutrients such as protein, omega-3s, selenium, vitamin B-12, vitamin D and other vitamins and minerals, global health authorities agree that seafood consumption is important for optimal health during all life stages (source, source, source). However, as our population continues to grow, how do we ensure wild-caught and farmed seafood can keep up with demand, without destroying our planet?

A FRAMEWORK FOR "SUSTAINABLE SEAFOOD" DECADES IN THE MAKING

'Sustainable development' as we understand it today appeared for the first time in 1987 in the famous Brundtland Report (also entitled 'Our Common Future') produced by several countries for the UN that identified a need to study the impact of human activity on the environment (source, source). While the term was first used in the report, efforts around the world date to some years earlier. For instance, here in the United States, the Magnuson-Stevens Fishery Conservation and Management Act (MSA) is the backbone of our sustainable fisheries. It was first passed in 1976 and "fosters the long-term biological and economic sustainability of marine fisheries" (source). Its objectives include:

• Preventing overfishing.
• Rebuilding overfished stocks.
• Increasing long-term economic and social benefits.
• Ensuring a safe and sustainable supply of seafood.

Prior to 1976, international waters began at just 12 miles from shore and were fished by unregulated, foreign fleets. The MSA extended U.S. jurisdiction to 200 nautical miles and established eight regional fishery management councils with representation from the coastal states and fishery stakeholders. Since the Sustainable Fisheries Act amendment in 1996 (and with another important amendment in 2006), the MSA has driven the rebuilding of U.S. stocks. U.S. fisheries management is a transparent and public process of science, management, innovation, and collaboration with the fishing industry (source). The model for the MSA is a success; by weight, roughly 99% of American wild-caught seafood is sustainable (source). The U.S. is a global leader in fishery sustainability and has created a proven and actionable model for adoption and enforcement in other geographies. 

Beyond the United States, the United Nations 2030 Agenda for Sustainable Development, adopted by all United Nations Member States in 2015, provides a shared blueprint for peace and prosperity for people and the planet, now and into the future (source). SDG 14 (life below water) frames the objectives to conserve and sustainably use the ocean, seas and marine resources for sustainable development. Biodiversity, control of acidification and pollution are all addressed within the collaborative framework (learn more here). 

THE ROLE OF NON-GOVERNMENTAL ORGANIZATIONS IN MEETING CONSERVATION OBJECTIVES 

Non-governmental organizations (NGOs) are non-profit groups that function independently of any government. Sometimes called civil societies, they are organized on community, national and international levels to serve a social or political goal such as humanitarian causes or the environment. Famous NGOs include Greenpeace and the World Wildlife Fund. It is important to understand that NGOs are approved by the Internal Revenue Service as tax-exempt, 501c3 charitable organizations; they are not for-profit corporations and are subject to strict compliance with applicable tax codes (source). 

Following the passing of the MSA, sustainable seafood focused NGOs formed to further the objectives and responsible fisheries management policies more globally. For instance, in April 1978 a group of marine scientists, local residents and members of the David and Lucile Packard Foundation of Los Altos, California, formed the Monterey Bay Aquarium Foundation (source). To the present day, sustainable seafood NGOS, such as Seafood Watch, the Conservation Alliance for Seafood Solutions, the Marine Stewardship Council, the Aquaculture Stewardship Council, FishChoice, FishWise, OceanWise, Oceana and many more provide an important bridge between the environmental community (who are sometimes perceived as opponents) and the seafood industry. Sustainable seafood NGOS have a history of being the first to alert the public to matters of social importance (example, example). And they don't always agree, openly debating issues and challenging one other's policies and perspectives, in a healthy and constructive manner (example). Despite the recent unfounded spate of disparagement and accusations in the Seaspiracy docudrama, sustainable seafood NGOs are fundamental allies in the fight for our ocean and can credibly stand on a 40+ year track record of transparently (and not for profit) investing in human capital and the public good.

 HOW IS SUSTAINABLE SEAFOOD DEFINED? 

The science behind environmental sustainability is quite comprehensive and generally agreed upon. The framework helps ensure that seafood is produced in a way that promotes the long-term well-being of wildlife and our environment. Let’s start with defining sustainability in wild capture fisheries.

WILD SEAFOOD: THE LAST WILD HUNT ON OUR PLANET

Remarkably, seafood is the last wild hunt on our planet for food at a commercial scale. Sir David Attenborough accurately summarized this in A Life On Our Planet, “…fishing is the world’s greatest wild harvest and if we do it right, it can continue because there is a win-win at play. The healthier the marine habitat, the more fish there will be and the more there will be to eat.” 

 Here is a quick overview of the criteria scientists at the Monterey Bay Aquarium Seafood Watch Program use to understand the environmental impact of seafood.

• Impacts on the Stock: the condition of the target fish population being assessed and if any overfishing is occurring.
• Impacts on Other Capture Species: the fishery’s impacts on other fish and animals that are caught or used for bait.
• Impacts on the Habitat and Ecosystem: the fishery’s impact on the seafloor and food web.
• Management Effectiveness: the efforts to understand and minimize the fishery’s impact on marine life.

AQUACULTURE: THE FASTEST GROWING SECTOR OF FOOD PRODUCTION GLOBALLY

While agriculture is farming on land, aquaculture is farming in the water (that can be done in land based tanks or in natural water features) and it’s a booming industry around the world that is helping us meet our growing global demand for seafood. Below are the key components researched when figuring out the environmental impact of aquaculture.

• Data Availability and Quality: the quality of published information about the farm’s impact on the environment.
• Effluent: the impact of farm waste that is released into the environment.
• Habitat: the impact a farm’s location or amount of production has on natural habitats, such as mangroves or wetlands.
• Chemical Use: the environmental impact of antibiotics and other chemicals released by the farm.
• Feed: the amount of wild fish and other sources of protein used to feed the farmed fish.
• Escapes and Introduced Species: the number of farmed fish that escape and their impact on the environment.
• Pathogens and parasite interactions: the impact of disease that spreads from farmed fish to wild populations.
• Source of Stock - Independence from wild capture fisheries: the amount of wild eggs or young fish used to support farmed fish.
• Predator and wildlife mortalities: the impact on wildlife populations that prey on farmed fish.
• Escape of unintentionally introduced species: the possibility that other non-native species, including pathogens and parasites, could be released into the environment.

EVERY SEAFOOD PRODUCT HAS A STORY TO TELL

“From small family-run shrimp farms in Vietnam to large tuna fishing fleets off the Atlantic coast, every seafood product has a story to tell. Knowing the details of how and where your seafood is harvested is key to protecting our ocean and ensuring a long-term supply of seafood” (source). Species, location and method play a big role in influencing these sustainability ratings. Some fishing and farming methods are better than others. For example, some fishing methods like pole and line or handlines are a more selective fishing method which result in less accidental catch of other species. Purse seine boats fishing for tuna can greatly reduce their bycatch by not using Fish Aggregating Devices, also known as being “unassociated” or “FAD-free” tuna. Seaweed and bivalves like clams, mussels, oysters and scallops are one of the most sustainably farmed species as all they require is raw seawater to grow. Recirculating Aquaculture Systems (RAS), aka land-based tanks, is also a growing method of aquaculture as it addresses many environmental concerns associated with open water net pens in addition to other improvements being made.

Using science backed guidance to establish standards and evaluate how every commercially relevant seafood source compares against the standard, Seafood Watch has over 2,000 seafood recommendations. A simple to follow model of: Best Choice, Certified, Good Alternative, and Avoid can help you to quickly filter your purchases by navigating to this phone or computer friendly database: here. Currently over 200 choices are rated as a green Best Choice. This is over 200 examples of a vast array of commercial seafood options that are transparently environmentally sustainable.

MAJOR ACCOMPLISHMENTS OF THE SUSTAINABLE SEAFOOD MOVEMENT

Today, seafood sustainability is an integral part of doing business. Supermarket chains have increasingly embraced the movement, prompted not only by consumer demand but by the growing realization that supply could be in jeopardy. By 2014, all but three of the top 20 grocery retailers in North America were working with NGOs that advocate for sustainable seafood. As of the present date, 90 percent of grocery stores in North America have made some form of seafood sustainability commitments and thousands of businesses have formed partnerships with conservation organizations (source, source). In particular the Conservation Alliance for Seafood Solutions is an official global community of stakeholders working together to continue to improve the sustainability and responsibility of seafood supply chains for our ocean and the people who depend on it.

Your seafood choices also matter, and when you use the power of the dollar to purchase sustainable seafood, you push suppliers to source more environmentally responsible products, driving significant improvements throughout the value chain.

IT’S MORE THAN JUST FISH

Sustainability’s definition is evolving and no longer solely focuses on environmentalism, but also social responsibility and economic justice. To be truly sustainable, social considerations such as safe working conditions and fair wages are also fundamentally important as are protections against modern slavery and hazardous child labor conditions. Learn more about the NGO FishWise’s roadmap for improving seafood ethics through the RISE initiative here.

THE IMPORTANCE OF LOCAL

We are very fortunate in America to have strong, science-based regulations in place to help prevent environmental impacts like overfishing and bycatch. As mentioned, the combined effects of the Magnuson Stevens Act, collaboration of NGOs and adoption of transparent Corporate Social Responsibility by supply chain participants has led to 99% of all seafood caught in US waters being sustainable (source). Despite the US having the second largest Exclusive Economic Zone in the world (source) and having easy access to sustainable fisheries, over 90% of the seafood consumed in the US is imported, with a trade deficit that has grown to over $11.2 billion annually (source). The main imported species are shrimp, salmon, crab and white fish and imports in this total include seafood caught in the US and processed abroad before being reimported for consumption (source).  This strategy has a large carbon footprint, introduces opportunities for fraud and economically harms US fisherman who must share profits with receivers abroad (source). On top of competing with cheaper foreign imports, American fishermen often are also bearing the cost firsthand to be more sustainable, such as the investment in new gear to reduce bycatch, the cost of individual fishing quotas and the financing of on-board observers like in the West Coast groundfish fishery.

Thousands of US commercial fishers, many of them third- or fourth-generation, also risk bankruptcy in the face of the pandemic with many of the nation’s fisheries — across geography, species, gear types and management reporting sales slumps as high as 95 percent (source). Socially just and resilient societies must equally protect people and planet. Businesses and consumers can help by choosing local U.S. seafood and refrain from spreading myths about the industry and the availability of sustainable and responsible sources of seafood.

In closing, scientists, social justice experts, policy makers, conservationists, businesses, and the seafood industry continue to work hard to make improvements in the production of our seafood. Everyday consumers and businesses can vote with their dollars to support the movement for our ocean.

Peter Adame is the former Outreach Manager of the Monterey Bay Aquarium Seafood Watch program and spent several years supporting the Global Seafood Ratings Alliance. He’s now the Communications & Sustainability Manager at Lusamerica Foods, a major West Coast wholesaler, processor and distributor.