Dear Chairman Grijalva and Ranking Member Westerman:
On behalf of the U.S. fishing and seafood sector participants we represent, we write in
opposition to Chairman Grijalva’s Amendment in the Nature of Substitute to H.R. 4690, which is
the subject of a Committee mark-up on September 21 and would reauthorize the Magnuson-
Stevens Fishery Conservation and Management Act (MSA).
The remarkable success of the MSA has put the United States at the global forefront of science-based fishery management. U.S. fisheries achieve exceptional environmental outcomes, deliver nutritious food to consumers, preserve vital cultural traditions, and create jobs in communities throughout the supply chain and across the entire United States. We are deeply concerned that your legislation would put that proud record of success at risk.
opposition to Chairman Grijalva’s Amendment in the Nature of Substitute to H.R. 4690, which is
the subject of a Committee mark-up on September 21 and would reauthorize the Magnuson-
Stevens Fishery Conservation and Management Act (MSA).
The remarkable success of the MSA has put the United States at the global forefront of science-based fishery management. U.S. fisheries achieve exceptional environmental outcomes, deliver nutritious food to consumers, preserve vital cultural traditions, and create jobs in communities throughout the supply chain and across the entire United States. We are deeply concerned that your legislation would put that proud record of success at risk.
During a legislative hearing on H.R. 4690 held last November, detailed testimony was presented by expert witnesses about sections of H.R. 4690 that raise alarms for fishery managers and participants. Unfortunately, those detailed and specific concerns appear to have been ignored.
As a result, the legislation that will come before the House Committee on Natural Resources tomorrow, if enacted, will unquestionably throw the U.S. fishing and seafood sector into chaos.
Sustainable federal fisheries will be curtailed or shut down entirely. Waves of opportunistic litigation will create uncertainty. Seafood sector workers, including in remote coastal communities, will lose their jobs. Seafood buyers will run short on domestic inventory and be forced to procure more product from foreign sources. American consumers will see seafood prices spike at their local restaurants and grocery stores, and they will turn to less nutritious food options and proteins with far higher carbon footprints than wild seafood.
For example, with very limited exceptions bycatch is a reality in every commercial and recreational fishery. In accordance with National Standard 9, managers and fishery participants go to great lengths to minimize bycatch to the extent practicable, while striking a balance with other vital MSA objectives. A mandate to absolutely minimize bycatch in all circumstances, however, as your legislation requires, could very well lead to managers or the courts shutting down fisheries where bycatch cannot be eliminated. Similarly, some of our nation’s biggest fisheries would meet the definition of forage fish in your legislation, needlessly requiring strict new limitations on directed fishing.
No less troubling is the language on Essential Fish Habitat (EFH), with new requirements that would absolutely minimize habitat alteration, regardless of impact, connected to federal fisheries. H.R. 4690 goes to the extreme by requiring Regional Fishery Management Councils to increase the quality, quantity and representativeness of EFH—requirements that far exceed Council capacity and will further expose the management system to litigation.
Combined with other provisions that would weaken Council authority and flexibility, these legislative changes would be catastrophic for sustainable domestic food production and the millions of Americans who rely on U.S. fisheries for jobs and income, economic security, and affordable protein.
All of us recognize the solemn obligation that we have to sustain healthy fisheries and marine ecosystems for the benefit of this and future generations. Indeed, overfishing and marine ecosystem decline are direct threats to the survival of fishing businesses and the long-term health of many coastal communities. It is critical to understand, however, that these objectives are being achieved under the existing science-based and collaborative management system created by the MSA. Over the last two decades, instances of overfishing have sharply declined, previously-overfished species have recovered to healthy levels, and ecosystem-based fisheries management has improved outcomes for broader marine ecosystem health. These are successes to be celebrated and built upon, not undermined through ill-advised changes in federal law.
Throughout its nearly fifty-year history, collaboration and consensus-building has been at the heart of the Magnuson-Stevens Act’s success. The law was written, and has twice been reauthorized, by broad bipartisan coalitions in Congress. Through the eight Regional Fishery Management Councils, commercial, recreational, subsistence and environmental stakeholders have worked cooperatively to implement the law. While we appreciate that Chairman Huffman initially sought a broad range of input through regional listening sessions and other mechanisms when starting to develop this reauthorization bill, we are disappointed and concerned that H.R. 4690 is now moving forward as a partisan bill with only narrow stakeholder support and exceedingly little time to analyze the ramifications of the latest revisions in the substitute amendment.
Rather than proceeding to mark-up of this legislation, we respectfully request that you pause the Committee process and return to and review the detailed concerns that have been raised by stakeholders through testimony and direct submissions.
Thank you for your consideration of our perspectives,
Sincerely,
Julie Bonney
Executive Director
Alaska Groundfish Data Bank
Rebecca Skinner
Executive Director
Alaska Whitefish Trawlers Association
Alan Alward
Co-Chair
Alliance of Communities for Sustainable
Fisheries
Tim Thomas
President
American Albacore Fishing Association
John Whiteside
General Counsel
American Scallop Association
James Budi
Executive Director
American Sword and Tuna Harvesters
William Gibbons-Fly
Executive Director
American Tunaboat Association
Luke Fanning
Chief Executive Officer
Aleutian Pribilof Island Community
Development Association
Stephanie Madsen
Executive Director
At-sea Processors Association
Martin T. Scanlon
President
Blue Water Fishermen’s Association
Robin Samuelsen
Board President
Bristol Bay Economic Development
Corporation
Rob Ross
Executive Director
California Fisheries and Seafood Institute
Mark Fina
Executive Director
California Wefish Producers Association
Eric Deakin
Chief Executive Officer
Coastal Villages Region Fund
Marjorie Orman
Executive Director
The Fisheries Survival Fund
Captain Bill Kelly
Executive Director
Florida Keys Commercial Fishermen’s
Association
Scot Mackey
Executive Director
Garden State Seafood Association
Chris Woodley
Executive Director
Groundfish Forum
Eric K. Kingma
Executive Director
Hawaii Longline Association
Bonnie Brady
Executive Director
Long Island Commercial Fishing Association
Acy Cooper
President
Louisiana Shrimp Association
Annie Tselikis
Executive Director
Maine Lobster Dealers’ Association
Heather Munro Mann
Executive Director
Midwater Trawlers Cooperative
Tom Hafer
President
Morro Bay Commercial Fishermen’s
Organization
Captain Robert F. Zales, II
President
National Assoc. of Charterboat Operators
Glenn Skinner
Executive Director
North Carolina Fisheries Association
Jackie Odell
Executive Director
Northeast Seafood Coalition
Jerry Sansom
Executive Director
Organized Fishermen of Florida
Dan Waldeck
Executive Director
Pacific Whiting Conservation Cooperative
Bob Kehoe
Executive Director
Purse Seine Vessel Owners Association
Sarah Bates
Treasurer
San Francisco Crab Boat Owners
Association
Bob Vanasse
Executive Director
Saving Seafood
Leigh Habegger
Executive Director
Seafood Harvesters of America
Kathy Hansen
Executive Director
Southeast Alaska Fishermen’s Alliance
Captain Robert F. Zales, II
Fishery Management Consultant
Southern Offshore Fishing Association
Tony Lombardi
President
Southeastern Fisheries Association
John Williams
Executive Director
Southern Shrimp Alliance
Brent Paine
Executive Director
United Catcher Boats
Lori Steele
Executive Director
West Coast Seafood Processors Association
Wayne Heikkila
Executive Director
Western Fishboat Owners Association
Ragnar Alstrom
Executive Director
Yukon Delta Fisheries Development
Association
F/V Aiden & Sadie (Chebeague Island, ME)
F/V Alaskan (Kodiak, AK)
All Lynn LLC (Marmora, NJ)
Ariel Seafoods of Florida, Inc. (Destin, FL)
Atlantic Capes Fisheries, Inc. (Cape May, NJ)
Bay Islander Fisheries (Newport, OR)
BJ’s Service Company, Inc.
(New Bedford, MA)
Blue Water Fisheries, Inc. (Montauk, NY)
Bob Zales Charters, LLC (Panama City, FL)
Bohica Fishing, Inc. (Crystal River, FL)
Boston Sword and Tuna (Boston, MA)
F/V Caitlin & Mairead (Montauk, NY)
Caito Fisheries, Inc. (Fort Bragg, CA)
Cal Marine Fish Company, LLC
(San Pedro, CA)
California Shellfish Co., Inc.
(San Francisco, CA)
Cape Canaveral Shrimp Company
(Titusville, FL)
Chandler Fisheries (Kodiak, AK)
Charles Bergmann, Fisheries Consultant
(Vancleave, MS)
Chellissa Fisheries, LLC (Kodiak, AK)
Coastline Seafood (Hampton, NH)
F/V Challenger (Homer, AK)
F/V Collier Brothers (Kodiak, AK)
Compass Insurance Solutions, LLC
(Norfolk, VA)
Coonamessett Farm (East Falmouth, MA)
Cory Dehning, Commercial Fisherman
(Kodiak, AK)
Debra Ann Corp. (Gouldsboro, ME)
Del Mar Seafoods, Inc (Watsonville, CA)
Directed Sustainable Fisheries, Inc.
(Daytona Beach, FL)
Dixie Crossroads Seafood Restaurant
(Titusville, FL)
Eagle Eye Fishing Co. (Marshfield, MA)
Englund Marine & Industrial Supply
(Astoria, OR)
F/V Eileen (Orange, CA)
F/V Evie Grace (Kodiak, AK)
Fish for America USA, Inc. (Steinhatchee, FL)
Fish-Net USA (New Smyrna Beach, FL)
Foley Fish (New Bedford, MA)
Fosmark Fisheries, LLC (Carmel, CA)
F/V Gold Rush Fisheries LLC (Clackamas, OR)
Greg Abrams Seafood (Panama City, FL)
Hallmark Fisheries (Charleston, OR)
Haworth Fishing (San Diego, CA)
Healthy Oceans Seafood Company (Santa Cruz, CA)
Hunt’s Oyster Bar (Panama City, FL)
Hunter Scalloping Company
(New Bedford, MA)
Hull’s Seafood Market & Restaurant
(Ormond Beach, FL)
Inlet Fisheries, Inc. (Fort Pierce, FL)
John Nagle Co. (Boston, MA)
Jolly Rogers II Fisheries (Steinhatchee, FL)
JPR Group (Staten Island, NY)
F/V Kanaloa (Tacoma, WA)
Kathryn Marie Scalloping Company
(New Bedford, MA)
Key Largo Fisheries (Key Largo, FL)
King’s Seafood (Port Orange, FL)
F/V Lady Lil (Jonesport, ME)
Law Offices of Clayton Wraith
(Nashville, TN)
F/V Leo Too (Panama City, FL)
Lindsay L Inc. (Barnegat Light, NJ)
Long Island Sound Seafood (Mattituck, NY)
Lund’s Fisheries, Inc. (Cape May, NJ)
Mar-sea inc. (Mattituck, NY)
Marcus Food Company, Fisheries Division
(Wichita, KS)
F/V Mojo (Wrangell, AK)
Monterey Fish Company Inc. (Salinas, CA)
Nantucket Sound Seafood
(New Bedford, MA)
F/V Njord (Brookings, OR)
F/V North Star (Davisville, RI)
Northeast Fishery Sector X
(Dartmouth, MA)
Northeast Fishery Sector XIII
(Dartmouth, MA)
Northern Seiners, Inc. (Kodiak, AK)
OBI Seafoods LLC (Seattle, WA)
F/V Ocean Angel (Watsonville, CA)
Ocean Fleet Services (Suffolk, VA)
Ocean Harvesters (Suffolk, VA)
Ocean Peace (Seattle, WA)
Ocean Trawlers (Suffolk, VA)
Offshore Fishery, Inc. (Montauk, NY)
O’Hara Corporation (Rockland, ME)
F/V Ole Greeley (Orr’s Island, ME)
Omega Protein (Reedville, VA)
F/V Pacific Star (Kodiak, AK)
Patrick J Fehily LLC (Lavallette, NJ)
Panama City Boatmen Association
(Panama City, FL)
F/V Persistence (Davisville, RI)
Plymouth Bay Lobster Co, LLC
(Plymouth, MA)
Point Adams Packing Company
(Hammond, OR)
F/V Prevail (Davisville, RI)
Providence Fisheries, Inc.
(Hampton Bays, NY)
Raffield Fisheries, Inc (Port St Joe, FL)
Raven Enterprises (Newport, OR)
Ravn Fishing (Palo Alto, CA)
F/V Relentless (Davisville, RI)
SAI Fisheries Inc. (New Bedford, MA)
Sea Watch International, Ltd.
(New Bedford, MA)
F/V Seadawn (Newport, OR)
Seafreeze Ltd. (North Kingstown, RI)
Seafreeze Shoreside (Narragansett, RI)
Seminole Wind Charters (Panama City, FL)
F/V Spirit of ’76, Inc. (Crescent City, CA)
Sun Coast Calamari (Oxnard, CA)
Surfside Foods, LLC (Port Norris, NJ)
Hunt’s Oyster Bar (Panama City, FL)
Hunter Scalloping Company
(New Bedford, MA)
Hull’s Seafood Market & Restaurant
(Ormond Beach, FL)
Inlet Fisheries, Inc. (Fort Pierce, FL)
John Nagle Co. (Boston, MA)
Jolly Rogers II Fisheries (Steinhatchee, FL)
JPR Group (Staten Island, NY)
F/V Kanaloa (Tacoma, WA)
Kathryn Marie Scalloping Company
(New Bedford, MA)
Key Largo Fisheries (Key Largo, FL)
King’s Seafood (Port Orange, FL)
F/V Lady Lil (Jonesport, ME)
Law Offices of Clayton Wraith
(Nashville, TN)
F/V Leo Too (Panama City, FL)
Lindsay L Inc. (Barnegat Light, NJ)
Long Island Sound Seafood (Mattituck, NY)
Lund’s Fisheries, Inc. (Cape May, NJ)
Mar-sea inc. (Mattituck, NY)
Marcus Food Company, Fisheries Division
(Wichita, KS)
F/V Mojo (Wrangell, AK)
Monterey Fish Company Inc. (Salinas, CA)
Nantucket Sound Seafood
(New Bedford, MA)
F/V Njord (Brookings, OR)
F/V North Star (Davisville, RI)
Northeast Fishery Sector X
(Dartmouth, MA)
Northeast Fishery Sector XIII
(Dartmouth, MA)
Northern Seiners, Inc. (Kodiak, AK)
OBI Seafoods LLC (Seattle, WA)
F/V Ocean Angel (Watsonville, CA)
Ocean Fleet Services (Suffolk, VA)
Ocean Harvesters (Suffolk, VA)
Ocean Peace (Seattle, WA)
Ocean Trawlers (Suffolk, VA)
Offshore Fishery, Inc. (Montauk, NY)
O’Hara Corporation (Rockland, ME)
F/V Ole Greeley (Orr’s Island, ME)
Omega Protein (Reedville, VA)
F/V Pacific Star (Kodiak, AK)
Patrick J Fehily LLC (Lavallette, NJ)
Panama City Boatmen Association
(Panama City, FL)
F/V Persistence (Davisville, RI)
Plymouth Bay Lobster Co, LLC
(Plymouth, MA)
Point Adams Packing Company
(Hammond, OR)
F/V Prevail (Davisville, RI)
Providence Fisheries, Inc.
(Hampton Bays, NY)
Raffield Fisheries, Inc (Port St Joe, FL)
Raven Enterprises (Newport, OR)
Ravn Fishing (Palo Alto, CA)
F/V Relentless (Davisville, RI)
SAI Fisheries Inc. (New Bedford, MA)
Sea Watch International, Ltd.
(New Bedford, MA)
F/V Seadawn (Newport, OR)
Seafreeze Ltd. (North Kingstown, RI)
Seafreeze Shoreside (Narragansett, RI)
Seminole Wind Charters (Panama City, FL)
F/V Spirit of ’76, Inc. (Crescent City, CA)
Sun Coast Calamari (Oxnard, CA)
Surfside Foods, LLC (Port Norris, NJ)