Seafood Harvesters of America: Letter to Secretary Wilbur Ross

March 31, 2017The Honorable Wilbur RossSecretary U.S. Department of Commerce1401 Constitution Ave NWWashington, DC 20230Secretary Ross,On behalf of the Seafood Harvesters of America, we welcome your leadership of the Commerce Department and look forward to working with you to ensure our nation has a sustainable, stable and safe supply of seafood.The United States has one of the most successful fishery management systems in the world with almost 500 federally managed stocks producing almost 10 billion pounds of seafood valued at over $5 billion annually. Our members are privileged to go to sea every day from coast to coast to bring to market healthy, domestic, sustainable seafood. We honor, depend upon and live with accountability in our fisheries and transparency in the regulatory process.Through the accountability standards and conservation mandates in the Magnuson-Stevens Act (MSA), our fisheries have improved dramatically as the commercial fishing industry has become more responsible, transparent and efficient. Where implemented, catch share programs have ended the race to fish and enabled more flexible harvesting. This allows for more complete yields of target species, which reduces bycatch and discards, avoiding catch of prohibited species.   It is within these sustainably managed fisheries that we encourage the Administration to focus its regulatory reform efforts to acknowledge, reward and incentivize success through market-based solutions. This can facilitate the innovation of new fishing gear to further reduce habitat damage and bycatch.Despite successes in many fisheries, scientific and management uncertainty elsewhere has impeded sustainable harvesting practices and led to unwarranted conflict. You recently testified that one of your top three challenges was “integrating technology into the Department to improve efficiency as well as the timeliness, depth and breadth of data…” We believe that the modernization and streamlining of fishery information systems is critical to provide more timely science for better management decisions. Unfortunately, existing systems are built using technology and practices that are outdated, slow, incomplete, expensive and often inaccurate. Relying on pen and paper to track billions of fish is obviously antiquated and results in management uncertainty and economic inefficiencies. We look forward to working with you to innovate and implement electronic monitoring and electronic reporting of real-time catch data for both the commercial and recreational sectors.Because we depend upon access to the sea for our livelihoods, decisions to reduce quotas or restrict fishing are always contentious. However, we willfully engage in the MSA process and abide by the decisions made through the regional councils, which have effectively prevented overfishing, rebuilt dozens of fish stocks and provided greater regulatory and economic certainty for our industry. MSA allows for identification of Essential Fish Habitat (EFH) and regulatory mechanisms for preventing fishing in areas designated as essential. We prefer utilizing the MSA management regime that incorporates the best science available, engages all stakeholders and is transparent. Consequently, we encourage the Administration to revisit the national monument designation process that unnecessarily takes fishermen off the water across vast stretches of traditional fishing grounds, threatening local economies, increasing our seafood deficit, and ignoring the federal fishery management process.Our harvesters work in some of the most harsh and dangerous environments and leave the dock each day not knowing for sure if they will return to their loved ones. Consequently, safety is of the utmost importance for our industry and we greatly appreciate the support of the Coast Guard in protecting our men and women through reasonable safety standards. However, our fishing fleet is aging and thus less safe than ideal. We desperately require access to finances to recapitalize our fishing fleet and encourage you to facilitate recapitalization through NOAA’s Fishing Finance Program or other mechanisms as the Administration invests in the nation’s infrastructure.With regards to trade policy, we ask that you help level the playing field for American harvesters. Illegal, Unreported and Unregulated (IUU) fishing is a multi-billion dollar scourge on our industry; to the extent that one in every five fish sold is caught illegally. This problem is geographically dispersed from foreign poachers in the Gulf of Mexico to illegal Russian crabs entering our marketplace from the Bering Sea. We ask you to champion fair trade standards and implement policies such as NOAA’s seafood traceability rule to ensure that we can compete fairly in the global marketplace.Finally, we need to ensure that at-sea fish surveys, fishery stock assessments, and cooperative research continue to be a priority throughout the budget process. This is the fundamental basis for which our fisheries are managed and require consistent, sustainable funding to ensure that we are harvesting robustly and sustainably. The return on investment for these funds is overwhelming as the National Marine Fisheries Service (NMFS) estimates that rebuilding all U.S. fish populations to healthy levels would deliver taxpayers an additional $31 billion in annual sales and support 500,000 new American jobs.We greatly appreciate the opportunity to work with you on these and other matters affecting the commercial fishing industry, which provides essential economic benefits for coastal communities and nutritious seafood for Americans across the nation.Sincerely,Chris Brown, PresidentKevin Wheeler, Executive Director