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February NPFMC Meeting Update

from Marissa Wilson


The North Pacific Fishery Management Council meeting in Seattle opened with a multi-day workshop on climate change. A group of marine scientists and economists hosted this conversation and were greeted with robust public engagement and participation. Thrilled to hear more about biological phenomena I’ve come to know through this work and grateful to hear participants speak to the need for increased interdisciplinary collaboration, I ultimately left unsettled. Some experts of western philosophies described the inevitability of winners and losers in our future of climate variability.

The idea of “winners and losers'' is an outcome of human design. In the ten-block walk from AMCC’s rental to the meeting location of people in power, I passed by a dozen unhoused people attempting to sleep on open sidewalks: winners and losers, according to a capitalist economy. The phrase has been haunting me, prompting questions. How do we talk about the complexity of relationships, of interconnectedness? How do we address the gaping wound of inequity in such a construct? What components of status quo must be dismantled to get there?

The primary focus for AMCC at this meeting was the culmination of a five-year review of Essential Fish Habitat, or EFH. EFH is defined as 95% of the range of a species, and is considered on a species-by-species basis for those species with “Fishery Management Plans” which primarily consist of groundfish (though not halibut) plus some others. It gets more convoluted from there: more than 850 pages of analyses and summaries were honed by Stock Authors and Advisory Bodies for years before the meeting, then finalized and posted weeks before the meeting began. Within them, the conclusion was drawn that the effects of fishing effort on habitat – 97% of which comes from trawling – had no adverse impacts to EFH that were “more than minimal and temporary in nature.”

As expected, a lot goes into that determination. Models are used to estimate the prevalence of habitat features, and equations help graph expected recovery for impacted features on the seafloor like sand waves and sea sponges. Sixteen species under consideration had more than 10% of their core habitat disturbed, and nine were flagged for having insufficient information to know whether alarm bells should be rung. Within those nine were the red king crab and snow crab of the Bering Sea. But the experts of western science who were consulted found that, within the construct of Essential Fish Habitat considerations, nothing was especially wrong with the species of their specific focus.

Since implementation of EFH on a national level some twenty years ago, no adverse impacts from fishing have ever been determined. The living, interconnected world outside this modeled reality indicates otherwise.

While there are admirable ongoing efforts to collect more data on the ecosystem we are stewarding, and some components of the modeling will be updated for the next five-year review, there were no foundational changes that addressed glaring gaps: there was no consideration of core areas of habitat with high disturbance for multiple species. There was no greater emphasis placed on species in decline, such as Bering Sea crab or Chinook salmon. There was no move to address the impacts of surveys conducted with bottom trawl gear. One consistent advocate within EFH reviews, Oceana, has mapped the fishing effects of all species together to get the most cohesive look at how habitat, in totality of functionality, might be faring. The results were described as a food desert, with sea “vegetables” valuable as food and shelter scrubbed from the seafloor by trawl gear. Slow-growing sea whips, akin to groves of old-growth trees, are estimated in EFH modeling to be as resilient as sea anemones. When Oceana presented this finding to the Council last year, nothing changed.

One of the Council’s Advisory Bodies, however, heeded the calls of public testifiers at this meeting. A small handful of people who have had the bandwidth to follow the process made a compelling case, supported by the legislation guiding the NPFMC, to seek proposals from the public to conserve and enhance EFH – especially considering the lack of accessibility for engagement of experts with non-western ways of knowing.

Responsive to the previous days’ workshop and public testimony, in an inspiring example of functional public process, the Advisory Panel passed a motion recommending the Council request proposals related to climate-sensitive species, impacted areas important to fishery-dependent communities, and habitats of particular concern.

Defenders of status quo characterized this ask as a gear war.

Again I found myself confounded by the seemingly effective injection of a social construct rooted in a competition framework over majority support for a holistic and inclusive approach. Questions kept whirring in my mind: what are the connections between trawl gear and warfare? Who is winning and who is losing, and who defines the rules of such a game? How do we address the gaping wound of inequity?

The Council did not adopt the Advisory Panel’s recommendation, citing the existing burdens on staff time. They emphasized that the public process is open, and the public is welcome to bring ideas forward anytime.

Our asks, questions and concerns about Essential Fish Habitat remain unaddressed - you can read AMCC’s testimony to the Council below - but rest assured, we will continue working with you to create a more just and healthful future.

Good afternoon Chairman Kinneen and Council members. For the record, my name is Marissa Wilson and I am the Executive Director of the Alaska Marine Conservation Council.

AMCC supports the AP motion requesting the Council initiate a request for proposals to conserve and enhance habitat. This motion recognizes the incredible work that has been invested in the 5-year review, and while we also appreciate that there are updates to the EFH construct that should be incorporated into the next review cycle, there is information here that can be referenced in proposals from the public to inform meaningful next steps for conservation of habitat, pursuant with components six and eight.

As this discussion has unfurled, I have heard many references to the number of meetings on EFH review that has led to this moment. But there is a big difference between something being open and something being accessible. The balcony on the 20th floor of AMCC’s rental downtown is open, but it is not accessible. The EFH review, a remarkable process done largely through the Stock Authors and SSC - bodies which are framed by the language and philosophies of westernism - is not approachable from a practical standpoint for many fishery participants. The AP heard this in public testimony and responded accordingly.

A sign of accessibility would show up in analysis. A quick search in the papers posted for this agenda item of key terms including LKTK, consultation and more only produced references to consultation with Stock Authors and other agencies. “Traditional dependence” was referenced only in the document on non-fishing effects, suggesting by omission that climate change fuels challenges to traditional lifeways at an ecosystem level, but not fishing effects. In practice, localized impacts from fishing effects also affect traditional lifeways and accessibility of fishing grounds. The EFH construct is designed to look at impacts to species-wide population distributions, not local habitat disturbances. The AP motion recognizes this. I appreciate that the AP’s motion elevated the Ecosystem Committee’s recognition of the ongoing work of the Climate Change Task Force, particularly as it incorporates LK/TK, as referenced in the SSC report yesterday, but it is worth noting that the Climate Change Task Force is limited in focus to the Bering Sea.

Regarding the AP’s three recommended sections for proposals, those sections brought forward by the public were informed largely by extensive and ongoing engagement with the EFH process from those of us who are privileged to be paid to follow and engage in this work. Those recommendations recognize some of the limitations of the current EFH process beyond more straightforward revisions or additions. Addressing ecosystem concerns proactively, though it certainly will require effort up front, will help prevent issues later. EFH is also the only agenda item the Council regularly reviews that explicitly addresses habitat, and is the appropriate item to bring these proposals forward through. Without a clear indication from the Council that it is receptive to proposals, particularly given the amount of discussion about capacity, the public will not have faith that their efforts will be worthwhile.

This is a time we can offer much-needed preventative care to the ecosystem we steward, and what better way than to invite holders of local and traditional knowledge to access this suite of analyses.

The intersection of climate change, which is framed as non-fishing effects on EFH, and fishing effects begs the question: recognizing that habitat and biodiversity are inextricably linked, are there habitat functionalities that are at risk which deserve greater care and consideration? Can fishing effects exacerbate the effects of climate change? Yes, fish may well be present in areas of high disturbance, but what if their presence is a consequence and indicator of disturbance? Are unchanged behaviors cultivating some species over others?

I was excited to hear at a presentation to the SSC just the other day that a study in the Bering Strait region has modeled, with various IPCC estimations of climate change scenarios, the effects of changing habitat functionality on benthic-pelagic coupling, a phenomenon that is a hallmark of the Bering Sea shelf. I am eager to incorporate more presentations and discussions from the SSC into recommendations for conservation and mitigation measures for EFH in the future. I trust that, if the Council carries the insight brought forward through the AP, the public will work hard to ensure that proposals are well researched and supported.

Opening a call for proposals from members of the public signals recognition of this gap and offers an onramp for ideas that may help bridge FE and climate considerations through the incorporation of local and traditional knowledge.

Offering communities the opportunity to respond to a suite of finalized analyses totaling more than 850 pages, with focus areas for requests such as those passed by the AP, would be a welcome opportunity for thousands of deeply concerned fishery participants.

Thank you for your time today.

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