November 24, 2010
Mr. Jay Reich
Senior Advisor and Deputy Chief of Staff
Department of Commerce
1401 Constitution Ave NW
Washington, DC 20230
Dr. Jane Lubchenco
Undersecretary of Commerce for Oceans and Atmosphere
National Oceanic and Atmospheric Administration
14th & Constitution Ave NW
Washington, DC 20230-0001
Dear Mr. Reich and Dr. Lubchenco,
The Marine Conservation Alliance is writing as follow-up to the meeting you had with several representatives of the Alaska fishing industry and communities on Wednesday, November 10, 2010; and in support of recent recommendations to NOAA from the North Pacific Fishery Management Council by letter dated October 27, 2010 regarding the Steller Sea Lion (SSL) Biological Opinion (BiOp), research priorities to address Steller sea lion issues, and potential for an external review of the SSL research program.
The Marine Conservation Alliance (MCA) is a broad based coalition of harvesters, processors, coastal communities, Community Development Quota organizations, and support service businesses involved in the groundfish and shellfish fisheries off Alaska. MCA was formed to promote the sustainable use of North Pacific marine resources by present and future generations. MCA supports research and public education regarding the fishery resources of the North Pacific and seeks practical solutions to resource conservation issues. Our members collectively represent approximately 70% of the production of North Pacific fisheries which in turn accounts for over half the nation’s fishery production.
First, MCA wishes to support the Council’s comments regarding the potential CIE review and terms of reference. In its letter of October 27, the Council reiterated its request to review the terms of reference (TOR) for the potential CIE review of the Final BiOp. In October NMFS agreed to provide the TOR prior to the December Council meeting. MCA supports the Council’s request and hopes that the TOR will be made available for Council review and public comment in December.
Secondly, MCA is writing to request that you take a hard look at NOAA’s current SSL research program, and redirect funding beginning in 2011 to address SSL research priorities identified by the Council at their October meeting. In their letter to you, the Council discussed the need for research in the Aleutian Islands to assess the status of SSLs in the region, obtain basic foraging ecology data, track short term movement, and conduct studies targeted to identify whether or not fisheries are affecting SSL recovery (effects on prey base adjacent to SSL sites, reproduction, and survival). The Council based their recommendations on a presentation of SSL research priorities by Dr. Demaster of NMFS. MCA strongly supports the Council’s recommended research priorities.
This topic also came up in our meeting on November 10, where we emphasized the urgency to initiate this research in the 2011 field season. While there is general agreement that research in the Aleutian Islands needs to commence in 2011, NMFS has stated that they will only initiate new research if additional funds are found. This could significantly delay start-up of crucial research. MCA believes that this is a short sighted approach to addressing the most critical research needs in the area of greatest concern for SSLs. We respectfully request that NOAA look for ways to redirect funds so that this research work can commence in the Aleutian Islands in 2011.
And, as a final matter, MCA believes that this is a good time to take a comprehensive look at the SSL research program. Beginning in the early 2000’s, substantial funding went into SSL research to look at factors affecting their recovery. Of fourteen indicators that NMFS used in the draft BiOp, only one was deemed to indicate that fisheries might be affecting SSL recovery, and there is considerable scientific debate about this one indicator. With this latest BiOp and round of mitigation measures, it is apparent that the lack of good empirical data on factors affecting recovery is costing the industry and the nation millions of dollars and thousands of jobs. MCA believes that a comprehensive review of the past decade’s SSL research program by an organization such as the National Research Council is in order. The review should look at the goals and results of the program, identify gaps in our knowledge, and make recommendations for new research directions to determine whether or not fisheries are significantly affecting SSL recovery, or if other factors are impacting SSL populations and their recovery. We encourage you to work with the Council and others to secure such a review.
Finally, we want to thank you and your staff for taking the time to meet with us on November 10 to discuss these issues. We thought it was a useful discussion and look forward to working with you as we move forward.
Sincerely,
David Benton
Executive Director
Encl: North Pacific Fishery Management Council by letter dated October 27, 2010 regarding the Steller Sea Lion (SSL) Biological Opinion (BiOp)
Cc: Governor Sean Parnell, State of Alaska
Governor Chris Gregoire, State of Washington
Governor Ted Kulongoski, State of Oregon
Senator Lisa Murkowski
Senator Mark Begich
Senator Patty Murray
Senator Maria Cantwell
Congressman Don Young
Congressman Doc Hasting
Mr. Eric Olson, Chair, North Pacific Fishery Management Council