HLA Concerned About Department of Interior Use of Seafood Sustainability Certification Programs

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HLA has written to Secretary of the Interior Sally Jewell expressing concern about the announcement that announcement that the National Park Service intends to use the Monterey Bay Aquarium Seafood Watch program (with reliance on the Marine Stewardship Council's sustainability certification) to guide purchasing decisions for more than 250 culinary operations in national parks nationwide.  HLA thinks it is inappropriate for a U.S. Government Agency to be effectively endorsing any particular commercial seafood sustainability certification program when there are several such programs in place.  Perhaps more important, HLA stresses that all seafood harvested by U.S. fishermen from stocks managed under the Magnuson-Stevens Act are deemed sustainable under that Act and no private certification should be necessary for those products to be acceptable for use or sale in businesses offering food in concessions at Federally managed facilities such as National Parks.  The full text of the HLA letter follows:

 

June 25, 2013

Ms. Sally Jewell, Secretary of the Interior

1849 C Street NW

Washington, D.C.  20240

 

Dear Secretary Jewell:

The Hawaii Longline Association (HLA) is writing to express its surprise and concern about the announcement that the National Park Service intends to use the Monterey Bay Aquarium Seafood Watch program (with reliance on the Marine Stewardship Council's sustainability certification) to guide purchasing decisions for more than 250 culinary operations in national parks nationwide. 

The HLA was established to represent the interests of the men and women active in or supporting the longline fishing fleet operating out of Hawaii to catch tuna, swordfish, and associated highly migratory species.  This fishery is very comprehensively regulated under the Magnuson-Stevens Act (MSA) as well as under regulations implementing conservation and management measures of two international tuna fishery management commissions.  In fact, the Hawaii longline fishery is probably the most intensively regulated longline fishery in the Pacific if not the world.  HLA members work closely with U.S. Government agencies including the National Marine Fisheries Service, U.S. Fish and Wildlife Service, and U.S. Department of State to ensure that the fishery remains well managed.  The fishery has been evaluated against the sustainability criteria of the U.N. Food and Agricultural Organization and received a score of 96 out of a hundred possible points.  HLA is proud of the achievements of its members in providing the bulk of fresh tuna and associated products to the people of Hawaii while preventing excessive harm to other marine resources.

HLA does not object to promoting the purchase and use of sustainable fishery products.  Indeed, HLA recognizes the need for management to ensure that the fish stocks on which we depend will be harvested at sustainable levels and in a manner that does not adversely affect the sustainability of other resources.  However, HLA must emphasize that all catches from fisheries managed under the Magnuson-Stevens Act are in fact determined to be "sustainable" under that Act (one of the National Standards of the MSA) and therefore sustainable under U.S. law.  Further, HLA notes that there are several organizations that provide some form of "certification" as to the sustainability of seafood products.  There is no clear consensus that any single private certification program is best for industry or the public.  In fact, some parties are pulling back from using or supporting MSC Certification.  Certification is a very complex issue; many factors can enter into the evaluation of whether a fishery is sustainable and whether the fishery is using "best management practices" such that, for example, adverse impacts on other marine resources are minimized or mitigated sufficiently.  HLA believes that the Monterey Aquarium Fishwatch Program is only one source of such evaluations and should not be singled out for special recognition, nor should the Marine Stewardship Council.   Various fishing industries/fleets face different issues, and the use of one certification program or another should be made depending on the needs of the specific industry or fleet.  The use of a private source that charges for its certification process may be suitable for some; it may not meet the needs of others.  However, certification should not be a requirement for products that are being bought for use in Federal facilities.  All fish products offered from U.S. fisheries operating under the MSA should be acceptable in such facilities, as those products could only come from fisheries that have been determined to meet the National Standards of the MSA, including sustainability.  It is inappropriate, in our view, for a U.S. Government agency to effectively endorse any single private certification source when this public "certification" provided through the MSA is available.  Concessionaires should not be required to rely on any single such program when making decisions as to the sources of their products, at least not for domestic sources that are U.S. fisheries managed to be sustainable under U.S. law.  It is one thing for private businesses to insist on a particular certification source; it is another for a public agency to do that.  The former is a practical business decision; the latter is destined to be a source of controversy and lead to accusations of preferential treatment for selected businesses. 

HLA urges the Department of the Interior to reconsider its decision and recognize the role that U.S. law already fills in ensuring that the seafood available to U.S. consumers from U.S. fisheries, whether in national parks or in their homes, comes from managed, sustainable fisheries. 

We appreciate your consideration of these comments.

Sincerely,

Sean Martin

President, HLA