lanejohnston

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About Responsible Offshore Development Alliance

Responsible Offshore Development Alliance (RODA) is a broad membership-based coalition of fishing industry associations and fishing companies — across the United States — committed to improving the compatibility of new offshore development with their businesses. The Alliance works to directly collaborate with relevant regulatory agencies, scientists, and others to coordinate science and policy approaches to managing development of the Outer Continental Shelf in a way that minimizes conflicts with existing traditional and historical fishing.

Connect with RODA on Twitter, Facebook, and Instagram.

Contact: lane@rodafisheries.org

FOR IMMEDIATE RELEASE
Date Published: March 29, 2023

Washington, D.C. March 29, 2023 — In 2020, the Responsible Offshore Development Alliance (RODA), NOAA Fisheries’ Northeast Fisheries Science Center, and the Bureau of Ocean Energy Management (BOEM) convened a first-of-its-kind workshop to evaluate the current state of science relevant to fisheries and offshore wind energy interactions. The final peer-reviewed report of the workshop is now available.

The “Synthesis of the Science” project was a key first step toward jointly building a regional fisheries and offshore science agenda. RODA brought together fishermen, fishing industry representatives, federal and state agency experts, wind energy developers, academics, and other prominent scientists from the U.S. and Europe to attend the workshop and contribute to the report.

This report enhances understanding of existing science and data gaps related to offshore wind energy development interactions with fish and fisheries on regional and broader levels. Ecological knowledge of the fishing industry participants was incorporated into all of the report topics covering:

• Ecosystem effects – including interactions with benthic habitat, physical habitat, oceanographic processes, and ecosystem synthesis by species groupings;
• Fisheries socioeconomics – covering fisheries operations, economics, and sociocultural effects throughout the fishing industry and dependent communities;
• Fisheries management and data collection – incorporating effects to resource surveys and governance processes;
• Methods and approaches – including addressing cumulative impacts, use of Integrated Ecosystem Assessments and innovative approaches and technologies; and
• Regional science planning – highlighting fishing industry-identified research priorities.

Funded by NOAA Fisheries’ Northeast Fisheries Science Center, the symposium and report advance a memorandum of understanding between RODA, NOAA Fisheries, and BOEM. Signed in March 2019, this ten-year MOU promotes collaboration on the science, research, monitoring, and process of offshore wind energy development on the U.S. Outer Continental Shelf.

In 2021, RODA received additional funds through this grant for a second synthesis of the science project. It is currently underway, and focuses on fisheries and floating offshore wind platforms. The project consists of a summary of current knowledge, research, and monitoring associated with floating technology, a workshop focused on floating turbine technology, and a review by the fishing industry of existing mapping efforts of fishermen’s data

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About Responsible Offshore Development Alliance

Responsible Offshore Development Alliance (RODA) is a broad membership-based coalition of fishing industry associations and fishing companies — across the United States — committed to improving the compatibility of new offshore development with their businesses. The Alliance works to directly collaborate with relevant regulatory agencies, scientists, and others to coordinate science and policy approaches to managing development of the Outer Continental Shelf in a way that minimizes conflicts with existing traditional and historical fishing.

Connect with RODA on Twitter, Facebook, and Instagram.

Contact:

Fiona Hogan, Director of Research

fiona@rodafisheries.org

FOR IMMEDIATE RELEASE
Date Published: December 13, 2022

Richmond, VA. Tuesday, December 13, 2022 – Yesterday, nine Atlantic Coast States released a request for information (RFI) to receive feedback on a regional administrator for fisheries compensatory mitigation from offshore wind development. [Available here]

The Commonwealth of Virginia acknowledges the great value of the commercial fishing industry and the need for their engagement in potential offshore wind development as early as possible. The Virginia Marine Resources Commission (VMRC) is responsible for the management of Virginia’s marine and aquatic resources, including the responsibility to ensure our historic seafood industry is maintained as economically healthy and sustainable. VMRC has been working toward encouraging early avoidance of fisheries resources with the goal of a coexisting relationship between renewable energy development and commercial fishing.

Through the Virginia Coastal Zone Management Program, the Commonwealth has supported the Responsible Offshore Development Alliance (RODA) to coordinate a critical group of commercial fisheries advisors to provide initial feedback on the States’ scoping effort and RFI. RODA is a coalition of fishery-dependent companies, associations and community members committed to improving the compatibility of new offshore development with their businesses. RODA is uniquely positioned to
facilitate the involvement from the commercial fishing industries in the New England, Mid Atlantic, Gulf of Maine and Pacific regions as they relate to offshore wind development.

“As providers of sustainable seafood, our members are deeply invested in protecting U.S. fisheries and are grateful to the Commonwealth of Virginia for the opportunity to participate in initial discussions of this state-led effort. It is essential that impacted parties have a central role in designing and administering strategies that will most effectively mitigate impacts of offshore wind, and we look forward to continuing to refine an equitable and appropriate compensation strategy,” said Lane Johnston, Programs Manager at RODA.

“The commercial fishing community are stewards of their resources and we as Virginians have a responsibility to ensure their equities are considered as we embrace an all-of-the-above energy plan that includes offshore wind. Our goal to ensure the Commonwealth has a reliable, affordable, clean and growing supply of power can be possible while protecting the jobs of our important fishing industry,” said Acting Secretary of Natural and Historic Resources Travis Voyles.

It is paramount that the fishing industry, as recipients of any mitigation and compensation strategies, are involved in designing a fair and appropriate regional compensation fund and administration process. The Commonwealth is committed to ensuring the fishing industry is an acknowledged equity throughout the development of offshore wind and through the design process of the RFI. The Commonwealth looks forward to hearing from all industry voices through the RFI comment period.

Virginia Contacts:

• Todd Janeski, VA Ocean Fisheries Coordinator (tvjaneski@vcu.edu)
• Rachael Peabody, Director of Policy, VA Marine Resources Commission (rachael.peabody@mrc.virginia.gov)

RODA Contact:

• Lane Johnston, Programs Manager (lane@rodafisheries.org)

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About Responsible Offshore Development Alliance

Responsible Offshore Development Alliance (RODA) is a broad membership-based coalition of fishing industry associations and fishing companies — across the United States — committed to improving the compatibility of new offshore development with their businesses. The Alliance works to directly collaborate with relevant regulatory agencies, scientists, and others to coordinate science and policy approaches to managing development of the Outer Continental Shelf in a way that minimizes conflicts with existing traditional and historical fishing.

Connect with RODA on Twitter, Facebook, and Instagram.

Contact: lane@rodafisheries.org or annie@rodafisheries.org

FOR IMMEDIATE RELEASE
Date Published: December 8, 2022

Washington, D.C. Thursday, December 8, 2022 — Yesterday, the Bureau of Ocean Energy Management (BOEM) completed five lease sales within two areas encompassing 582 square miles (373,268 acres) off the California coast, an area half the size of Yosemite National Park. In total, the auction generated $757M (or 17% of the total raised by BOEM during the February 2022 auction for the New York Bight – $4.37B).   The current process for leasing and permitting offshore wind development projects remains rushed and fails to properly consider and protect existing ocean users and resources. Regarding the California leases, siting decisions were made without a robust public process and without consideration of the impacts to users and the areas themselves.  

The lease sites, when developed, will be populated by floating offshore wind energy facilities. At present, there are no large-scale floating offshore facilities anywhere in the world and significant uncertainties remain over the technology that will be installed, much of which has not yet been designed. This may explain the lack of interest and underwhelming price tag for the California leases.

Little has been done to resolve the significant scientific, environmental, and economic uncertainties of offshore wind development, despite the fishing industry reasonably requesting such action for over a decade. We have repeatedly called for a programmatic environmental analysis for each region before offshore wind decisions are made, and our questions and concerns regarding the cumulative ecological impacts of large-scale ocean habitat conversion are beginning to be echoed by the conservation community.  These concerns were made even more critical given the recent publication of a study finding offshore wind farms change marine ecosystems. (1) The California Current Large Marine Ecosystem (CCLME) is a highly productive coastal marine ecosystem in the northeast Pacific Ocean and preserving and protecting the ecological function and integrity of the CCLME should not be secondary to privatizing our oceans with unproven technology producing unknown impacts.

Equitable strategies for climate action must directly involve impacted communities to achieve enduring solutions. Instead, investment banks and goliath energy corporations are teaming up, fueled by taxpayer-funded credits, to acquire public lands for private use – an activity that would be highly regulated in any other sphere. Despite the lackluster auction, the huge geographic areas covered by the leases demonstrate the need for strong oversight and transparency on matters of environment, health, safety, and social justice. Important work stands before us to establish such policies for offshore wind.

As noted above, the auction raised roughly $757 Million, a far cry from the $4.37 Billion raised during the New York Bight auction ten months ago. The per acre value of the California lease sales averaged $2,061/acre compared to $8,831/acre for the New York Bight lease sales. The three lease sites off Morro Bay generated $425.6M and the two lease sites off Humboldt $331.5M. Just in 2019, 20 million pounds of seafood was landed by U.S. fishermen in the Eureka Port Complex adjacent to the Humboldt lease sites, an ex-vessel value of $38.6M in that year alone. 

To the U.S. based representatives of RWE Offshore Wind Holdings, LLC, California North Floatin, LLC, Equinor Wind US, LLC, Central California Offshore Wind, LLC, and Invenergy California Offshore, LLC, we must work collectively toward developing a better future. We encourage you to constructively engage with the fishing industry, listen authentically to impacted communities, and consider regional level impacts when determining next steps. Your corporations must be willing to take a flexible approach to mitigation based on the significant financial commitments invested in a paper lease. Lease siting did not avoid impacts, so a willingness to spend hundreds of millions of dollars on leases must entail an equal commitment to minimize and mitigate the environmental and socioeconomic impacts to small business owners who feed the nation.  

(1) See Offshore wind farms change marine ecosystems, study shows (phys.org)

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About Responsible Offshore Development Alliance

Responsible Offshore Development Alliance (RODA) is a broad membership-based coalition of fishing industry associations and fishing companies — across the United States — committed to improving the compatibility of new offshore development with their businesses. The Alliance works to directly collaborate with relevant regulatory agencies, scientists, and others to coordinate science and policy approaches to managing development of the Outer Continental Shelf in a way that minimizes conflicts with existing traditional and historical fishing.

Connect with RODA on Twitter, Facebook, and Instagram.

Contact: mike@rodafisheries.org or annie@rodafisheries.org

FOR IMMEDIATE RELEASE
Date Published: Monday, November 21, 2022

Washington, D.C. Monday, November 21, 2022 — On November 18, 2022, U.S. commercial fishing industry leaders and participants submitted recommendations to the White House Office of Science and Technology Policy (OSTP) to inform the development of a U.S. Ocean Climate Action Plan (OCAP).  The letter outlined nine specific actions necessary to develop an OCAP that is inclusive and protects the seafood industry’s role in contributing to food security, the economy, and the culture and heritage of our coastal communities. It was signed by 49 individuals from seafood harvesters, processors, and associations representing a wide array of fisheries from Maine to Alaska and California to North Carolina. The recommendations are based on a November 15 comment letter submitted by the Responsible Offshore Development Alliance (RODA).  

The recommendations stress items including:

• The importance of collecting, understanding and incorporating fishermen’s ecological knowledge in climate policy; 
• Acknowledging the role of commercial fishing to the nation’s overall well-being; 
• The significance of a fully informed decision-making process considering costs, impacts and benefits; and
• The need to prioritize and enhance collaborations between agencies and stakeholders.

On October 4, 2022, OSTP released a Request for Information announcing its preparation of an OCAP, which would span multiple activities from increasing offshore wind energy to conserving marine areas to reducing shipping emissions. RODA’s response letter points to the importance of federal support for a thriving domestic seafood industry–a cornerstone of coastal economies and communities that is often overlooked in high-level ocean policies. 

RODA’s West Coast Director Mike Conroy states, “OSTP has the opportunity to include those on the front lines of climate change.  Our members stand ready to assist in the development of an OCAP that incorporates their knowledge and experience.  Working collaboratively to consider and implement ocean-based climate solutions that protect U.S. food security while maintaining our ability to provide a low climate impact source of protein represents a win-win scenario.”

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About Responsible Offshore Development Alliance

Responsible Offshore Development Alliance (RODA) is a broad membership-based coalition of fishing industry associations and fishing companies — across the United States — committed to improving the compatibility of new offshore development with their businesses. The Alliance works to directly collaborate with relevant regulatory agencies, scientists, and others to coordinate science and policy approaches to managing development of the Outer Continental Shelf in a way that minimizes conflicts with existing traditional and historical fishing.

Connect with RODA on Twitter, Facebook, and Instagram.

Contact: mike@rodafisheries.org or annie@rodafisheries.org

FOR IMMEDIATE RELEASE
Date Published: Monday, November 14, 2022

Washington, D.C. Monday, November 14, 2022 —On November 8, 2022, the Responsible Offshore Development Alliance (RODA) filed a motion for summary judgment in its lawsuit over the approval of the Vineyard Wind 1 offshore wind energy project against the Bureau of Ocean Energy Management (BOEM) and other federal defendants in the U.S. District Court for the District of Massachusetts. RODA is represented by Marzulla Law, LLC.

The plaintiff, a national coalition of fishery-dependent businesses and associations, commenced the lawsuit last year after BOEM approved the project. This first commercial-scale offshore wind energy facility in federal waters, along with the dozens that are expected to follow in the near future, carry significant environmental uncertainty and pose severe threats to domestic seafood production. The government’s permitting process lacks meaningful opportunities to avoid, minimize, and mitigate these effects.

The motion establishes a clear record showing that the law and facts of the case are in fishermen’s favor and that the project approval was arbitrary, capricious, and contrary to law. The filings show that BOEM’s Record of Decision and its underlying environmental review are in direct contravention of several statutes including the Outer Continental Shelf Lands Act, National Environmental Policy Act, Clean Water Act, Endangered Species Act, Marine Mammal Protection Act, Merchant Marine Act, and Administrative Procedure Act.

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About Responsible Offshore Development Alliance

Responsible Offshore Development Alliance (RODA) is a broad membership-based coalition of fishing industry associations and fishing companies — across the United States — committed to improving the compatibility of new offshore development with their businesses. The Alliance works to directly collaborate with relevant regulatory agencies, scientists, and others to coordinate science and policy approaches to managing development of the Outer Continental Shelf in a way that minimizes conflicts with existing traditional and historical fishing.

Connect with RODA on Twitter, Facebook, and Instagram.

Contact: info@rodafisheries.org

FOR IMMEDIATE RELEASE
Date Published: Thursday, October 20, 2022

Washington, D.C. Thursday, October 20, 2022 — On October 18th, 2022, the Bureau of Ocean Energy Management (BOEM) published a Final Sale Notice (FSN) for two areas encompassing 582 square miles off the California coast. The lease sites included in the FSN, when developed, will be populated by floating offshore wind energy facilities. At present, there are no large-scale such facilities anywhere in the world. A thoughtful and measured approach to design, construction and operation should be ensured given the lack of verifiable scientific data on potential impacts to the environment and ecological function of the California Current Large Marine Ecosystem. The Responsible Offshore Development Alliance (RODA) commends BOEM for:

• Acknowledging the lease areas, as finalized, still encompass areas that have historically been used by several fisheries.
• Increasing the amount of the bidding credit offered for the Lease Area Use Community Benefit Agreement (CBA) from 2.5 to 5 percent.
• Adding an additional General CBA bidding credit of 5 percent to provide for communities, Tribes, or stakeholder groups affected by potential impacts on the marine, coastal, and/or human environment.
• Requiring lessees to prepare semi-annual progress reports and regular engagement with affected parties (including the fishing industry), to develop communications plans for fisheries, and to discuss strategies for conflict reduction with facility designs and marine vessel operations.

However, BOEM did not incorporate or address several recommendations in RODA’s comment letter on the Proposed Sale Notice. For example,

• Requiring a specific financial commitment to qualify for the CBA credits.
• Establishing an oversight body, including fishing community members, to receive and evaluate the required reports for the fishing industry.
• Incorporating sliding scale bid credits so that more robust mitigation agreements are afforded greater weighting.
• Requiring a fishing industry/community representative on the panel which will be established to “review the non-monetary component” of any bid.

“Fishing community members are hopeful that winning bidders will make financial commitments to impacted communities commensurate with their full, cumulative impacts and induced risk,” said Mike Conroy, RODA’s newly-appointed lead for West Coast activities.

It is encouraging that BOEM has committed to update its processes in an effort to achieve a more transparent Area Identification process. The agency states it is pursuing Wind Energy Area site suitability analyses in locations with preliminary areas identified to facilitate wind energy development, with the goal to “support environmental, economic, and social sustainability; and minimize resource use conflicts.” Provided ocean users are directly involved in this effort, and fishermen’s ecological knowledge is incorporated, such an effort could make progress toward that goal. It is unfortunate that such an analysis was not undertaken for the lease sites identified off California.

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About Responsible Offshore Development Alliance

Responsible Offshore Development Alliance (RODA) is a broad membership-based coalition of fishing industry associations and fishing companies — across the United States — committed to improving the compatibility of new offshore development with their businesses. The Alliance works to directly collaborate with relevant regulatory agencies, scientists, and others to coordinate science and policy approaches to managing development of the Outer Continental Shelf in a way that minimizes conflicts with existing traditional and historical fishing.

Connect with RODA on Twitter, Facebook, and Instagram.

Contact:

Mike Conroy, mike@rodafisheries.org

FOR IMMEDIATE RELEASE
Date Published: Tuesday, September 6, 2022

Washington, D.C. Tuesday, September 6, 2022 — Responsible Offshore Development Alliance (RODA) is proud to announce that Mike Conroy will be joining our team to lead and enhance west coast engagement.  Mike joins RODA from the Pacific Coast Federation of Fishermen’s Associations (PCFFA) where he served as Executive Director.  PCFFA is the largest organization of commercial fishermen and women on the West Coast. “I am very much looking forward to joining the talented group of folks at RODA as we continue to speak for and with America’s seafood harvesters, processors, dependent fishing communities and all those who consume sustainable, healthy, domestically sourced protein.”

Mike brings to RODA knowledge and experience obtained by spending years on the water operating commercial and charter fishing vessels.  Mike is also a licensed attorney in the State of California whose practice focused on small businesses, fisheries management and policy, and administrative processes.  Mike is the Vice Chair of the Pacific Fishery Management Council’s Highly Migratory Species Advisory Subpanel and Co-Chair of the Marine Planning Committee.

Mike has been involved in offshore wind issues off the west coast since three Call Areas were identified off California in late fall of 2018.  He is also involved with NOAA’s efforts to identify and establish Aquaculture Opportunity Areas within the Southern California Bight.

“We are excited to bring Mike aboard.  We strongly believe his knowledge and experience will help RODA increase our activities on the west coast and federally, creating better representation for fishermen and their communities. The overwhelming show of support from across the seafood industry for expanding our coalition underscores the importance of our mission, to coordinate science and policy approaches to offshore development that minimize conflicts with existing traditional and historical fishing,” said Annie Hawkins, RODA’s Executive Director.

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About Responsible Offshore Development Alliance

Responsible Offshore Development Alliance (RODA) is a broad membership-based coalition of fishing industry associations and fishing companies — across the United States — committed to improving the compatibility of new offshore development with their businesses. The Alliance works to directly collaborate with relevant regulatory agencies, scientists, and others to coordinate science and policy approaches to managing development of the Outer Continental Shelf in a way that minimizes conflicts with existing traditional and historical fishing.

Connect with RODA on Twitter, Facebook, and Instagram.

Contact:

info@rodafisheries.org

FOR IMMEDIATE RELEASE
Date Published: Thursday, June 23, 2022

Washington, D.C. Thursday, June 23, 2022 — Today, the Bureau of Ocean Energy Management (BOEM) released Draft Guidelines for Mitigating Impacts to Commercial and Recreational Fisheries on the Outer Continental Shelf Pursuant to 30 CFR Part 585. The Responsible Offshore Development Alliance (RODA) commends BOEM for pursuing an effort to address the critical impacts to fishing from offshore wind energy development. The draft guidelines provide several new criteria for mitigating these impacts, including burying static cables to a minimum depth of six feet, avoiding rock mattressing, and implementing structure-free setbacks between lease areas with differing layouts. They also mark the federal government’s first explicit acknowledgement that offshore wind energy developers should compensate fishing communities for losses to their businesses and livelihoods from these energy projects, costing billions of dollars and taking up hundreds of square miles of ocean habitat.

Regrettably, the potential effectiveness of these proposed guidelines is all but nullified by the fact that they are mere suggestions to individual offshore wind energy developers, rather than binding requirements. BOEM has taken the position that it lacks authority to regulate developers’ projects in a way that would mitigate fishing impacts, despite its clear mandate under the Outer Continental Shelf Lands Act to “provide[] for the prevention of interference with reasonable uses” including fishing. BOEM further erroneously asserts that it cannot implement regional mitigation plans.

While we welcome any first step toward improving attention to fisheries conflicts, in form and content, it is overall difficult to find evidence of the diligent input provided by the fishing industry in these guidelines. Scores of fisheries experts requested federal oversight beyond voluntary guidelines and asked that mitigation be designed to address cumulative impacts. RODA also produced the only report to date assembling the expertise of a large national cross-section of fishing industry members on effective guidelines and principles regarding compensatory impact fees for the entire seafood industry, from crew members to vessels and shoreside businesses, and provided this valuable information to BOEM.

In that report and fishing industry comment letters, we universally asked for the development of equitable, transparent, inclusive, and intelligible processes to determine mitigation principles. This included strong opposition to relying on a formal “notice and comment” process to address fisheries mitigation and compensation. We also explicitly requested that fishermen be able to directly provide their local ecological and business knowledge into this process. BOEM has not adjusted or improved its process despite those requests.

Fishing groups across the country unanimously stated that the most important consideration for BOEM to reduce impacts was that mitigation must follow a stepwise approach, prioritizing immediate action on the first step, avoidance, which entails developing measurable criteria to site offshore wind infrastructure off of fishing grounds. The draft guidelines do not address this primary need, and instead focus mainly on compensation. These avoidance criteria are the most pressing need for coastal states and regions that just now are identifying areas for leasing, as opposed to others that have been engaged in offshore wind development discussions for years. BOEM’s draft guidance does not distinguish between the two. Again, “notice and comment” is not the proper approach to equitable and durable mitigation for regions in variable stages.

RODA’s final request was for standardized compensation strategies that are equitable and based on science. While the draft guidelines suggest the use of third-party administrators, they leave every detail of such administration to the full discretion of developers. This directly conflicts with our direct request that “any framework must be co-designed with impacted parties.” It makes little sense for for-profit developers (lessees) to be able determine whom to compensate; yet the draft guidelines do just that.

We need enforceable and effective measures to avoid, minimize, mitigate, and compensate for offshore wind’s considerable impacts to seafood production. BOEM’s draft guidelines, and especially the process and scope of their development, appear to do little to solve this urgent problem. We will gather additional feedback from seafood producers across the country in coming weeks to prepare more detailed suggestions, and look forward to working with BOEM and other parties to improve and strengthen oversight of offshore wind energy activities to protect our existing coastal and fishing communities.

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About Responsible Offshore Development Alliance

Responsible Offshore Development Alliance (RODA) is a broad membership-based coalition of fishing industry associations and fishing companies — across the United States — committed to improving the compatibility of new offshore development with their businesses. The alliance works to directly collaborate with relevant regulatory agencies, scientists, and others to coordinate science and policy approaches to managing development of the Outer Continental Shelf in a way that minimizes conflicts with existing traditional and historical fishing.

Connect with RODA on Twitter, Facebook, and Instagram.

Contact:

info@rodafisheries.org

FISHERIES ORGANIZATIONS REQUEST APPROPRIATIONS TO NMFS FOR OFFSHORE WIND SURVEY MITIGATION AND COOPERATIVE RESEARCH

RODA and Seafood Harvesters of America, along with the support of numerous other fishing organizations and business owners, have submitted a letter to the House and Senate Chairs and Ranking Members of the Commerce, Justice, Science, and Related Agencies (CJS) Appropriations Subcommittee requesting funding to NMFS for survey impact mitigation and cooperative research:

Dear Chair Shaheen, Ranking Member Moran, Chair Cartwright, and Ranking Member Aderholt:

We write today to express the urgent need for providing the National Marine Fisheries Service (“NMFS”) with robust funding to address the impacts of offshore wind energy development (“OSW”) on federal fisheries surveys and to support cooperative research efforts led by NMFS that uses the expertise and skills of the commercial fishing industry to address the impacts of OSW.

We represent a diverse group of commercial fishermen, seafood processors, and shoreside support businesses who depend on access to healthy fish stocks and marine environment. While the species we target, gear we use, and vessel sizes may differ, we all firmly believe in robust federal investments to address the impacts of OSW on our ocean and fishery resources to ensure we can continue to both be a global leader in ocean sustainability and provide consumers with sustainable seafood.

To date, the Bureau of Ocean Energy Management (“BOEM”) has issued 28 federal OSW leases, with construction already underway for the first two major commercial wind energy facilities in the Northeast. Over 23 million acres of public trust resources on the Northeast Shelf, 30 million acres in the Gulf of Mexico, and one and a half million acres off the West Coast are in various stages of planning for offshore wind energy development. The enormous size of these areas and their direct overlap with key grounds for seafood production and protected resource conservation underscore the critical need for funding to address the impacts of this burgeoning industry.

We appreciate the FY23 President’s Budget request that includes the following investments relative to offshore wind energy development:

• $17,380,000 for ORF NMFS Wind Energy: Scientific Survey Mitigation;
• $8,669,000 for ORF NMFS Wind Energy: Fisheries Science & Technical Reviews;
• $6,155,000 for ORF NMFS Wind Energy: Fisheries Management;
• $4,476,000 for ORF NMFS Wind Energy: Protected Species Environmental Reviews and Science; and
• $8,719,000 for ORF NOS Foundational Information for Expansion of Offshore Wind Energy.

We have serious concerns, however, that these investments will not adequately fund the activities and personnel (FTEs) necessary to appropriately minimize and mitigate the environmental and 2 economic impacts of OSW. Specifically, we are concerned that the dollar amount requested for the Scientific Survey Mitigation work is far too low given the rapid pace of OSW leasing and the additional scientific surveys that will be impacted. Furthermore, we request the Committee to consider appropriating additional funding specifically for cooperative research projects aimed at evaluating and mitigating the impacts of OSW.

ORF NMFS Wind Energy: Scientific Survey Mitigation

We respectfully request no less than $43.75 million for NMFS Scientific Survey Mitigation.

Fisheries data collection, surveys, and assessments are crucial to our understanding of our ocean and fishery resources. Specifically, the data collected through annual federal scientific surveys is an integral piece of the stock assessment and catch limit setting process, foundational pillars of our nation’s sustainable fisheries management. NMFS currently conducts more than 50 such long-term standardized surveys, many of which have been ongoing for more than 30 years. These surveys provide a long-term time series data set, essentially a time lapse of the status of fish stocks; their scientific value lies in their consistency over time.

NMFS has made it clear that impacts to scientific surveys will occur and will need to be mitigated due to: preclusion, statistical design, habitat alteration, and loss of sampling efficiency. NMFS must also mitigate the impacts on fisheries dependent data, which supplement and improve survey data for many major U.S. fisheries. This mitigation work is a significant undertaking for a single scientific survey and yet we are now looking at no fewer than 25 known surveys across the Atlantic and Pacific coasts that will be disrupted by OSW. At $1.75 million per affected survey to adjust scientific methodologies and calibrations in the face of large-scale OSW installations, this request is both reasonable and necessary.

Scientific survey mitigation has resulted in, and will continue to cause, increased demand for staff time and resources from NMFS Science Centers, Regional Offices, and Office of Protected Resources. As noted in the BOEM/NMFS Draft Survey Mitigation Implementation Strategy and underscored by both agencies, the fishing industry, and the public for years, NMFS has yet to receive any dedicated funding for scientific survey mitigation. Simply put, this is unacceptable. Furthermore, as current and historical users of the marine environment whose livelihoods will be impacted by disruptions to surveys and fishing grounds, this funding will be critical to ensuring the agency can begin to address survey impacts so that we understand and secure our future fishing opportunities.

To execute NMFS’ statutory mandate to manage, conserve, and protect living marine resources using the best available science, and to protect the billions of dollars worth of investments in our fisheries management, science, and fishing business operations, it is paramount that Congress increase scientific investments aimed at understanding the impacts of OSW, deliver critical scientific data, and ensure that domestic sustainable seafood production is supported in the process.

NMFS Cooperative Research

We respectfully request no less than $30 million for NMFS Cooperative Research projects specific to addressing the impacts of OSW, equivalent to $5 million per Fisheries Science Center.

NMFS Cooperative Research efforts give commercial fishermen and processors a role in building the industry’s resilience to climate change while building trust in management outcomes and decisions. Additionally Cooperative Research helps address existing and emerging data gaps, rebuilds trust between managers and the seafood industry, helps incorporate local and traditional knowledge in science, and encourages buy-in to management decisions.

Specifically with respect to OSW, cooperative research will allow fishermen and processors to participate in improving our collective understanding of impacts and how best to sustain the viability of both industries. Fishermen develop important hypotheses based on observed environmental changes and collect data that improve understanding of local conditions and inform climate and fisheries sciences. More cooperative research would assist in understanding fisheries behavior and operational needs in relation to OSW. Cooperative Research projects specific to OSW may also provide an alternative source of income for those fishermen who are displaced from their fishing grounds and present an opportunity for fishermen to assist NMFS in collecting data in/around OSW arrays where larger NOAA research vessels may not be able to access.

Currently, there is a gross disparity in federal research funding available to OSW proponents, with extraordinarily little available to those without a financial interest in its deployment. Yet, despite the vast importance of cooperative research toward achieving equitable participation in ocean planning, we are concerned that its funding is often the first item on the chopping block when cuts are necessary. We strongly urge the Committee to resist reducing or cutting funding for Cooperative Research, particularly as we face significant hurdles with respect to addressing the impacts of OSW.

Conclusion

The scale of OSW proposed in the U.S. is staggering. So too, are the financial resources already invested and required to develop effective strategies for its deployment. Notably, one recent lease alone sold for over $1 billion in the New York Bight. Other federal agencies have received billions of dollars to support OSW permitting and transmission needs; we feel the development of appropriate environmental impact mitigation strategies are equally important, if not more so. Additionally, given the pace of OSW and the lack of consideration of development on fisheries impacts, this funding is important now; securing funding after surveys are impacted will be too late.

While we acknowledge the need to take action on climate change, our government must ensure that it does everything in its power to avoid, minimize, and mitigate the impacts of OSW on our marine environment, fishing businesses, and fishing communities. Adequately funding Scientific Survey Mitigation and additional Cooperative Research would be a productive place to start and we implore you to take seriously our requests outlined above.

We are glad to see President Biden’s FY23 Budget Request include investments across NOAA to address the impacts of OSW. However, we strongly support additional investments in NMFS Scientific Survey Mitigation and Cooperative Research initiatives and urge Congress to direct federal appropriations to these two critical NMFS programs.

We appreciate your consideration of these requests. Please don’t hesitate to reach out to Leigh Habegger (leigh@seafoodharvesters.org) or Annie Hawkins (annie@rodafisheries.org).

Respectfully,

Leigh Habegger, Executive Director, Seafood Harvesters of America

Annie Hawkins, Executive Director,  Responsible Offshore Development Alliance

See full letter with additional signatories below:

220621_FY23_OSW_Funding_FINAL

Date Published: Tuesday, June 21st 2022

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About Responsible Offshore Development Alliance

Responsible Offshore Development Alliance (RODA) is a broad membership-based coalition of fishing industry associations and fishing companies — across the United States — committed to improving the compatibility of new offshore development with their businesses. The alliance works to directly collaborate with relevant regulatory agencies, scientists, and others to coordinate science and policy approaches to managing development of the Outer Continental Shelf in a way that minimizes conflicts with existing traditional and historical fishing.

Connect with RODA on Twitter, Facebook, and Instagram.