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:
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.