Claim that trawl skippers/crews are “local knowledge holders that make up a community of stakeholders.”
From Intrafish
By Rachel Sapin
June 26, 2023
A proposal to incorporate more local knowledge, traditional knowledge and subsistence information in the North Pacific Fishery Management Council’s (NPFMC) decision-making process is drawing concern from Alaska’s pollock industry. The council determines fisheries regulations in federal waters off Alaska.
At-Sea Processors Association (APA) Director Stephanie Madsen’s comments submitted to the task force earlier this month noted that some parts of the measure could further slow the council’s decision-making process and, “particularly in the context of rapid climate change, will have to be balanced with the needs of stakeholders seeking expeditious action.”
Her organization represents US pollock fishing giants American Seafoods, Trident Seafoods, Arctic Storm, Coastal Villages and Glacier Fish.
“APA member skippers and crew have many decades of experience of fishing in the Bering Sea, and have direct knowledge about the marine ecosystem and the ongoing effects of climate change. We believe that they are local knowledge holders that make up a community of Bering Sea fishery stakeholders with valuable knowledge and perspectives to contribute to the Council’s fishery management process. Our organization has pioneered efforts to collect fleet level local knowledge and perspectives that should be considered within the Council’s decision-making process.”
Stephanie madsen, APA director, commenting on including Local, Traditional and
Subsistence knowledge in the NPFMC process, march 2023
The proposal comes as the NPFMC looks at implementing a limit on the number of salmon harvested as bycatch by Alaska pollock fishing vessels.
Bycatch is non-targeted fish caught while vessels are harvesting a different species. A so-called prohibited species catch limit would require the Alaska pollock fishery to close if it caught a specified number of chum.
Alaska tribes are intensely scrutinizing the Alaska pollock fishery, asking about its role in critically low chum counts on the Yukon River now for several years in a row.
Madsen, a participant in one of the NPFMC’s committees, has advocated against creating a hard cap on salmon chum bycatch, noting it could shut down the Alaska pollock fleet entirely, not just her member companies.
There’s no way the pollock fleet can sit here and say we will accept these,” Madsen said in response to recommendations by five members of the NPFMC salmon bycatch committee, noting “the hard caps could shut down the Alaska pollock fleet entirely, not just her member companies.”
NPFMC testimony, MARCH 2023
In February of 2020, the council directed its Local Knowledge, Traditional Knowledge, and Subsistence (LKTKS) task force to identify potential onramps–or points of entry–for incorporating the knowledge and information into its decision-making process. The document contains 11 different onramp recommendations for the council to consider.
The first recommendation includes the council’s use of a task force-created search engine that includes peer reviewed articles, databases, narrative sources of information, reports, technical memos, and other sources of information.
Another recommendation includes the council initiating a process whereby tribes could engage directly with the council. The first option for those meetings recommends the council or one of its advisory bodies host informal engagement sessions with tribes and/or tribal consortia.
The engagement sessions could occur under an agenda item or as separate meeting, but would have to be public, according to procedural requirements of the Magnuson-Stevens Fishery Conservation and Management Act (MSA).
A second pathway available to the council is to participate in engagement trips that provide opportunities for two-way dialogue and knowledge sharing that does not require a public meeting or the other procedural formalities under the MSA.
“Implementing a process for council-tribal engagement could afford the council, Alaska natives tribes and/or tribal consortia meaningful opportunities for deliberative and inclusive dialogue, as well as opportunities to build relationships and mutual trust,” the task force said.
It added that information “usually shared orally” could be better communicated by more of these types of engagement sessions.
“The council has experienced consistent and increased engagement from Alaska native tribes and tribal consortia in its decision-making process,” the task force said.
“Alaska native tribes are sovereign governments with constitutions, bylaws and a right to self-determination. This legal status distinguishes tribes from other fishery stakeholder groups that engage the council’s decision-making process.”
The task force is also recommending the council consult with tribes earlier in its decision-making process.
“NMFS has historically conducted tribal consultations after the council selects a preferred alternative. and this can make it challenging for tribes and their representatives to having meaningful and timely input in the development of fisheries management and regulations,” the task force said.
Other onramps ask for the council to include “tribal co-management partners” in reports and presentations as a way “to increase consistency and equity for tribal co-management partners.”
More seats at the table
The task force is also recommending the council appoint more “designated Alaska native tribal seats” to its advisory bodies.
In February, the council appointed Shawaan Jackson-Gamble to hold the first-ever Alaska native tribal seat on its advisory panel seat. The seat was added after years of pressure from native groups.
Alaska lawmaker Mary Peltola, then executive director of the Kuskokwim River Inter-Tribal Fish Commission, testified before Congress that Alaska natives have only had concerns heard “through a Governor’s office that has historically and presently prioritized those with private financial interests in the fisheries over the long-term subsistence interests of Alaska natives.”
The task force said the move to add more representation could encourage “Alaska native elders, tribes, and communities to participate in the council’s process, feeling as though added representation is a meaningful invitation to participate.”
This measure was also emphasized by comments submitted by the US Department of the Interior supporting the proposal.
The federal department agreed the council should consider adding indigenous representation and membership and formalizing “opportunities for indigenous elders to speak on issues before a vote is set in motion (in addition to speaking during public hearings) to encourage greater two-way dialogue and knowledge sharing.”
The US Department of the Interior further supported the task force’s recommendations as a solution to “knowledge holders” who experience “‘regulatory fatigue,’ a scenario described by members of the task force that can result from impacted fishery stakeholders and/or tribal representatives having to engage with multiple processes and meetings to make their perspectives, experiences, and asks known.”
The request that the task force’s recommendations be fully adopted and implemented has also been supported by several other stakeholders.
They include the Alaska Tribe Aleut Community of St. Paul Island (ACSPI), The Alaska Longline Fishermen’s Association, Alaska Marine Conservation Council, The Association of Village Council Presidents, Bering Sea Elders Group, Bering Sea Fishermen’s Association, The Chevak Native Village, The Native Village of Elm, Chinik Eskimo Community, The Kuskokwim River Inter-Tribal Fish Commission (KRITFC), The Lake and Peninsula Borough (LPB), Nome Eskimo Community Tribal Government, The Pew Charitable Trusts, SalmonState, the Bristol Bay Native Association, Tanana Chiefs Conference, Native Village of Unalakleet and Native Village of White Mountain.
