May 9, 2014
Secretary Penny Pritzker
U.S. Department ofCommerce
1401 Constitution Ave., NW
Washington, D.C. 20230
Dear Secretary Pritzker:
We respectfully request that the Department of Commerce issue a corrected “2012 Fisheries Economics of the United States” that separates imported seafood from domestic seafood.
In the “2011 Fisheries Economics of the United States,” as a result of the constructive engagement of industry, policy makers and researchers, the National Marine Fisheries Service split the economic impacts of the seafood industry into that portion supported by domestic seafood harvest and that portion attributable to imported seafood product. This is very important as imports generate the lion’s share of economic activity in this country. In 2011, only 40% of the total sales in the U.S. were generated by domestic harvest. In 2012, only 36% of total sales were generated by the domestic harvest of fish. Perhaps most importantly, the 2011 report provided more information. It provided the impacts generated by domestic harvest plus the additional impacts generated by the importation of seafood, and the report summed both for the total economic footprint of the seafood industry. Generally, more information is preferred to less by all users of this valuable report.
Separating the imports from domestic harvest is also important because imports do not really stimulate what is traditionally considered the seafood supply chain. Imports are rarely processed in the United States because labor costs are so much higher in this country. Instead of entering the U.S. seafood supply chain, imports go directly to retail or pass through a broker or importer who simply warehouses and ships imported product. It is inappropriate to mix these two types of impacts together for a number of reasons. First, imported seafood does not come from U.S. fisheries stocks nor does it move through fishing communities or traditional seafood industry pathways. Imports are no different than any other imported protein. Second, NMFS has very limited policy or regulatory charge that involves importers or retail sales of seafood. Third, state fishery management partners and fishery management councils have more need for the impacts stemming from domestic sources only and would prefer to have these numbers split out. To avoid clouding domestic fishery policy matters, NMFS chose correctly to separate out imports in 2011.
Without explanation or warning, the 2012 FEUS combined imports and domestic production again. This generated a lot of press from the commercial industry proclaiming huge growth in the industry and a reason to shut down the allocation discussions currently underway in several councils. Nothing could actually be further from the truth. While total impact increased in 2012, the impacts of domestic production actually fell by over $2 billion dollars while the impact of imports increased by $11.3 billion. So while the domestic commercial industry is using the FEUS 2012 numbers to demonstrate their growth, they actually shrunk considerably while Americans increased their demand for foreign seafood dramatically.
This is the perfect argument for why government indices should not be tampered with -- and should be published consistently from year to year. These numbers impact livelihoods, private business plans and fishery policies. Additionally, various public relations machines spin these numbers to advocate for changes in government policies and these press releases misrepresent the true picture under the color of NMFS-‐produced “facts.” NMFS made a decision, wisely and backed by industry, academics and policy makers, to separate out imports in the 2011 FEUS. It should not have re-combined them in 2012 with no explanation. Furthermore, the public used to be able to separate these two import economic indicators using the NMFS online web queries. Unfortunately, NMFS has not updated those queries since 2009.
This change is poorly timed. Heated debate rages nationwide regarding the allocation of fish stocks between commercial and recreational interests. When imports are included and not provided separately, the commercial industry looks nearly two and one half times larger than the recreational industry. This is significantly misleading. Without imports, the commercial industry is actually nearly $8 billion dollars smaller than the recreational industry in terms of total sales. In fact, if you remove industrial fisheries, bait, shellfish and other species that are not subject to recreational fishing, the recreational industry is very conservatively $39.2 billion dollars larger than the commercial industry. In every fishery that the recreational angler cares about, the recreational industry generates more economic activity. Study after study demonstrates that. FEUS should demonstrate that as it did in 2011.
We feel NMFS needs to correct this misleading report. We ask that NMFS amend FEUS 2012 and separate out imports as they did in the 2011 report. We also ask that NMFS issue the appropriate press releases, including an update to FishNews, reflecting that imports make up over 64% of all impacts reported in that document.
Mike Nussman, President and CEO
American Sportfishing Association
Jeff Angers, President
Center for Coastal Conservation
Patrick Murray, President
Coastal Conservation Association
Steve Stock, President
Guy Harvey Ocean Foundation
Rob Kramer, President
International Game Fish Association
Thom Dammrich, President
National Marine Manufacturers Association
cc: NOAA Assistant Administrator for Fisheries Eileen Sobeck
NOAA Deputy Assistant Administrator for Regulatory Programs Sam Rauch