CFSB & PCFFA's joint public comment on the Fishing Communities Report

The Fish and Game Commission recently completed a set of listening sessions with representatives of fishing ports across the state. The July 2018 report is available at

Below is our letter in response


Dear Ms. Ashcraft,

On behalf of the Pacific Coast Federation of Fishermen’s Associations and our fourteen member organizations comprising over 750 commercial fishermen and women living in California’s fishing- dependent communities, we write to provide comments on the Fish and Game Commission’s draft Staff Report on California Coastal Fishing Communities Meetings (“report”).

Many of our members participated in the fishing community meetings the Commission hosted and we appreciate the time and attention taken to produce the draft report. The report, and the effort it represents, has tremendous potential to guide the Commission’s policies regarding the future of commercial fisheries in California. We look forward to working with as you work to enhance and finalize the report.

We have divided our comments into guidance for new policy considerations and constructive criticism on the contents of the draft report.

I. A vision based in innovation and collaboration to enhance management outcomes

As the report highlights, there are readily identifiable gaps between the needs of fishing communities and the abilities of, mandates for, and services performed by state regulatory agencies. We feel that some of these gaps can be addressed simply by designing projects and policies that establish trust and enfranchise commercial harvesters in the various management processes. When provided a stronger role in management, and when agencies and managers are enabled and trained to engage, fishermen can bring their knowledge and experience to bear in ways that enhance regulatory processes and achieve management objectives more efficiently. Collaborative partnership between managers and fishermen, and strategies to align economic incentives with quality management and monitoring, can also be supported by revisions to policy frameworks. This is all the more urgent as rapid and unpredictable climate change ups the role of

more intensive monitoring to understand changing resource status and economic vulnerabilities tied to these changes.

Against a backdrop of rapid climate-driven ecological change, it becomes harder to associate any human actions with ecological response with high degrees of certainty. Thus, in the future it may be less likely that any human action (whether harvest or management) will yield predictable responses in a fish population. There will be climate winners and climate losers, and the Commission must ensure that its policies enable the winners while supporting the losers as they transition to other opportunities.

This regime of ecological uncertainty differs from the steady-state management approaches conceptualized by the fisheries scientists of the last century, and from the fishing-driven ecosystem change that intensified around the turn of the century. A suite of management actions designed to reduce fishing pressure by rationalizing fisheries and implementing networks of MPAs have led us to an era in which the level of fishing effort for many fisheries in California is at historical lows for the past 50 years, while the intensity of climate stressors has climbed. The socioeconomic consequences of these actions have been severe: losses of opportunity, infrastructure, and confidence are rampant; these profound losses were articulated repeatedly during each of the fishing community meetings.

This reality leads should lead to a new conceptual framework by which to approach natural resource management: California must take proactive and innovative measures to manage for socioeconomic and ecological resilience in our fisheries. Steps must be taken by agencies to bring fishermen and managers into alignment on how these measures are designed and how they are implemented.

The draft report contains several recommendations that our organization agrees with, but it would be strengthened by additional content and sophistication. We suggest including an additional goals and objectives section of the report and aligning the final recommendations with the goals and objectives contained therein. Goals and objectives should be informed both by a thorough analysis of existing Commission and CDFW mandates to preserve and protect fishing communities, and any additional goals and objectives not explicated in statute that were elucidated during the community meetings. We stand ready to assist in this regard, including facilitating dialog between members of the commercial fishing industry and Commission staff/members as time and availability allow.

Here we provide several recommendations that build on the draft contents of the Fishing Communities Report:

  1. The report should include a review of the current mandates dealing specifically with fishing communities found within the Fish and Game Code and/or driven by the state’s coordination with federal management processes under the Magnuson-Stevens Act.

  2. The report should more specifically reference and reflect the provisions reviewed based on our recommendation (1) and, specifically, the MLMA’s various mandates for supporting fishing community needs.

  3. The report should include a new section listing goals and objectives for managing marine resources in order to support fishing communities, and it should specifically align the final recommendations with those goals and objectives where appropriate.

  4. The report should include a section on the public trust, including a discussion of the Commission’s various mandates to preserve access and enhance beneficial uses, as well as discuss how these relate to fishing community needs identified in the fishing community meetings and elsewhere.

  5. The report should focus on innovative approaches to data and collaboration with members of the fishing industry. The time is now to deploy an arsenal of ecosystem and fisheries indicators built on fishing behavior and fisheries-dependent data. Engaging fishermen in fisheries-dependent research while refraining from prescriptive and costly monitoring mandates whenever possible aligns fishermen with managers, facilitating trust and partnership. Let’s invest in pushing digital data collection systems by the Department and smartphone platforms for engaging fishermen in monitoring on the water. With these new tools and capacity, collecting more comprehensive data on size structure of catch and CPUE are cost-effective.

  6. The report should focus on recommending new approaches to enhanced local co- management, which are urgently needed as fish stocks shift their locations with warming sea temperatures. Importantly, however, a management regime focused on increased flexibility also comes with pitfalls. Stock assessments and fishery management plans must be designed to enable flexibility during and between cycles. In addition, Experimental Fishing Permits should become a standard part of the management repertoire, and the Commission should familiarize itself with them and become comfortable adjudicating their use.

  7. The report should include recommendations for the review of the Commission’s and Department’s budget processes with respect to supporting fishing communities, including a review of the funding for mandates listed based on our recommendation (1). The report should include specific recommendations for how the Commission could best approach the forthcoming service-based audit of the CDFW in order to improve its mission and better meet the goals and objectives of the report based on our recommendation (3).

  8. The report should specifically address anadromous fisheries and the ways that the Commission can support communities that rely on them. The Commission’s regulatory authority includes approaches to supporting the integrity of public trust anadromous fisheries for the benefit of fishing

  9. Any new Fishing Community policy framework should be founded on and explicitly enumerate the reinforcing pathways between the biological sustainability of fisheries and the economic sustainability of fisheries. Further, Fish and Game Code needs fleshing out on the mechanisms for the Department to prioritize minimizing adverse impacts to fishing communities, responding quickly to environmental and socio-economic factors harming fishing as a livelihood, and communicating with fisheries stakeholders.

  10. The number and quality of tools available to managers is a limiting factor in being able to respond adaptively to environmental change, especially in ways that are protective of the economic stability and success of fishing. Permit stacking (e.g., the Bristol Bay gill net sockeye fishery) is a great example of how a fishery can adaptively expand and contract with the resource with a mechanism that is economically rational.

  11. Challenges to access and changes to access are the prime message of the report. We urge the Commission to make limited entry reform a priority. A blue-ribbon panel, which is representative of stakeholders and chaired by 1-2 commission members, could be tasked with producing a set of detailed, well-researched recommendations on how to align the limited entry policy.

  12. The report should make specific recommendations for the support of redeveloping and maintaining port infrastructure. We incorporate by reference comments provided by the Alliance of Communities for Sustainable Fisheries and Mr. Mike Conroy, regarding infrastructure support, particularly the suggestion of the State-level adoption of the MSA’s Community Sustainability Plan program, which provides a framework for implementing an analysis of community needs in a structured and uniform basis.

  13. Market access and market dynamics must be considered in assessing the impact and effectiveness of new management actions. To do so, fishermen should be engaged as co- designers of new permits to make them economically feasible.

  14. The report should encourage the development of innovative solutions to mitigate risk in commercial fisheries in the face of climate change and uncertainty. Financial tools to mitigate risk can add to the strategies for rapid recovery from fisheries disasters.

II. Ideas for improving the quality and utility of the report

  1. The synopsis of answers to the 4 core questions gathered at the meetings is a highly valuable product, and as such, we feel that the descriptions of topics under Questions 2 and 3 could be fleshed out. Relative to the very informative information under Question 1, these two are fairly brief and unclear in places.

  2. In Question 2, more detail on the context in which these 4 listed adaptation strategies played out is important to document. Can you provide any insight into which of challenges listed in Question 1 (or something else) were mentioned as the likely triggers and causes of these adaptations? Did you hear perspectives on how well each of the adaptation strategies worked? Whether they had lasting positive or negative impacts on the nature of commercial fishing operations in the ports? Were these changes mostly permanent or temporary? Also lacking from the list is the frequent scenario in which fishermen must turn to public or family assistance because they do not find ways to implement these adaptation strategies. This is important to document here. The fisheries closures that led to Federal Disaster Assistance provide examples of this that are well documented in State senate hearings, etc.

  3. The descriptions of topics under Question 3 are sometimes unclear and should be explored and developed more completely. What does ‘streamlined’ refer to? Could an example or two be given? Why should ‘marine protected area collaboratives’ be embraced, and what value do they provide to efforts to support communities? What does ‘electronic representations’ mean? ‘Modernization of facilities’ is vague. Each of these bullet points deserves at least 2-3 sentences of description, context and use of examples where possible.

  4. Permit transferability, a critically important issue area for this report with a vast amount of complexity, is repeatedly mentioned in the report with little background or context. The report would benefit from an introduction to the topic within the ‘synopsis of perspectives. This is an important component of access that isn’t mentioned in the section on ‘fisheries management changes and access.’

  5. The Recommendations section begins by pointing out that each suggested action gathered and listed in the report could be labeled as ‘Management’ ‘Policy or ‘Other.’ Perhaps this could be actually done in the report? It would add clarity, inform expectations, and help focus the conversation moving forward.

  6. The stated goal was to develop potential ‘pathways forward.’ This effort presumably will be founded on the list of 8 stated recommendations at the end of the report. Many of these recommendations are lacking a basic definitions, a statement of reason and justification. Below are suggestions for strengthening the clarity and utility of these recommendations:

  7. The 1st priority listed needs a bit more clarity, given its top position. What is meant by this and what role it would play? For instance ‘This policy would be a vehicle for addressing x, y and z...” or “This policy would fill a gap that exists...” How might this policy might be generated? Are there examples elsewhere to draw from and/or ideas of what it might include?

  8. The 2nd recommendation could be strengthened by focusing on generating changes to the policy in response to a review of the past performance of the policy.

  9. The 3rd recommendation begs for an example. Please define what ‘small-scale fishing opportunities’ refers to or is defined as, and explain what is meant by ‘information gaps.’

  10. The 4th recommendation is somewhat obvious and vague. Can you explain how this should be done differently than how it is already being done?

  11. The 5th recommendation also needs sharpening and focus. There is one prior suggestion in the report that CDFW engage more with PFMC, but there is no context as to why and how? We assume that there is good justification for this, but without explaining the justification, it is difficult to motivate follow through and guide it to be done effectively. Please replace ‘etc.’ with named entities. To recommend that CDFW just engage ‘with everyone more’ is not effective advice.

  12. The 6th recommendation is concrete and specific - a good example to borrow from in how to improve the other recommendations.

  13. The 7th – did the set of community meetings provide any starting list of specific data gaps and examples of collaborative research to build on? This should be included as an appendix.

  14. The 8th – Can you describe this in more detail so it doesn’t appear to be asking for the same process to be repeated? Perhaps the report could include a section on information that was sought through the process, but not well acquired. Describe which topics were difficult to inform through stakeholder engagement, and which have been well informed.

  15. In appendix A, please use full sentences in order to communicate these ideas clearly, and leave less chance of misinterpretation. Examples: what does ‘decreased food system viability’ mean? Complete the sentence: ‘Fishery and area closures are...”

  16. . Please consider creating transcripts of the meetings so that they can be more fully utilized in the study of fishing communities.

We applaud the Commission’s time and attention to this critical matter for our members, and we stand ready to assist in the completion of this report. Please don’t hesitate to contact us with any questions or to continue the conversation. We look forward to reviewing your responses to these comments.


Noah Oppenheim Executive Director, PCFFA

Kimberly Selkoe, Ph.D.
Executive Director, Commercial Fishermen of Santa Barbara Marine Scientist, UC Santa Barbara

Chris Voss
F/V Bella “B”
President, Commercial Fishermen of Santa Barbara