Herring Scrap 28 - Herring Revitalization Committee pt 2

Back in March, I posted a scrap explaining the emergence of a State of Alaska policy vehicle called the Herring Revitalization Committee (HRC). It seemed that the point of the committee, before it even began, was designed to promote the "restructuring of the Alaska herring resource." I was worried it could herald an era of intensified herring fishing in Alaska. Now, months later, some wheels have turned, there's more information, I'm more worried.

When I last wrote on the HRC, the committee was about to be formed in time for a pair of initial meetings, to be held on April 2nd and April 12th. This week, HRC is on the Board of Fisheries calendar again - twice actually, first at the Board of Fisheries Work Session on Oct 29/30, and then in a standalone HRC meeting on Oct 31st.

The committee signals the intent from the State of Alaska to relax and redefine herring permits in Alaska. Key decision-makers are driving towards expanding opportunity in time and space for commercial herring permit holders. The ball is rolling and the implications could be huge, and I want to make sure people know it's coming. Nobody has really written about it, and decisions made at and around the upcoming Board of Fisheries meetings in Cordova in December, Ketchikan in January, coupled with decisions made by the Commercial Fisheries Entry Commission (CFEC), could unleash massive fishing pressure on herring stocks in across Alaska.

At the same time, those same processes could also mark a turning point to firmly limit the harmful intensity of sac roe herring fisheries in Alaska, to find something that might work. Change is being signaled. Change can be good. Will it be?

What follows is my best effort to fairly capture what the Herring Revitalization Committee seems to be about. Hint: the committee meetings aren't the important part.

Two Meetings

The Herring Revitalization Committee (HRC) was announced in March, and a hasty call for committee members was made. April 2nd marked the first meeting of the committee panelists (each of them an appointee of Governor Dunleavy): Commercial Fisheries Entry Commission (CFEC) Commissioner Glenn Haight, Board of Fisheries Executive Director Art Nelson, and Board of Fisheries members Tom Carpenter and Gerad Godfrey. Their task was to build a committee from those who had answered the call for nominations.

It went much like the Upper Cook Inlet Board of Fisheries meeting in March (described in scrap 23) where this whole notion of the Herring Revitalization Committee first emerged: Glenn Haight (who had been Executive Director of the Board of Fisheries for some years) ran the show and got what he came for: a committee of 11, representing commercial fishing and processing interests with one subsistence seat. The vetting process was chummy and expedient, without the least bit of contentiousness, disunity, or hesitation. Some nominated people weren't mentioned at all; nobody fretted over process.

At the second meeting - the first (and only, so far) meeting of the newly assigned committee, the purpose of the committee was explained and everybody had a chance to introduce themselves and to say a bit about the barriers and opportunities they face as (mostly) holders of herring permits or processing operations in Alaska.

The general sentiment was that market and regulatory conditions were preventing seiners from making money off of herring, and that it would be nice to be able to have permission to fish herring in more places in more seasons for more markets.

I'm not going to get into specifics about the meeting here - it was chatty and informal, b-reel for regulatory theater - but below the main text of this scrap, I've listed committee membership (it otherwise is nowhere on the internet as of this writing) and included one lengthy quote from each committee member or panelist from the meeting in case you're interested.

What Does this Committee Exist To Do?

The Committee is a vehicle for regulatory review. Here is what Glenn Haight wrote on behalf of the Commercial Fisheries Entry Commission (CFEC) to the Alaska Seafood Marketing Institute (ASMI) (bold emphasis mine):

"Through a cooperative joint committee on herring revitalization, the Board of Fisheries (board) and Commercial Fisheries Entry Commission (commission) are taking an opportunity to review the commercial herring industry with an eye towards modifying our separate governance structures. In parts of the state the commission permits herring fisheries by product form, something not done for any other fishery. As markets change this permitting structure boxes in permit holders who could otherwise fish at a different time and better utilize the resource. If we are to unwind this longstanding system, we need to go down legal paths not yet walked. For the board, their work is arguably not as complicated, but they are the best venue for reviewing and changing fisheries in Alaska. The commission would prefer to follow their lead in that work."

The section in bold represents the major (de)regulatory project in play here for the CFEC: "to unwind this longstanding system" of permitting by product form. The CFEC can't really do that unilaterally, and they see an easier path if it happens in lockstep with action at the Board of Fisheries level. That's why the schedule described in the committee's charge statement wraps up in January, in time for the Board of Fisheries meeting in Ketchikan dealing with Southeast Alaska herring.

If the CFEC goes ahead and turns all of the current herring (sac roe) permit holders into herring (food/bait) permit holders, then that change will not be functional without matching change from the Board of Fisheries. And the thing is that if the goal is to make space for the production of other products – that means changing the season too. This is about freeing up sac roe permit holders to catch fat herring in the summertime and fall, when their value is higher for most purposes, whether as bait, food, fish meal, or oil. Removing restrictions to product form necessarily means also removing restrictions in time and space. Setting those rules to match changes to CFEC permit structures is what could happen at the Board of Fisheries meetings in Cordova and Ketchikan in the coming months,whether or not in response to existing proposals, making those meetings extra-consequential.

So what else is this... uh... committee... doing?

Last month, the Commercial Fisheries Entry Commission published an Optimal Numbers Study for the Kodiak herring food-and-bait fisheries. Optimal Numbers studies are done to assess how many permit holders in a fishery yields the best economic result in a workable management context. Back in Scrap 23 I described how the Herring Revitalization Committee thing started out of a Kodiak-area proposal to allow sac roe permit holders to fish in other seasons for other products - this Optimal Numbers study was prompted by those same conversations. And so the result is noteworthy, not just for Kodiak but all of Alaska:

The study predicts that the herring sac roe market is dead and not coming back. Specifically, the report says: "we present what has occurred in the past and predict that the sac roe markets will not return." This isn't surprising, especially for people who heard the recent 5-part series of stories by Katherine Rose of KCAW (part one, two, three, four, five) to attempt to find any evidence that there's still a serious market for Alaska sac roe in Japan.

The CFEC's Kodiak Optimal Numbers study seems to reach the conclusion that the best way forward lies in Board of Fisheries action to convert the entire Guideline Harvest Level (GHL: the portion of the biomass allocated to commercial fishery) into Food/Bait GHL instead - only if that happens, the report seems to say, can Kodiak permit holders and managers have their needs provided for. I see no reason reason to think that they wouldn't wish to extend that same premise statewide. And that would be a huge change.

If that premise is applied, then suddenly conditions could be ripe to turn on the machinery that would allow for expanded time-and-space herring fishing efforts statewide. Without appropriate regulatory checks, these could take the form of high-intensity reduction fisheries - akin to those widely credited with wiping out herring populations in the early-mid 1900's, allowing that earlier form of harmful herring fishery to proliferate once again in Alaska. I don't know if it will actually happen that way, I only mean to flag that it could happen and quickly.

In that model, various food products will be promoted as the principle product of the fishery; markets may be developed through Global Food Aid programs and other subsidies (link is to Alaska Seafood Marketing Institute's 2024 Global Food Aid budget document), while the real steady money is being made from the scrap by–product: fish meal, pet food, fertilizer, oil, etc (link is to ASMI's 2022 Alaska Herring Market Recovery report). Unlike most herring food products, there's a bottomless appetite for those by-product products in this world and it could happen fast and it could accelerate the stripping of Alaska's coastal ecosystems of keystone forage fish.

And that's what I want to say today! More shall be revealed by this week's meetings I suppose. I mentioned that I'd include the committee membership and some quotes from the April 12 HRC meeting. You'll find that below. I'll follow up tomorrow with a post about some of the Proposals currently on the table for the Board of Fisheries, as Sitka's Local Advisory committee to the Board of Fisheries is meeting to discuss herring in the next couple weeks.

Best,

Peter

April 12 meeting (you can re-live it here on youtube)

The April 2nd meeting produced the following committee membership; this full group convened on April 12:

Panelists:
CFEC Commissioner Glenn Haight
Board of Fisheries Exec Director: Art Nelson* (I'm not certain, actually, of Art Nelson's role in all of this. He may not exactly be a panelist and may be functioning as more of a convenor).
BoF Member: Tom Carpenter
BoF Member: Gerad Godfrey

Committee Members:
Alaska Seafood Marketing Institute rep: Bruce Schactler
Subsistence: Mike Miller
Processor: John Woodruff
Commercial: Sam Mutch
Justin Peeler
Frank Woods
Former ADF&G staff / Former Director of Commercial Fisheries / : Jeff Regnart

Quotes from April 12 Herring Revitalization Meeting

"And we've got some technical changes to our system that we could make or meet or need to make. They're complicated to unwind some of the stuff we have, it's a lot of legal issues to figure out. So like to use this forum, as part of that, understand how we might be able to do that fairly. But at the same time, since we're here talking about herring, I think I think it would be great if we could really explore some of the aspirational things that folks are looking at things that Bruce has been talking about for years, what markets can be developed, how can we start to turn some of the wheels of the public sector such as ASMI more focused on on getting into those markets? And what are they? I don't know, I don't know how far we can get into that in less than a year, because some of that might take some some real research, but it sure would be great to kickstart some of that." - Glenn Haight, CFEC Commissioner, Herring Revitalization Committee Panelist

I would just echo what Glenn said, more than anything on priority is to listen and listen and learn, and especially about the aspirational aspects here. So look forward to discussion. - Gerad Godfrey, Herring Revitalization Committee Panelist and Board of Fisheries Member

"My personal opinion is, I think this conversation is, is long overdue, specifically in a statewide forum, because there's, there's a lot like I said, there's a lot of under utilized resource out there that I think that we need to consider looking at."
- Tom Carpenter, Herring Revitalization Committee Panelist and Board of Fisheries Member

"Most of the access to herring, the access is the sac roe limited entry permits. And so one of the things that I'm interested in hearing is from people around the state, if they would like to develop new markets, and they, you know... It's kinda hard to take something away from a sac roe limited entry permit holder that once probably made quite a bit of money holding that permit, but probably doesn't today. Most of them probably haven't put their net in the water around the state in quite a long time. So I'm really interested to hear from people that hold those permits, if they are willing to kind of possibly look at the potential to open up other markets and other times of the year, but they would also have to potentially give up some access if the sac-roe markets were to ever come back. So that's just something that I think about." – Tom Carpenter, Herring Revitalization Committee Panelist and Board of Fisheries Member

So what are the paths? I've been thinking about it a lot. And it's a it's a monumental kind of thing in front of us. Where do you go with this – How do we get more people participating? How to get – number one is you need markets. And some value.

One of the things I looked at was, you know, and it's, it's, it gets a, it might get a sigh, but you look at fishmeal, and you look at oil prices: fish meal prices have been going up, I think they are 1850 a ton right now, for fish meal; it takes four or five tons of raw product to make a ton of fish meal. And then there's also the oil value, which is a pretty good number.

And my understanding is that there's maybe some state regulations against using a product just for fish meal, I haven't seen those but I'm I'm told there might be something at the state level. And then I'm also told that on the federal level. National Marine Fisheries has kind of said we don't want to go down that road of any new fisheries, doing reduction. But like the Menhaden fishery out of Florida, I think that was maybe grandfathered in for that discussion. But I don't really know the details of it.

So I mean, that's a possibility of something to look into when you have these, these monster herring classes that are huge. It's, it's a way to maybe get some product moving and give some opportunity to coastal communities. Other than that, you know, when we look at the food thing, we need to look at that too. But there's some monumental obstacles there with shipping prices, things like that. So hopefully, we can focus on some things that could just help fisheries around the state.

- Sam Mutch

It'd be so much easier if it looks like there– or it can be demonstrated that there's some kind of conservation benefit. And that could be something like, you know, not focusing on the spawning fish, which has always been an issue in the tribe. Increased research, I think is something that would be a common theme that tribal folks could could support, and increased opportunity. In line with what Frank was talking about it's easier if it looks like there's increased opportunities. And realizing we're in, you know, our towns are in a tough place, man, the tribal and non tribal people of having a hard time affording to be in our own towns. And so it's important, I think, to look at new opportunities to, for for folks that are here." - Mike Miller,

"I think it's important to note that as markets changed, and people had an idea, the state of Alaska has a history of changing the format of the herring fisheries and, you know, that's why I'm here is because I'd like to see some changes made to Southeast Alaska food and bait. It's a hard fishery, it's, it's, you know, just like any winter fishery, it's, there's those difficulties, but also, you know, in southeast Alaska, we're limited on our net, and that has a big profound impact. If you can't get a steady product to the plant, the plant can't operate at a level, therefore, you know you, you don't really lose your market, but it becomes impossible to do and not profitable for anybody. So, you know, with that being said, there are years that the current net works great, but there are years where you're just driving around looking at 1000s of tons of herring that you can't touch. And so without consistency in that fishery and the right tools, you're not going to see it utilized." - Justin Peeler

"What I'm thinking is a Bristol Bay Coalition for the Bering Sea. And what I've come up with is community harbor quotas to guarantee if we do secure markets, we have a secure supply for those markets. Right. So in that arena, I posted the Native American agriculture fund, just for ideas, because that outlines to actually give us federal dollars for planning, production and marketing of this food fish." - Frank Woods

"I guess, when you talk about markets, when you talk about what you're going to do with this stuff, you can explore a lot of stuff a couple things, though, that that are gonna get in your way. One is consistency of supply. Just like Sitka, it's huge now, it's been very small in the past so if you're if you're planning on harvesting a bunch of fish and getting into a market that wants it year after year, that's going to be a consideration for sure. How do you - how do you provide consistency of supply? Because nobody's gonna want to take your resource, which is going to be a product they're going to do something with and suddenly find out oh we don't have so much this year. The other piece is going to get - it gets in the way of Alaska constantly. And that's logistics. It's almost as expensive to ship herring frozen from Sitka to Dutch Harbor, as it is to buy the stuff and process it. It's almost that expensive. So logistically, Alaska's got, you know this, huge challenges. And that's another thing that's going to get in the way. I, I encourage people to, and I know who Bruce have talked about. But whatever we can do, but there are lots of impediments. And economics is certainly going to be a big issue, and we've got to buy the stuff, you got to process it somehow in Alaska, and then you got to ship it to a place where somebody is going to make something into it that people are going to consume or pets are going to consume." - John Woodruff

"We have to understand what product form is going to sell in today's market. We know it's not what we've been doing. What we've been doing isn't working anymore, as far as you know, at least economically viable herring fishery in most places, they have had herring fisheries historically. So what is that product form? You know, if you want to ask me and Bruce can, can speak to this. They're gonna say, Okay, we'll sell it. But what's the product for? What what are we actually going to push out into the market? And so that we have to help answer the question." - Jeff Regnart

"So if you get into a different product form, for example, like Sam said, we have here in Kodiak, and I think that Petersburg's got a meal plant also... I'd say 50% of the North Sea herring, most of the mackerel, almost all the capelin, that all goes into meal and oil. I mean, hundreds of 1000s of tons into the meal and oil business. But I for example, just last week, for the our food aid program, I took some bait - Sam I'm sure caught it - I had it locally hand filleted and ended up with about since it was a bait product, and it's not handled like food. There was a lot of - we only got about 30% recovery. But those I had custom canned for presentation, because I'm doing the end of the month in Washington DC, or international food aid. I never, you can't get your home pack, you got to have it commercially canned. And that's their request of new products, shelf stable products that can be used. Well, you go back there and, and and let's let's say they decide they want, you know, a million cases, which isn't that much when you look at the six ounce can to go to I don't care Ukraine, Somalia, it's back to what Frank mentioned, as a guaranteed supply. Can't do anything here, we have no opportunity to get into the business of guaranteed supply, which is year round, if we don't have access to it" - Bruce Schactler