Biodiversity Policy Engagement Analysis
Biodiversity Lobbying Overview: The Pacific Seafood Processors Association (PSPA) has predominantly negative engagement with biodiversity-related policy. PSPA has generally cautioned against increased regulation to address habitat change and overexploitation of species.
Top-line Messaging on Biodiversity Loss: PSPA has limited high-level messaging on biodiversity loss. In a comment to the Department of the Interior in 2022, PSPA recognized some of the science of biodiversity loss but attributed it solely to climate change. On its website, accessed in February 2024, PSPA states broad support for government policy in Alaska aligning with sustainability but has not taken a clear position on the need for regulation to respond to biodiversity loss. In a 2023 position paper, PSPA describes the cost of compliance with environmental standards as a concern for the industry.
Engagement with Biodiversity-Related Regulations: PSPA has engaged on policy relating to habitat change, overfishing and pollution.
On its website, accessed in February 2024, PSPA states support for existing marine protected areas in Alaska. However, in regulatory comments, PSPA has consistently opposed the creation of additional marine protected areas. In November 2020, PSPA signed a joint letter opposing the 30 x 30 target, to protect 30% of the nation’s land and sea by 2030, under the Ocean-Based Climate Solutions Act. In a 2021 hearing organized by the National Oceanic and Atmospheric Administration (NOAA), a representative of PSPA appeared to warn against additional area based closures and argued that restrictions would lead to increased imports of fish from countries with less stringent environmental regulation. In December 2022, PSPA opposed the emergency closure of the Red King Crab Savings Area and Subarea to fishing in comments to the National Marine Fisheries Service (NMFS).
PSPA has taken some positive positions on policy intended to reduce overexploitation. In October 2022, PSPA signed a joint letter which supported improved measures to avoid overexploitation in Alaska to ensure continued sustainability certifications. However, the majority of PSPA’s engagement on overexploitation has been oppositional. PSPA has consistently opposed the expansion of the Seafood Import Monitoring Program (SIMP) to additional species, for example in comments to the Environmental Protection Agency (EPA) in 2023. In a letter to the United States Trade Representative in 2021, PSPA stated the expansion was “inspiring some countries to respond in kind, with requests for equally burdensome and unrealistic requirements”. PSPA has also opposed specific restrictions in comments to the Alaska Board of Fisheries, including a proposal to reduce certain fishing periods in March 2022 and restrictions on salmon fisheries in September 2021.
PSPA has limited but positive engagement on biodiversity loss due to pollution. In comments to the EPA in 2020 and 2022, PSPA strongly opposed the Pebble Mine project, which the EPA ruled would have "unacceptable adverse effects on certain salmon fishery areas in the Bristol Bay watershed".
Positioning on Statutory Protection of Wildlife: In comments to the NMFS in 2023, PSPA opposed the proposed listing of the Pycnopodia helianthoides (sunflower sea star) as endangered under the Endangered Species Act.