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THE PACIFIC COAST FEDERATION
OF
FISHERMEN'S ASSOCIATIONS


From Fishermen's News of November, 2008

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Offshore Drilling -- It's Back
"Drill, Baby Drill," Really Burn, Baby Burn for Fisheries

By Zeke Grader and Glen Spain


Well, it's back. After nearly 30 years, widespread offshore oil drilling is once again on our near horizon. Not much has changed though, despite promises of new technology, since the fishing industry last worked to halt oil and gas drilling that threatened coastal fish and fishing three decades ago.

If there is any difference now, it's only in the panic that has occurred at the pump and the carefully orchestrated clamor that has reached the crescendo fervor pitch of "Drill here, drill now," and "Drill, baby drill" in the recent political debate.

This is not good news for the fishing industry. Fish stocks are once again placed at risk, fishing is made even more difficult and, worse, the amount of oil that's in question -- and the timing of when it could possibly be finally developed -- won't make a dime of difference in the price paid for diesel at the fuel dock.

With a concerted push for more offshore drilling, including proposals to even open the marine sanctuaries, and seemingly little pushback from either traditional foes of drilling in Congress or environmental groups, the PCFFA Board last month formally reaffirmed its 30-plus years of opposition to offshore drilling. The action by the PCFFA Board was out of a commitment to review past policies, but also to let politicians and other public officials know there was strong opposition from at least some in the fishing community to new drilling.

PCFFA's Board action was followed by the 16 October United Fishermen of Alaska (UFA) letter to the U.S. Minerals Management Service (MMS) calling for strong fishery protections in the North Aleutian Basin OCS [Outer Continental Shelf] oil and gas lease sale which is now underway.

What has happened that has taken offshore oil from being a relatively minor issue to becoming a major force to now be reckoned with amidst all the other maladies facing our fisheries? Let's review the problem, how we got to the present situation, the alternatives and what can be done.

Commercial Fishing and Offshore Drilling -- A Troubled History

Following the gas panic after the Arab nation cut-off of oil exports to the U.S. in the late 1970's, the Carter Administration proposed new oil company leasing sales around the nation, in addition to the already developed tracts in the Gulf of Mexico and Santa Barbara Channel. One of these lease sales -- OCS Lease Sale 53 -- was to extend all the way from the Santa Barbara Channel to the Oregon Border, encompassing many prime west coast salmon, crab and groundfish trawl grounds.

Initially courted by some oil companies, the PCFFA Board, based on the experiences of its members from Santa Barbara, formally voted in 1978 to oppose Lease Sale 53 and any new drilling along the coast. It was not the big spill that had occurred just 10 years before off Santa Barbara that was so troublesome as just the day-to-day problems of dealing with the drilling by fishermen trying to operate along a relatively narrow shelf. There would have been displacement and loss of fishing grounds, trash from the drilling operations, scaring of fish stocks by the seismic boats, the chronic small (and mostly unreported) spills and pollution from the drill muds and other similar problems. Fishing was seen as sustainable, drilling was not. PCFFA was not alone in this position. Trawl and other fishing organizations from Massachusetts to Alaska joined us in opposing more offshore drilling.

The adverse impacts of offshore drilling begin with disruptive seismic survey airgun operations and continue with routine day-to-day toxic discharges of heavy metals and mutagenic hydrocarbon compounds into the ocean, even during normal operations. In spite of the much-touted "new technology" on the Outer Continental Shelf, chronic damage to the marine environment is still very much a part of every step of offshore drilling activities, including the following:

(1) Seismic Airgun Survey Impacts On Marine Life: The initial exploratory phase of offshore oil and gas activities involves the discharge of thousands of high-intensity blasts from powerful "airguns," creating a strong shockwave throughout the ocean that pounds into the seabed.

Because water is an excellent medium for the transmission of sound, seismic airgun exploration has been directly associated with mass strandings and resulting mortality of whales and other marine mammals, and with decreased fish catch in the impacted region. Permanent damage to the acoustic receptors of various fish species has also been well documented, and the hearing capacity of fish enables them to avoid predators, locate mates, and find prey.

The "Eggs & Larvae Committee," established in the 1980's as a fishing-oil industry collaborative to look at seismic impacts on fish found that the blasts caused major mortality for young anchovy. Fishermen were already aware of the "spooking" the testing caused on adult fish stocks of many species.

(2) Routine Discharges Of Offshore Drilling Wastes: During normal drilling operations for oil or gas, drilling muds are used to cool and lubricate the drill bits. Once the useful properties of drill muds are exhausted, large volumes of spent drill muds are simply discharged over the side of the drill rig directly into the ocean. Each well drilled produces, on average, 180,000 gallons of drilling mud and cuttings. Dumping of spent drill muds spreads plumes of turbidity as the "fine" particles spread throughout the water column, and the heavier components of the discharge accumulate on the seafloor to smother benthic organisms and other marine life.

These discharges also customarily contain toxic materials known to bio-accumulate in the ocean food chain leading to humans. Of primary concern are toxic heavy metals like mercury, chromium, barium, arsenic, cadmium, and "Polycyclic Aromatic Hydrocarbon" compounds (or PAHs), all found to cause life-cycle mutagenic damage to eggs of pink salmon in the years following the Exxon Valdez oil spill at levels of only two parts per billion.

In addition, what are known as "produced waters," which originate from subsea aquifers, are brought up with the oil or gas, and hundreds of thousands of gallons of often toxic produced waters are subsequently dumped into the ocean.

In many geologic settings in the Gulf of Mexico and elsewhere, produced waters contain radioactive radium, and the resulting discharge is the source of a radioactive plume trailing from the rig on the ocean currents. Radium is readily taken up by marine life and also bio-concentrates in the marine food web.

While regulations now require drill muds from operations offshore California to be disposed of safely onshore, the same is not true elsewhere. In the Gulf of Mexico, for example, high levels of mercury have been found in recreational anglers eating fish caught around oil platforms. Researching and reporting on the cause in 2000, the Mobile Press-Register not surprisingly found that fish feeding around the oil rigs had elevated levels of mercury compared to those found elsewhere in the Gulf. The source of that mercury was determined to be the drill muds.

(3) Accidental Oil Spills From Rigs: In recent years, oil spills from offshore exploratory and production rigs have often resulted from equipment failure or human error, or a combination of both. Computerized equipment, not subject to constant monitoring and human oversight, has resulted in uncontrolled discharges of oil at many operations in various locations.

Drilling advocates (including certain radio talk show hosts) have often cited oil industry propaganda claiming that there were no oil spills caused by hurricanes Katrina or Rita in 2006. Even a cursory information search shows that claim to be nonsense. Official government reports demonstrate more than 741,000 gallons of oil was spilled from offshore oil rigs damaged by Katrina (see: www.mms.gov/ooc/press/2006/press0501.htm).

After Hurricane Katrina, oil spills were so pervasive that remote sensing equipment using Synthetic Aperture Radar on the "Radarsat" Canadian orbital satellite detected extensive slicks of highly-toxic liquid natural gas condensate, a light oil, spreading throughout the Gulf of Mexico from damaged offshore natural gas drilling infrastructure at the Apache Field. The US Minerals Management Service listed 113 Gulf of Mexico oil platforms as destroyed in 2006 by hurricanes Katrina and Rita, with hundreds more seriously damaged.

Hurricanes of the scope and destructive power of Katrina are expected to become more common in the future, as well as more frequent in higher latitudes, due to the accelerating impacts of worldwide climate change.

Routine discharges of pollutants to ocean waters and the atmosphere are virtually identical for oil or for natural gas operations, except that every phase of gas production also releases fugitive emissions to the atmosphere from leakage from wellheads, compressors, and pipeline and processing components. Natural gas is a powerful accelerant to global climate warming.

The worst case oil spill from an offshore rig in the US was the Ixtoc I blowout incident on June 3, 1979, when a US rig operating 600 miles south of Texas lost drilling mud circulation, ran into high pressure gas, and suffered a blowout in which the oil caught fire and the platform collapsed. In the next few months, approximately 10,000 to 30,000 barrels of oil per day were discharged into the Gulf of Mexico until the blowout was finally capped the following year, on March 23, 1980. At one time during this blowout, ten percent of the surface of the Gulf of Mexico was covered with oil slicks or sheen, and tar balls washed ashore on the beaches of Padre Island in Texas.

"With the nation now debating whether to open more areas offshore to oil and gas drilling, the oil industry can rightly claim it has avoided a repeat of that [1969 Santa Barbara Channel spill] catastrophe, even as offshore activity has ballooned," the Houston Chronicle reported on July 19th, 2008. "But offshore operators continue to spill thousands of barrels of oil, fuel and chemicals into federal waters each year, government records show."

(4) Oil Spills From Pipelines And Tankers Transporting Offshore Oil: California's "Torch" pipeline oil spill, and Alaska's Cook Inlet "Cross-Timbers" oil spill, represent recent examples of highly-automated subsea oil pipelines that have leaked for extensive periods of time without the source of the leaks being detected.

Since any oil produced from offshore drilling operations that lie beyond existing pipeline infrastructure is inevitably transported by barge or tanker to refining centers, there is also a constant risk of a tanker spill that can originate from any point in transit. Modern oil tankers are much larger than the Exxon Valdez that ran aground and spilled its oil 30 years ago, and a spill from one of these super-takers could be even more catastrophic.

In addition, massive floating offshore oil storage facilities, now being expanded in the Gulf of Mexico and planned for other regions, represent an increasing risk of very large spills.

(5) Air Pollution From Offshore Drilling Operations: Oil and natural gas drilling and production operations offshore generate a suite of air pollutants, including ozone, oxides of nitrogen, and sulfur compounds. Each gas well releases 50 tons of nitrogen oxides (NOx), 13 tons of carbon monoxide, 6 tons of sulfur dioxide, and 5 tons of volatile organic carbons (VOCs) each year. The platforms themselves annually generate another 50 tons of NOx, 11 tons of carbon monoxide, 8 tons of sulfur dioxide, and 38 tons of VOCs.

Because drilling rigs offshore lie outside of the regulatory jurisdiction of onshore air quality management districts, coastal states generally have little authority over air emissions from the rigs. Tankering and barging also generate emissions from the transportation of produced crude oil, both as a result of the burning of vessel fuel and from fugitive hydrocarbon emissions from the loading and offloading of tank ships.

In the past the emissions issue has been essentially one for local governments and the environmental community, but now as we're watching the Arctic ice cap disappear and oceans become more acidic as carbon is sequestered from the atmosphere, greenhouse gas emissions have to be a concern from fishermen as well -- both in developing and transporting the oil and gas and in its subsequent burning.

So How'd We Get Here?

Thirty years ago, in response to the offshore drilling threat, many commercial fishing associations joined with environmental groups (principally the Sierra Club, Natural Resources Defense Council and Friends of the Earth), as well as local coastal businesses and local governments in a David versus Goliath kind of battle against the oil companies.

Remember, at the time we were being told that offshore "drilling was inevitable" and to make our peace now with the oil companies. It got worse when Interior Secretary Cecil Andrus was replaced by James Watt. Watt, President Reagan's choice to oversee the nation's natural resources, championed offshore drilling literally with a religious fervor.

The first victory for fishermen and their allies was when Secretary Andrus agreed to confine Lease Sale 53 to the Santa Maria basin and south, sparing California's central and north coast fisheries from drilling. Watt too, in his extremism, helped the coalition stop new drilling; first off in California, later the nation -- including the Washington and Oregon coasts, the west coast of Florida and Georges Bank. Eventually previously leased areas of Bristol Bay were bought back.

Congressional leaders, including Leon Panetta (D-CA), Les AuCoin (D-OR), Ed Markey (D-MA), Barbara Boxer (D-CA) and Senators Alan Cranston (D-CA), Pete Wilson (R-CA), and Ted Kennedy (D-MA) worked through the appropriations process to cut-off DOI/MMS funding to pursue offshore leases. Finally, in 1982 Congress put in place its OCS Moratorium to include waters not previously leased along much of the nation?s coast, excepting portions of Bristol Bay and the Gulf of Mexico.

Of course, oil interests have always tried to keep the issue alive. In 1991, former oil tycoon and then President George H.W. Bush commissioned the National Research Council (NRC) of the National Academy of Sciences to conduct a one-year study to determine whether or not there exists sufficient scientific information to enable offshore oil and gas leasing to occur in the Congressional OCS moratorium waters and ensure that the environment could be protected.

After holding public hearings in various communities and conducting a year of deliberations, the NRC issued their formal findings. The NRC determined that there was insufficient scientific data available to permit leasing in these sensitive waters while securing adequate protection for the marine environment.

In 1992, President George H.W. Bush issued the first Executive OCS Withdrawals -- also known as Executive OCS Deferrals -- protecting the same geographic areas as the Congressional moratorium with this separate and second backup measure invoked via his power of Executive Order. The Bush Executive Deferrals set these areas aside initially until 2002.

In 1998, then-President Bill Clinton extended the Executive OCS Deferrals until June of 2012, and added the fishery-rich waters of Bristol Bay in Alaska to the Executive Deferrals, since Congress had since added Bristol Bay to the legislative moratorium during the intervening years. In the meantime, no substantial action has been undertaken by MMS to fill the specific scientific data gaps identified by the NRC since the issuance of their findings in 1991.

In spite of lack of scientific information on how to protect fisheries, in the fall of 2003 Senator Ted Stevens (R-AK) removed the House-adopted Congressional moratorium for Bristol Bay. Alaska. In January of 2007, the current President George W. Bush unilaterally rescinded the Executive OCS Deferrals for Bristol Bay. So in June of 2007 Bristol Bay was quickly included in the Minerals Management Service's (MMS) Five-Year OCS Leasing Program, which now proposes a Bristol Bay offshore lease sale scheduled for 2011.

Then earlier this year, as gas prices began to spike, the well-orchestrated and oil-industry inspired drumbeat began, to open the areas covered by the OCS moratorium.

First among those in Congress pushing for new drilling was former House Speaker Newt Gingrich (R-GA). Gingrich, who has taken on different consulting roles since leaving Congress and most recently is heading a 527 organization, called "American Solutions," is promoting a "Drill Here. Drill Now. Pay Less" campaign. That campaign has collected over one million signatures on its petition to Congress to act immediately to lower gasoline prices "by authorizing the exploration of proven energy reserves" off our coasts.

Gingrich even co-authored a book, Drill Here, Drill Now, Pay Less: A Handbook for Slashing Gas Prices and Solving Our Energy Crisis, with Vince Haley, as part of the campaign to convince Americans they could lower fuel costs by drilling offshore. American Solutions is heavily funded by Las Vegas billionaire Sheldon Adelson.

The White House with all of its friends in the oil industry was not about to be left out. They too helped orchestrate a broad Republican Party-adopted campaign to sell off the moratorium areas to the oil companies by telling Americans that this relatively small amount of oil offshore was urgently needed to "make America energy independent" and "lower the costs of prices at the pump." This immediately became a GOP marching song in a hotly contested 2008 Presidential election year, when the Republicans began picking up political traction with a public facing escalating gas prices.

So, on July 14th, 2008, President George Bush rescinded all his father's Executive OCS Deferrals, calling on Congress to lift its own moratorium as well. Then the Republican minority in Congress began attaching offshore oil drilling riders to every conceivable bill they could, however unrelated, and threatened to bring Congressional business to a halt over the issue. Since the Congressional moratorium sunsets this year, all the Republicans had to do was stall its renewal by the majority and it would expire by default at the end of the current budget year on September 30th. They counted this a political victory that would help their candidates in the polls.

Unfortunately, many in Congress who should know better have also bought into the notion that selling off rights for new offshore drilling, despite numerous existing leases the oil companies have yet to develop, is going to help the nation's immediate energy situation.

Worse, many in the environmental community have gone AWOL in this most recent challenge to the moratorium. True, the Sierra Club, NRDC, Defenders of Wildlife and Environment Now have spoken out against this oil-industry backed campaign, but most of the rest (including a lot of the MPA yapping dogs) went missing or were suddenly mute.

As a result, traditional offshore drilling opponents in Congress saw no constituency this time around supporting the moratorium to justify running the political risk, and so on September 30th, 2008, the 27-year old moratorium expired by default. And with it went a lot of protections for coastal fish and fishermen we had long taken for granted.

What this means is that the federal MMS will soon begin drawing up oil leasing plans for nearly all the nation's coastal waters. Waters of marine sanctuaries may be safe for now, but there are some in Congress, including Senator Jim DeMint (R-SC) that want to open up everything, including all marine sanctuaries.

It will be a while before the final lease sales take place and probably a decade before any oil from these areas comes to market, if ever, but the impacts on fisheries could be immediate. Oil companies will be looking for the leases that show the most promise. To find that out, they will be contracting with seismic vessels soon to begin acoustic surveys of the seafloor -- much of this right in the middle of our richest fishing grounds. That's what we're likely to be stuck with until some sense returns to Congress or to the next national Administration.

Moreover, even under a new President and Congress the issue may no longer be whether to drill or not to drill, but what kind of regulations can be put in place to assure some modicum of environmental protection, including at least some mitigation enacted specifically to protect offshore fishing.

Newt Gingrich, leading the charge, has made all kinds of specious claims about how safe offshore drilling has been for other fishing countries, particularly Norway. Yet despite Gingrich, Norway's Environmental Minister Erik Solheim said, "Gingrich is making a mistake if he thinks oil exploration in Norway takes place without regulation. It's precisely the regulation we have that's contributed to the Norwegian offshore activity being as clean as it is."

"Gingrich [in a blog praising drilling in Norway] didn't mention that most all the drilling takes place far from the coast, mostly in the middle of the North Sea, and is strictly regulated if not prohibited in scenic areas or close to shore. It's also highly restricted in environmentally sensitive areas like the Barents Sea," wrote Kristin Nilsen in the July 4th edition of Afterposten. "Nor did he mention any of the ongoing conflicts between the oil and gas industry and the country's fishing industry. Norwegian seafood interests have been battling not only drilling but most recently, the sonic testing being carried out by oil exploration vessels, because fishermen claim the sonic disturbance underwater is scaring off fishing stocks."

What Are the Alternatives?

The intense lobbying campaign to open up the US for offshore drilling is really all about election politics and bolstering oil company profits, not protection of the public from high fuel costs. More offshore oil drilling is not even going to make a significant dent in global oil prices, nor US domestic gasoline prices, in any foreseeable future.

In a July 15th, 2008, article in The Progress Report by Faiz Shakir, Amanda Terkel, Satyam Khanna, Matt Corley, Ali Frick, Benjamin Armbruster, and Brad Johnson, the authors, quoting the Energy Information Administration (EIA), found that "access to the Pacific, Atlantic, and eastern Gulf regions would not have a significant impact on domestic crude oil and natural gas production or prices before 2030."

They went on to say, "[But] because United States demand for oil far outstrips production -- we consume 25 percent of the world's supply but have two percent of the proven reserves -- further exploitation of domestic resources will not have a long-term impact either. After 2030, the EIA found, 'any impact on average wellhead prices is expected to be insignificant.'"

"U.S. offshore oil fields could hold enough crude to supply all of the country's needs for more than 11 years," wrote San Francisco Chronicle staff writer David Baker in the July 22nd, 2008, edition. "Or they might not. No one knows for certain because, with new offshore oil drilling banned on the East and West coasts, no one has gone looking for oil there in years."

What this all means is that the amount of offshore U.S. oil is unknown. Nor could it possibly make the nation "energy independent" -- not when the U.S. consumes 25 percent of the world's oil, but has only 2 percent of its oil reserves. Only weaning the US economy off oil altogether could accomplish that.

Worse, the relatively tiny bit of U.S. oil that might be available from offshore drilling in ten years or so would not go directly to the U.S. consumer. Far from it.

Oil companies are multi-national corporations that deal in an international oil market that is far more influenced by OPEC and major foreign oil producers' decisions than anything the U.S. produces or does. The additional oil would be an insignificant addition to the whole world market, and likely not drop U.S. fuel prices by any appreciable degree even once available.

In other words, offshore oil development is a total crap shoot. The oil industry stands to take home a jackpot. For fishermen though, it's snake eyes.

The worst part of all of this -- even if there was a lot of oil out there and it could be extracted without harming fishing -- is that this is exactly the wrong fuel to be pursuing. Haven't we learned anything over the past decade about carbon emissions, greenhouse gases and what it's doing to the planet -- particularly the ocean and the fish?

With an estimated decade before any oil from the old moratorium areas comes to market, it would seem that our time would best be spent developing renewable energy sources instead. Scientists already estimate that electricity generated from solar plants in the desert of California and Nevada could supply the nation's energy needs. The biggest impediment may be updating the grid to carry that power.

For the power electricity cannot supply, such as for aviation and maritime uses, electrical energy could be used to produce hydrogen. A simpler solution may be biofuels -- and we don't mean corn based -- such as from algae. These fuels could be developed to power jet engines and diesels without expensive conversions. If we can make the strides we have in medicine with stem cell and other research, certainly our scientists should be able to develop an abundant, affordable fuel based on a renewable resource.

Even under the worst scenario, a massive conversion to non-carbon production of electricity will help to reduce demand on oil sources (and the burning of oil) to make it more affordable for those types of transportation that cannot convert to electricity.

What Do We Do?

The first thing we believe fishermen need to do is speak out against the offshore oil fantasy. This is the classic case of the "Emperor has no clothes," and that's just where the nation is headed with this offshore drilling nonsense.

This "drill, baby drill" policy is going to leave our fisheries and our oceans bare and unprotected. It's already leaving the nation bare as far as a sustainable energy policy or energy independence is concerned, because people are being told lies that this will solve our energy problems when it clearly won't. We need to speak out on these issues, even if that doesn't make us popular in certain quarters.

Right now we've got an energy policy that seems to be driven by mob rule. Like all mob actions, they solve nothing and are later regretted. It's up to us to stand up to this mob and their spokesmen and women. We need to demand a thoughtful and reasoned energy policy, not one driven by mobs and the oil industry minions inciting them.

The message is simple: Offshore drilling threatens our fish stocks and the health of our oceans. There are sustainable alternatives available that won't harm either our fisheries or our planet.

Finally, where the leasing is already proceeding, such as in the North Aleutian Basin, it's important to demand the maximum amount of protection for fish and fishing. The conditions spelled out in the UFA letter to MMS (see below) are an example of the type of protections fishermen should be demanding everywhere these conflicts exist.

As long as the US delays developing renewable energy sources and a coherent energy policy to wean ourselves from a diminishing resource, the more difficult it's going to be for our fisheries and our nation. It's time to speak out and try to bring some sense back to this debate. If we don't, this mob will leave us hanging, chanting "Burn, baby burn."


UFA Comment on EIS for Lease Sale 214 in the North Aleutian Basin

United Fishermen of Alaska (UFA) provides the following recommendations for the Proposed Oil and Gas Lease Sale Area 214 in the Program Area of the North Aleutian Basin (NAB) Planning Area Identified and Included in the Final Outer Continental Shelf (OCS) Oil and Gas Leasing Program 2007-2012.

United Fishermen of Alaska is an umbrella association which represents 37 diverse Alaska commercial fishing organizations operating in almost all nearshore and offshore areas off the coast of Alaska. UFA represents fishermen that harvest nearly half of the total sustainable, wild capture seafood harvest of the entire United States. UFA asserts that sustainable, wild capture seafood production is an integral part of our national food production, and as such it is essential to overall national security.

The North Aleutian Basin Planning Area includes the Southeast Bering Sea and Bristol Bay regions of Alaska with the NAB proposed lease sale area encompassing nearly 5.6 million acres. Area 214 is located in the southeast portion of the NAB. Fisheries resources of the region that includes Area 214 in the SE portion of the NAB sustain the regional communities and support the most productive and sustainable commercial fisheries in the world. As the most important economic driver of the region, the commercial fishing industry has impacts extending throughout Alaska and the Pacific Northwest. As shown by National Marine Fisheries Service statistics, over 40% of the commercial U.S. fisheries catch including the nation's richest crab, pollock, cod, halibut, and salmon fisheries come from the Bering Sea region with annual harvests worth more than a half a billion dollars.

Both groundfish and shellfish fisheries completely overlap the proposed lease sale area 214. Shellfish harvested in significant numbers include Bristol Bay red king crab, Bering Sea tanner crab, and Bering Sea snow crab. Commercially harvested groundfish species include Pacific cod, Alaska pollock, Pacific halibut, flatfish species, rockfish species, Atka mackerel and sablefish. The Bristol Bay and north Alaska Peninsula salmon fisheries depend on the large numbers of all five species of Pacific salmon that utilize the area for feeding and migration. Subsistence fisheries, while not economically comparable to the region's commercial fisheries, are vital to local communities. In order to appropriately evaluate the impact of oil and gas development in the NAB, a more complete assessment of fish stocks and fisheries that utilize the stocks is needed. At a minimum, the assessment should include impacts to population abundance and productivity, seasonal distribution, movement and migration patterns, and short and long term economic impacts.

Environmental and fisheries protections are a major concern for the members of UFA in the context of nearshore (state waters) and Outer Continental Shelf (OCS) oil, gas and minerals development. Given the risks and challenges facing OCS development off the coast of Alaska, there is an urgent need to engage in a dialogue with the oil and gas industry to address UFA concerns.

For purposes of the current North Aleutian Basin Offshore Oil and Gas scoping process, UFA recommends these initial fisheries protections and mitigation measures:

Thank you for your consideration of these comments,

Sincerely,

Joe Childers, President
Mark Vinsel, Executive Director


Zeke Grader is the Executive Director of the Pacific Coast Federation of Fishermen?s Associations (PCFFA), the west coast's largest trade association of commercial fishing families. Glen Spain is PCFFA's Northwest Regional Director. PCFFA can be reached at its Southwest Office at PO Box 29370, San Francisco, CA 94129-0370, (415)561-5080, and at its Northwest Office at PO Box 11170, Eugene, OR 97440-3370, (541)689-2000 or by email to: fish1ifr@aol.com. PCFFA's Internet Home Page is at: www.pcffa.org.

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