Asmi Letter To Msc

October 13, 2009 Chris Ninnes Marine Stewardship Council 3rd Floor, Mountbarrow House 6-20 Elizabeth Street London SW1W 9RB UK Dear Chris, The Alaska Seafood Marketing Institute (ASMI) Board of Directors voted to provisionally become the new Client for Alaska Salmon replacing the Alaska Department of Fish and Game (ADFG). Final action will be taken at the December 3rd, 2009 Board meeting subject to clarification by the Marine Stewardship Council (MSC) of several questions and concerns. The ASMI Board of Directors recognizes that in certain markets the Marine Stewardship Council logo adds value and complements the Alaska Seafood brand by recognizing the sustainable management practices inherent in Alaska’s fisheries. They are taking this action as a service to customers and industry members who want to continue to use the MSC logo. The ASMI board is taking the time between now and its December board meeting to reach out to its stakeholders (fishermen, processors and State of Alaska officials) to be sure there is adequate input into this decision. They realize the deadline of 31 October for expiration of the certification occurs prior to that meeting. However to adequately vet this action with stakeholders will take that long and the Board requests that if ASMI formally becomes the client in December the action will be retroactive to cover the period in between. Here are the points the ASMI Board would like the MSC to respond to: Funding This client role must be cost neutral to ASMI and must be funded by those who actually use the MSC program itself. This is because ASMI is funded by the entire Alaska Seafood industry, not all of whom will benefit directly from the salmon certification. Since MSC already has a mechanism in place to collect fees from those who use the logo is there a way that MSC can collect the fees along with MSC logo licensing fees and transmit the funds to ASMI. ASMI will closely track costs over the next several years to get an accurate cost figure. The estimate currently is about $250,000 which will cover one full time MSC program position at ASMI, contract fees with Moody Marine and administrative costs for the Alaska Department of Fish and Game who will still have a certain amount of work to do even with a new client.

311 N Franklin, Suite 200 • Juneau, Alaska 99801-1147 • (907) 465-5560/(800) 4782903; Fax: (907) 465-5572 www.AlaskaSeafood.org • [email protected]

Origin Identification The ASMI Board and the State of Alaska are very concerned that the origin of our products will become lost in the MSC program. For example, we have already seen packaging that highlights “MSC Wild Salmon”, but does not mention the product originates in Alaska, even though up until a few weeks ago Alaska was the only legitimate source. ASMI has worked for many years to differentiate Alaska Seafood products from others in the market. Remaining in the MSC program must not weaken Alaska’s own marketing efforts. What accommodation can be made in the MSC process to ensure the origin of our products is not lost? Is it possible to require that the origin be prominently called out on all MSC certified products that originate in Alaska? Do MSC rules allow the client to stipulate calling out origin as a condition for using the MSC logo? Would the MSC allow the ASMI logo to be inserted in the box in the new MSC logo to show the product comes from Alaska? Fisheries Management A number of stakeholders present at our board meeting expressed concern about potential interference in Alaska fisheries management as a result of continued participation in the MSC program. Much of this stems from difficulties surrounding the last five year recertification of the Alaska Salmon fishery which imposed a model upon Alaska that really doesn’t match with the reality of our salmon fishery. While a good number of the issues stemming from that recertification have been effectively resolved there is still lingering concern that attempts to interfere in the management of the fishery could again crop up. The ASMI board would like clarification of how the MSC sees its role and that of its certifier in relationship to the actual management of the state’s fisheries. In addition, the board would like assurances that the fishery would be addressed as one, a requirement for continued participation by ADFG, and that the model imposed on the Alaska salmon fishery at the last recertification will be revisited at the next recertification. Administrative burden The Board expressed strong concern that taking on the MSC client role would become an excessive administrative burden for ASMI and detract from its current mission. The Board understands that the MSC is in the process of making management improvements to reduce administrative burdens on clients along with costs of its programs but is not sure exactly what those are or how they will impact ASMI. Please explain efforts the MSC has undertaken or plans to undertake to reduce the administrative burden on clients. In addition, please describe any plans MSC may have to help reduce the current cost burden on clients and participants in the MSC program. Changing Agendas The Board is concerned that criteria for what constitutes a “sustainable fishery” in the eyes of the MSC will be continually changing to take into account various emerging social issues being pursued by non-governmental organizations. This would mean the bar would constantly be changing for mature fisheries with a proven track record like Alaska’s, while other fisheries that have yet to even achieve the level of sustainable management already present in Alaska fisheries will be entering into the MSC program or simply continue to compete with Alaska in the market 311 N Franklin, Suite 200 • Juneau, Alaska 99801-1147 • (907) 465-5560/(800) 4782903; Fax: (907) 465-5572 www.AlaskaSeafood.org • [email protected]

place. What assurances can the MSC provide to ASMI and the state of Alaska that any future changes contemplated in the MSC evaluation criteria will be fully vetted with clients before they are imposed? Will MSC be focusing more on bringing other world fisheries up to the same level as well managed fisheries like Alaska before imposing new requirements for certification on fisheries that have been in the program for a long time? A final concern that has arisen is that some groups, for political purposes, are extracting points from the MSC assessments to imply the certifier is somehow endowed with more knowledge about the salmon fishery in Alaska than ADFG, the manager. These are then being used to attack our fisheries managers even though they have successfully passed the MSC certification and audit. A clarification by MSC that supports our management system and the work of ADFG by explaining that the intent of the audit or certification is to verify not second-guess the fishery manager would be very helpful. ASMI would like to work in a complementary way with MSC and sees value in becoming the client. The Board looks forward to MSC clarifying the matters outlined in this letter. The ASMI Board also extends an invitation for an MSC representative to attend and participate in the discussion at our December 3rd ASMI Board meeting which will be held in Seattle at the Doubletree Guest Suites, Seattle/South Center. Sincerely,

Ray Riutta Executive Director, ASMI Cc:

ASMI Board of Directors

311 N Franklin, Suite 200 • Juneau, Alaska 99801-1147 • (907) 465-5560/(800) 4782903; Fax: (907) 465-5572 www.AlaskaSeafood.org • [email protected]