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October 13, 2009

Chris Ninnes
Marine Stewardship Council
3rd Floor, Mountbarrow House
6-20 Elizabeth Street
London SW1W 9RB

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:


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) 478-
2903; Fax: (907) 465-5572 •
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

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

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) 478-
2903; Fax: (907) 465-5572 •
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.


Ray Riutta
Executive Director, ASMI

Cc: ASMI Board of Directors

311 N Franklin, Suite 200 • Juneau, Alaska 99801-1147 • (907) 465-5560/(800) 478-
2903; Fax: (907) 465-5572 •

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