Net Gains Alliance Letter to the National Marine Fisheries Service on the Proposed Confidentiality Rule

Net Gains Alliance has submitted a letter to the leadership at NMFS and NOAA voicing our appreciation for the attention to the confidentiality issue and our concerns that the current approach is not as comprehensive as we believe it should be to achieve NMFS' stated goals.


Net Gains Alliance Initial Response to the National Marine Fisheries Service Proposed Confidentiality Rule

After reviewing the NMFS’ proposed confidentiality rule, Net Gains Alliance is drafting our comment letter. We’ll share this letter on our website when we submit it, but that will likely happen just before the April 25, 2024 deadline, too late to contribute to the kind of discussion that we often facilitate. While we’re finalizing our letter, here are some of the key issues from our read for your consideration as you develop your own comments.


Now Open for Public Comment: Draft National Marine Fisheries Service Data Confidentiality Rule

Net Gains Alliance brings your attention to NMFS’ recently released draft rule on confidential fisheries data and information. The rule will be open for comment for 45 days, until April 25, 2024.


Empowering National Marine Fisheries Service Data Champions: In Appreciation of the Agency’s Fishery Information Systems Program

NMFS’ Fisheries Information System (FIS) program has been a constant driver of deliberate and strategic progress. Because FIS focuses on information needs identified by NMFS staff and data partners, people and organizations outside that network may not know about the program and its positive impacts. From the Net Gains’ Alliance’s perspective, FIS is central to the data modernization improvements of the last decade. As NGA wraps up this phase of our work, we’re writing this love letter to FIS to help others learn from their example and share their stories of how FIS has improved their work. 


Data Interoperability: The Slow and Steady Path Forward

Since the Net Gains Alliance began our work in 2017, we’ve called for implementation of unique trip identifiers (UTIDs) as a way to quickly and reliably integrate commercial fishing data. Ideally, unique trip identifiers are machine-generated at the first point of data collection and automatically propagated to link all of the information generated by a trip such as trip reports, dealer reports, observer information, and Vessel Monitoring System (VMS) tracks. UTIDs are often lauded as the key to data interoperability, and they could be if we were designing our fisheries data systems with a clean slate. The reality is that we’re trying to reverse engineer interoperability into distributed data systems that have evolved over decades. Solving this puzzle requires a more stepwise approach.


NGA Comments on Advance Notice of Proposed Rulemaking for National Standards 4, 8, and 9 of the Magnuson-Stevens Fishery Conservation and Management Act

The Net Gains Alliance appreciates the opportunity to comment on the National Marine Fisheries Service’s Advance Notice of Proposed Rulemaking (ANPR) regarding potential changes to the implementing guidelines for National Standards, 4, 8, and 9 of the Magnuson-Stevens Fishery Conservation and Management Act (NS guidelines).


Current and Potential Use of VMS Data - August 2023

In August 2023, Net Gains Alliance generated a report on the uses of VMS data products which can provide valuable insights for fisheries management, conservation, business analytics, and science. Spatial information about economically and ecologically important fishing areas is critical to maintaining sustainable fisheries in a changing world, particularly since fishing is one of many activities competing for ocean space. The National Oceanic and Atmospheric Administration’s (NOAA’s) National Marine Fisheries Service (NMFS) collects, provides, and uses spatial tracking data collected from commercial fishing vessels through Vessel Monitoring Systems (VMS). However, VMS data are difficult to access and are underutilized as a result. 


NMFS Data Modernization Progress Report - July 2023

Despite the importance of data to NMFS’ mission, the agency does not publicly report on the state of its data infrastructure - the people, processes, policies, and products that enable NMFS to turn information into action. The Net Gains Alliance believes a critical part of supporting fisheries and ocean sustainability is making data infrastructure visible so it can be invested in and improved. This report assesses NMFS on 15 data modernization metrics, using information gathered through June 30, 2023. Of the 13 metrics we could evaluate, four are stalled, five are in progress, and four have been partially or fully achieved. 


Five Recommendations for Better Utilizing VMS Data to Enhance Fisheries Management - June 2023

As the oceans become busier and climate change upends our expectations of stability, information about where and when fishing happens is vitally important. Location data is critical to achieving NMFS’ fisheries conservation and management mission and for planning for a sustainable ocean future. However, there is limited spatial information on fishing areas to support science, management, and business; and data products that do exist are difficult to find and access. 

NMFS should take proactive steps to improve the availability of spatial data about fisheries. In addition, managing data as an asset—a commitment of NOAA’s Data Strategy–depends on making data findable, accessible, interoperable, and reusable.


Comments on NOAA's National Seafood Strategy

The National Seafood Strategy outlines NOAA’s direction for supporting a thriving domestic U.S. seafood economy and enhancing the resilience of the seafood sector in the face of climate change and other stressors. Improved data and information systems will be essential for achieving the goals of the National Seafood Strategy. As a non-partisan, independent initiative working to improve the collection, management, and use of data and information, the Net Gains Alliance identifies areas of information needs that can help address these goals.

In these comments, we focus on additional areas where data modernization is needed to advance the Strategy, and the interconnected portfolio of NOAA and NMFS goals.


Release of Metrics to Track NMFS Data Modernization Progress

Our team created a list of NMFS data modernization metrics to highlight actions that will support NMFS’ data health and advance its conservation and management capacity. Find out more by reading the report.


Comments on the NOAA Fisheries Equity & Environmental Justice (EEJ) Strategy

Improved data and information systems will be essential for achieving the goals of the NOAA EEJ strategy. As a non-partisan, independent initiative working to improve the collection, management, and use of data and information, the Net Gains Alliance identifies areas of information needs that can help address these goals.


Communicating the Value of a Data-Driven NMFS

This document is a resource for use by NGA, our partners, and other data modernization champions to continue the work of identifying and sharing stories that illustrate impact. We appreciate the contributions of data system experts with NOAA Fisheries, the regional fishery information networks, the regional fishery management councils, industry, NGOs, and our Net Gains Advisory Panel members who shared their perspectives. 


NMFS Data Modernization Update - May 2022


NET GAINS ALLIANCE IMPACT REPORT 2021

The sustainability and economic performance of U.S. fisheries rely on data. Innovations in data science and technology are transforming every part of the world, including the ocean, and the United States must continue to prioritize modernization of its fisheries information systems and strategies. The Net Gains Alliance (NGA) was established in 2017 to support that modernization, with a mission to improve the collection, management, and use of data and information to enhance the social, economic and environmental benefits obtained from sustainable management of fisheries and marine ecosystems.


An Open Letter To NOAA

The NGA wrote a call to action for NOAA to advance our data modernization and regulation goals for the fisheries industry in 2021. The letter includes recommendations for the following:

  • Invest in NMFS staff data capacity

  • Update data access policies and practices

  • Design collaborative data value chains

  • Support explainable AI for fish

  • Point to purpose


Advancing the Potential of Electronic Reporting in the Charter/For-hire Sector

The ongoing implementation of electronic reporting (ER) in the federally permitted charter/for-hire fishing sector is a transformative step toward improving fisheries data timeliness and quality, enhancing accountability, and supporting science and management.

The Net Gains Alliance convened two virtual roundtables to foster cross-regional discussion between industry leaders, managers, and electronic technology service providers. In this report, NGA Core Team members Katie Latanich and George Lapointe provide recommendations for building on the successes achieved so far and empowering the industry to utilize modern data tools.


Recommendations for electronic monitoring program design and requests for proposal

Over the last two decades, electronic monitoring (EM) has proven to be an effective component of fisheries monitoring programs. EM is now in use on approximately 1,500 to 2,000 vessels worldwide, but growth of the tool has been relatively slow given its potential to cost-effectively support fisheries monitoring objectives. While there are some excellent examples of well-designed EM pilots and programs, there are also examples of inefficient programs that feed a perception that EM is too costly or not easily scalable. Members of the EM service provider community believe that improved program design, better requests for proposal (RFPs), and clearer communication and understanding of the capabilities and cost drivers of EM programs can enable better, more affordable, and scalable EM programs. This report provides recommendations for designing and procuring EM services for fisheries, an overview of the main cost drivers, and a high-level summary of the current technological capabilities of EM.


IMPROVING NET GAINS: PAST, PRESENT & FUTURE

Modern fishery information systems are critical to achieving the full potential of the United States’ fisheries. Four years have passed since the Fishing Data Innovation Taskforce, a diverse coalition of fishery stakeholders, issued recommendations to elevate and address the most pressing data modernization needs. The resulting 2017 Improving Net Gains report spurred the creation of the Net Gains Alliance (NGA), an initiative to advance these recommendations through grant-making, convening, policy engagement, and constituency building. The Improving Net Gains report was also a driving force behind the NOAA National Marine Fisheries Service (NMFS)’ recent release of the Fisheries Information Management Modernization (FIMM) Technical Memorandum, which demonstrates the Agency’s commitment to data modernization. This NGA retrospective reflects the progress and challenges NGA has seen to date as we begin a process to look ahead and envision what could be next.


IMPROVING NET GAINS: DATA-DRIVEN INNOVATION FOR AMERICA’S FISHING FUTURE

Rebounding U.S. fisheries provide our nation with an exciting moment of opportunity. In the past, declining stocks put fishermen out of work, kept recreational anglers off the water, and deprived seafood businesses and consumers of American-caught product. But after years of bipartisan reforms and sacrifice by fishermen willing to think long term, many depleted stocks are rebounding and fisheries-related employment is on a steady upward march. Our challenge now is to unlock the full potential of healthier American fisheries. We need to ensure that recreational anglers can enjoy the benefits of rebuilding fisheries through increased access. Commercial fishermen should see their bottom line improve as they meet growing demand for sustainable seafood. Grocery stores and restaurateurs should have the opportunity to provide high-quality product that meets consumer demand for local and fully traceable seafood. And we need to improve our ability to respond quickly and effectively to changing ocean conditions. We can do all these things with accurate, precise, timely and readily accessible data.


Part One: Recommendations to improve data sharing agreements for U.S. fisheries in the Pacific region

This report is Part One of a two-part package designed to support the ongoing cultural, legal, and technical negotiations surrounding the digital transformation of fisheries. This report describes priority issues that arise in the context of data sharing and management as identified through the lens of the U.S. National Oceanic and Atmospheric Association’s (NOAA) National Marine Fisheries Service (NMFS) Highly Migratory Species Professional Specialty Group (HMS PSG).


Part Two: Recommendations to improve data sharing agreements for U.S. fisheries in the Pacific region

Data sharing is based on relationships. And, when well-communicated, negotiating and growing data sharing relationships can create significant opportunities to increase the value and expand the impact of data. While many of us experience data sharing relationships through formal agreements, like contracts, or specific technologies, both of those things are meant to reflect our relationships - and like relationships, they can be uneven, hard-to-approach, and need attention to adaptation over time. To date, the fishing ecosystem’s relationship to data sharing agreements comes, primarily, from compliance requirements, as opposed to a broader relationship development and opportunity space. And for public institutions, ensuring compliance is vital. But data sharing and digital transformation also offer a number of shared opportunities that extend beyond regulation.