July 5, 2019
To Whom It May Concern:
On behalf of the Consortium for Ocean Leadership, which represents our nation’s leading ocean science, research, and technology organizations from academia, industry, and the larger non-profit sector (to include philanthropy and aquariums), thank you for the opportunity to offer input into the development of a new set of national statistics that would provide information on the economic activity generated by ocean- and Great Lakes-related transactions in the United States. I appreciate the Experimental Ocean Economy Satellite Account (OESA)’s goal of providing a more detailed look at our nation’s ocean and Great Lakes economy and have a few suggestions to help ensure the OESA provides information that helps decisionmakers better manage our ocean and coastal resources and aids businesses and industry in making wise investments and identifying new and growing markets.
Critical to a robust blue economy, as well as to our national, homeland, energy, food, and water securities and to our public health and safety, is a healthy ocean, which in turn is underpinned by ocean science and technology. Enhanced “ocean security,” where these aforementioned securities are upheld, guarantees the safety and survival of our nation and its people. We cannot achieve this level of ocean security without a healthy, productive ocean, so measurements of ocean health must be an integral part of any assessment of the blue economy. An overfished, acidified ocean full of trash, bursting with harmful algal blooms, and devoid of life won’t benefit anybody — or even support life on our planet, including our own.
Any meaningful evaluation of the economic data the OESA plans to collect requires due consideration of the health of the ocean upon which it relies. Without ocean health data and projections, it is impossible to interpret or predict ocean impacts on business and industry. Therefore, in addition to collecting data necessary to measure and grow the blue economy, the OESA or an associated database must also gather information necessary to better understand and ensure ocean health. Without this knowledge, government agencies will not be able to make wise management decisions, and businesses and industry will not be able to make good investment and marketing choices without significant risk. For example, a threatened fish stock may be recovering, but additional analysis on ocean health might show that ocean conditions are changing, and the species could be moving further north to remain in its ideal habitat conditions. How should that information inform decisions about commercial and recreational catch limits? Likewise, a new business that invests in ecotourism centered around coral reefs in the Florida Keys needs to know how much of a threat coral bleaching is, just as an entrepreneur involved in shellfish aquaculture needs to understand and prepare for ocean acidification. Collecting data that show how fisheries, ecotourism, and aquaculture generate economic activity gives us a piece of the picture; gathering information to understand ocean health provides the full scene. These environmental data are critical to contextualizing the economic data the OESA plans to gather, which will allow for stronger long-term analyses and more confident correlations between economic trends and oceanic conditions. Data that help us better understand ocean health and its associated impact on the blue economy include, but are not limited to, satellite imagery to help us observe and monitor phenomena such as harmful algal blooms, anything tied to ecosystem health (e.g., environmental DNA), and high-resolution altimetry data to examine regional changes in sea level.
Additionally, the Federal Register notice describes the creation of “national-level economic activities.” Is this inclusive of all sectors, including state, local, and tribal, or just those at the federal level? If analysis is not already taking into account activities across the stakeholder spectrum, both public and private, it needs to. A robust OESA would require a coordinated interagency effort and could be run under the congressionally mandated National Oceanographic Partnership Program, which allows federal agencies to come together and leverage resources for priorities whose scope extends beyond any single agency.
Thank you again for the opportunity to provide comments on the OESA and for your important efforts to better understand the blue economy. I appreciate all NOAA has done to advance our ocean security, and I would be happy to meet with agency leadership to discuss this topic in more detail.
Jonathan W. White, RADM (Ret.), USN
President and CEO
Consortium for Ocean Leadership