How much seafood do people eat on a day-to-day basis, and how does that number play a role in regulating clean water? A Southeast Native environmental group is partnering with Wrangell’s tribe to try to find out how much fish coastal Alaskans actually eat day-to-day.
According to a state formula used by environmental regulators, Alaskans only eat a bite of fish per day: 6.5 grams, or about a fifth of an ounce.
“That’s a piece of fish maybe the size of a quarter, but thicker,” says Fred Olsen Jr., the executive director of the environmental advocacy group, the Southeast Alaska Indigenous Transboundary Commission. In his estimation, it’s far too little.
The number is a problem, he says, because it goes into a formula used by regulators to compute probable hazards from contaminants in fishy foods: “The fish consumption rate — the amount of fish people eat from that from the water sources, would then dictate how much pollution you’re going to allow into the system,” Olsen explains.
Humans are exposed to pollutants from obvious sources like the air and drinking water. But things like heavy metals can bioaccumulate in fish tissue — which we eat.
“It’s a real fundamental nuts and bolts issue,” Olsen says, “Where the rubber meets the road, where regulations are made, and water quality standards determined by this formula.”
Alaska uses the fish consumption rate of 6.5 grams per day per person as part of its water quality standards formula. If Alaskans do eat more than 6.5 grams per day of seafood, Olsen says, they could be exposed to higher levels of potentially harmful substances than the state accounts for. That’s especially concerning for rural, subsistence-based, and Indigenous populations in the state that rely heavily on fish as a food source.
So the Southeast Alaska Indigenous Transboundary Commission — a consortium of 15 tribes — recently received federal funding: a Bureau of Indian Affairs Tribal Climate Resilience grant of $130,000. Its project will investigate how much seafood the Indigenous population in a coastal town like Wrangell consumes day-to-day.
“We’re just trying to see how much, or show how much people eat,” Olsen says. “And we figure it’s more than six and a half grams a day.”
SEITC will work with the local Tlingit tribe, the Wrangell Cooperative Association, to survey households in the community about their consumption of seafoods like salmon, halibut, shellfish, and kelp over a period of two years. Olsen says the goal is to get a picture of the population by looking at select households and extrapolating from there.
“It’s kind of like being a Nielsen family,” he says, referencing the families with boxes attached to their televisions that track their viewing habits. It’s how the networks compute TV ratings. It’s the same idea with this seafood survey, with a random selection of families indicating the habits of the area.
“It’s basically going to be an avenue that continues to help protect the environment,” says Esther Reese, the tribal administrator of the Wrangell Cooperative Association. “And [it will] bring more focus on safe consumption of foods.”
She says the tribe is excited to be working with SEITC on the survey. Reese says the partnership expands on the WCA’s recent efforts to promote and preserve traditional foodways through projects like building smokehouses for tribal citizens and revitalizing Wrangell’s community garden.
“It dovetails nicely because it helps increase that knowledge of traditionally what we consumed,” Reese says, “And it will help going forward to make sure that the water quality continues, or hopefully will continue to be such that we can continue to consume [seafood] at the same levels that we are used to.”
Other Pacific states like Washington and Oregon use average fish consumption rates more than 25 times higher in their human health criteria calculations.
Olsen says he hopes the survey will be able to help inform Alaska officials’ decision-making.
“It’s so fundamental,” Olsen says, “It’s a little thing, like your power cord. Without the power cord, your TV doesn’t work at all. But it’s this little thing, it doesn’t really matter, does it? But oh, it does when you need to plug in your TV. And the fish consumption rate is a fundamental part of the formula. So by keeping that low, they can pollute the water more.”
Alaska’s Department of Environmental Conservation — which regulates our air and water — says it’s working to update human health criteria, including the fish consumption rate. It’s listed as one of its top priorities for the next three years.
But the DEC’s Brock Tabor says it’s difficult for Alaska to pin down what number fits the state best. Tabor is the water quality standards section manager with the agency in Juneau. Fish consumption is a lot higher in rural communities than urban ones, for example.
“Would I say 6.5 [g/d] is reflective of fish consumption of the state as a whole? No,” Tabor says, “Because we’ve done studies. And we’ve said: ‘Okay, this number isn’t reflective of it anymore.’ But now, it’s a question of, ‘Okay, what number would be reflective of the state? What part of the state are you going to be concerned with?’”
Plus, Tabor adds, the formula isn’t a direct line between the fish consumption rate and pollution permits. It also takes into account body weight, drinking water consumption, and other possible exposure sources over the course of a day, a week, or a lifetime.
Even then, Tabor says sometimes human health criteria aren’t the determining factor for pollution caps. He says the state defaults to the most strict guideline, which isn’t always human health protection.
“For a lot of these pollutants, certainly for metals, our water quality criteria [for aquatic life] are more stringent than our human health criteria,” he explains.
Tabor adds that the process of changing a standard isn’t just about finding a new number. DEC also has to consider updated numbers necessitating new or more precise testing equipment, as well as how it will affect businesses and organizations applying for wastewater permits.
And changing regulations also opens the state up to legal and technical blowback. Back and forth over human health criteria between the Trump and Biden administrations has also found the state of Washington in the midst of a legal battle over their water quality standards, including their fish consumption rate, which Tabor says is a worry for the state of Alaska as well.
The survey that SEITC is planning will be the first of its kind in Southeast Alaska. But other tribal governments around the state have looked into the fish consumption rate of their citizens.
The Sun’aq Tribe of Kodiak completed a survey in 2019 which found that respondents consumed about half a pound of seafood per day, and the Seldovia Village Tribe in Cook Inlet completed a survey that showed respondents ate 100 grams of seafood a day.
Tabor says the state is happy to take into account data from independent surveys as it works to develop new standards and a plan to implement them.
“I think we’ve got a really good foundation of data,” Tabor says. “Any new reports that came in, we would certainly want to consider — not measure them one against the other, per se, but we would certainly want to consider the results of what one report says versus another one.”
Olsen says SEITC has hired a project manager for the Wrangell survey, and they’ll hold a public forum on the project in Wrangell later this year. After that, WCA and SEITC will start hiring survey-takers and collecting data.
9/22/2021: This article has been updated to clarify that water quality criteria for aquatic life are more stringent than human health criteria when it comes to some pollutants and metals.
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