APO Letters

APO Letters and Communications

Letters written by the APO, and their responses, regarding various Observer Programs

APO has provided official statements and letters to state, federal and international agencies on a variety of issues concerning agency policies that impact monitoring programs and observers. We have also on occasion written official letters on behalf of the welfare of individual observers when it appears that outside intervention is necessary.


North Pacific Groundfish Observer Program (starting from most recent)

Alaska Marine Mammal Observer Program

West Coast & Hawaii

West Coast Groundfish Observer Program

At-Sea Hake Observer Program

Southwest Region Observer Program

Hawaii Longline Observer Program


Southeastern Shrimp Trawl Observer Program

Southeastern Shark Gillnet Observer Program

Southeast Fisheries Science Center Pelagic Observer Program


Northeast Groundfish & Shellfish Observer Programs

National (United States)

National Observer Program

  • APO Statement to the House Natural Resources Committee on the next Reauthorization of the Magnuson-Stevens Act, 13 March 2013.
  • Letter to Bill Hogarth – March 10, 2004
    • Regarding 11/13/03 Memo on application of the FLSA to observers – his response to the APO on 4/21/04.
  • Comments on Federal Observer Compensation Act – Sept. 2002:
    • In late July, the National Observer Program solicited comments on draft legislative language that establishes an alternative observer compensation plan for work-related injuries. The plan is intended to provide to:
      • DRAFT FOCA language and Whitepaper providing background information
      • APO consulted with Tim McHugh, a lawyer who participated in the NOP’s 2001 Insurance & Liability workshop, to assist us with comments on the draft legislation (excerpts from email below).
        There are two major areas of concern:
        • The primary issue is the potential loss of remedies now available under state worker’s compensation for non-work related disabilities incurred by observers on standby through illness or injury. I think NOAA needs to provide a comparative table of remedies available under FOCA and state comp to demonstrate why “the LHWCA model is much better suited to provide observers superior benefits and procedural rights, . . .” White Paper, at 5. 
        • The second major area of concern is that observers would have no right to sue a vessel owner under Section 905(b) of the LHWCA. My comments on this issue are contained in Footnote 16 to the White Paper.
        I have tried to explain the Jones Act and how it works in comments to the text, and have tried to provide a better definition for the scope of FOCA’s application through the definition of “fisheries observer.” 
        Kim and I look forward to working with you and your office in continuing to improve observer remedies.
      • APO FOCA comments and Whitepaper Comments
        • Providing first party compensation coverage to observers in the event of injury or death,
        • Re-assurance to vessel owners that liability for negligence will be held to a minimum,
        • One stop coverage for land and sea based duty stations,
        • Coverage that would provide protection while en route to and from all assigned duty stations,
        • Cost benefits to the Federal government through the reduction of redundant insurance coverage.
  • Letter to Vicki Cornish – January 7, 2002
    • Regarding status of Dept of Labor & Dept of Commerce determination of application of the Service Contract Act to observers in the Alaska & West Coast Observer Programs.
    • Response
  • Letter to Vicki Cornish – 10-25-01
    • Regarding progress on Management Control Review recommendations

NOAA Headquarters

  • Letter to NOAA calling for more transparency of observer information – October 21, 2012


Western and Central Pacific: Regional Observer Programmes

  • 2-6 Dec 2012: APO Position Statement for the Regular Session of the Western and Central Pacific Fisheries Commission Regular Session held in Manila, Philippines
  • 6 Nov 2013: APO signed on to a letter to the Western and Central Pacific Fishery Commission regarding a need for increased transparency and access to meetings and information