Something’s Fishy: A Deep Dive into Seafood Mislabeling, with Kailin Kroetz

Notable Quotes

• Seafood mislabeling defined: “[Seafood mislabeling] is a pretty broad term, in some sense. It’s a term we chose to use because it encompasses both deliberate (fraudulent) mislabeling and accidental mislabeling. The other thing I want to highlight is what we mean when we say ‘mislabeling’ in terms of what consumers experience. Instead of getting the product that you expect (the product on the label), we’re really interested in understanding these cases where the consumer actually receives something different, which we call a ‘substitute product.’” (4:47)
• Likelihood of eating mislabeled seafood: “You as an individual, or us as a country—we might consume something very infrequently, but it might have a really high mislabeling rate … and on the other hand, another way that we can encounter mislabeled products is that there’s a lot of products that we eat a lot. We might encounter a mislabeled product, even if the rate is low, because we just eat so much of it. This is one thing we really wanted to pick up on in this paper. If you eat a large quantity (or if we as a country consume a large quantity), even if that mislabeling rate is low, the quantity of mislabeled product could be high.” (15:00)
• Responsible fisheries management: “What we see is that, when we compare the expected versus the substitute products, expected products tend to be produced in the United States, and substitute products tend to be produced abroad. Now, this is really important when we think about things from more of a species-population perspective and a management perspective, because here in the United States, we have some of the best-managed fisheries that are generally well-regulated. Well-regulated from an environmental aspect, but also in terms of social aspects. There’s a big concern now in the fisheries space related to slave labor and other social outcomes, as well.” (21:46)

Top of the Stack

• “Consequences of seafood mislabeling for marine populations and fisheries management” by Kailin Kroetz, Gloria M. Luque, Jessica A. Gephart, Sunny L. Jardine, Patrick Lee, Katrina Chicojay Moore, Cassandra Cole, Andrew Steinkruger, and C. Josh Donlan
• “To create sustainable seafood industries, the United States needs a better accounting of imports and exports” by Jessica Gephart, Halley E. Froehlich, and Trevor A. Branch
• “The characterization of seafood mislabeling: A global meta-analysis” by Gloria M. Luque and C. Josh Donlan
• Seafood Watch from Monterey Bay Aquarium
• Inside of a Dog: What Dogs See, Smell, and Know by Alexandra Horowitz
• The Ministry for the Future by Kim Stanley Robinson

The Full Transcript

Kristin Hayes: Hello, and welcome to Resources Radio, a weekly podcast from Resources for the Future (RFF). I'm your host, Kristin Hayes. My guest today is Dr. Kailin Kroetz, who's an assistant professor at the School of Sustainability in the College of Global Futures at Arizona State University (ASU). Kailin's research focuses on policy questions related to aquatic and terrestrial species management. Before heading to ASU, Kailin was a fellow here at RFF, and she remains an RFF university fellow today.

Kailin and I are going to be talking about seafood mislabeling. Seafood is the most globally traded food commodity, as I learned from reading Kailin's work, with supply chains that can be particularly hard to trace. Concerns over the mislabeling of seafood products, either by source or by type, have grown in recent years.

Kailin and a number of coauthors published a paper in the Proceedings of the National Academy of Sciences in late 2020, that provided a deep and empirical look at the scale of the problem here in the United States, showing systematic evidence of environmental impact from these mislabeling occurrences. We'll talk about the paper findings, including the research team's ideas for mitigating some of the challenges that they identified. Stay with us.

Hi, Kailin, welcome to Resources Radio. It's very nice to hear your voice.

Kailin Kroetz: Yes. It's wonderful to chat with you today, Kristin.

Kristin Hayes: Okay. So before we take our deep dive (and yes, that is an ocean pun) into the world of seafood mislabeling, let's talk a bit about your research interests more generally. I think they're certainly familiar to those of us and our listeners who followed your work here at RFF, but I'd love to hear what you're working on now. Maybe you could say a little bit about how you started working on species management generally, and then on fisheries in particular.

Kailin Kroetz: Thanks, Kristin. I think really my entry into the world of environment and resource economics—this is taking me way back—came from a freshman seminar in the Environmental Studies Department at Dartmouth, when I was there. It was actually a required seminar. And I think we ranked choices; I may not have gotten my first choice, but in the end, I think this ended up being a great experience and a good home for me. While I was an undergrad, I also did some research assistant work for a Dartmouth faculty member, Karen Fisher-Vanden, on water quality–trading markets. I think that experience really helped solidify a lot of my interests related to resource and environmental policy.

And then, I guess, related to: How did I get into fisheries and what am I working on now? Most of my work has a really applied focus related to policy and management. I think that's been a theme throughout my career and is something that, to a certain extent, is still evolving. For example, a lot of my current work considers economic efficiency, which I'm sure folks at RFF are really familiar with—but a lot of what I'm doing is thinking about other factors, too.

So, today, we'll talk about environmental outcomes, and I have other work that is thinking about social and community outcomes. Big picture, what's guiding my work right now is the idea that, for us to generate positive change in the environment and resource space, we really need to be thinking about and collaborating in an interdisciplinary way. A lot of my current work relates to challenges arising from climate change. And when I think about climate change (I'm sure, Kristin, you know this well), no one person or discipline is going to be able to, on their own, figure out the path forward.

This is just a good example of where we really need interdisciplinary work and thinking. And really similarly, this mislabeling work and a lot of other fishery challenges are other cases where I think there's a lot of work that we need to do to improve sustainability, and I'm excited to be involved in it.

Kristin Hayes: Yeah. Fascinating. Well, seafood mislabeling is, I'll be totally candid, not a term that I was particularly familiar with, although you and I set the wheels in motion for a potential podcast recording a while ago. So it's something that I was introduced to through your work. It would be great to just start with the basics of the problem: When we're talking about seafood mislabeling, what does that mean? And what forms does it take?

Kailin Kroetz: It's a pretty broad term, in some sense. It’s a term that we chose to use because it encompasses both deliberate (fraudulent) mislabeling or accidental mislabeling. The other thing I want to highlight for listeners is what we mean when we say “mislabeling” in terms of what consumers experience. Instead of getting the product that you expect (the product on the label), we're really interested in understanding these cases where the consumer actually receives something different, which we call a “substitute product.” Throughout the paper and our conversation today, I'm going to be using those terms a lot: the “expected product” (what's on the label—that's what you expect to get) and the “substitute product” (what you actually get).

Kristin Hayes: Fascinating. Okay. And what types of mislabeling are there?

Kailin Kroetz: This is a really good question. I think you could talk to different people, and they can give you a lot of different examples, but within my own work (and I would say probably broadly for the team that I've been with), there are few types that really emerge. One, which is the focus of the paper that we'll talk more about coming up, is species. This is when you expect one species, but you actually get another.

Other examples are: You might expect a product that was caught in the United States—so, there might be something on the label related to the origin of the fish product, and instead, it could be from somewhere else. A third example is when maybe the label indicates something about the production method. Maybe there's information about a product being wild caught, but it's actually farmed and produced via aquaculture.

So I think it’s this idea of: Are you getting exactly what is on the label, or not? And if not, then it's mislabeling—but there are a lot of different attributes that are on those labels. And if folks don't believe this, I encourage you, next time you're at the grocery store, to have a look at all the different labels that are out there.

Kristin Hayes: Right. I'm sure we'll get into this a little bit more, but I am curious about why this happens. Why does mislabeling happen? You mentioned that sometimes it's fraudulent, and sometimes it's accidental. Can you say a little bit more about how some of these mislabeling occurrences come to be?

Kailin Kroetz: Yeah. Let me touch a little bit on the fraudulent piece, and then I think I'll talk a little bit more about seafood supply chains, as well, as we dig deeper into the paper. But big picture, I think most people can imagine every retailer—or somewhere on the supply chain, somebody has some economic motivation. I think that one would probably resonate a lot with the listeners. You can imagine somebody deciding to substitute in a lower-value product for that higher-value product. Certainly there's a motivation in that sense.

One of the other motivations I'm really interested in, and I think is a big motivator for the paper we'll talk about, is that mislabeling can be an entry point, or a way to reach markets, when a product is illegally caught. There's a term, “IUU” [illegal, unreported, and unregulated fishing], which we often use in the fisheries space to talk about catch that's not reported—that's not regulated. Oftentimes, there are regulations and policies in place to try to keep these products out of certain markets like the United States and the European Union, but mislabeling is one way that you may be able to get some of those products into these markets. And then, Kristin, I guess this leads nicely into the big picture—what we are trying to do and some of the motivation for this paper more broadly.

Going into this paper, we realized that a lot of the work in the mislabeling space had actually been done by scientists who are experts in the technology to test fish products. Nobody had looked really systematically about the potential impacts of mislabeling. Myself and one of the primary collaborators on the paper, Josh Donlan (he's trained as an ecologist)—we came up with this idea to use the best available data and information to try to determine whether, on aggregate, there's evidence that mislabeling is having a negative environmental impact.

Going back to that idea of, well, what are the motivations for mislabeling? We can conjecture that they might make sense, but we were really interested in exploring from an empirical standpoint: Do we see evidence that these motivations could be leading to, in the case of this paper, environmental impacts?

Kristin Hayes: Did you go in with an intuition of whether or not that would be the case, or were you really just trying to look at the question fairly agnostically of: We know this is happening, but we're not actually sure whether it's a big deal or not.

Kailin Kroetz: That's a really good question. You know what? The evidence prior to us starting this work was pretty anecdotal; it was species by species. One paper that came out maybe about a year before ours tried to do something a little bit more systematic, but there really wasn't that much out there.

Based on the anecdotal evidence, we thought this could be something that is generating substantial impacts. Then, you think about the motivations, and I think there are incentives for this to be occurring, but we weren't sure. We felt, at a minimum, we wanted to hopefully start changing the dialogue a little bit within this space to highlight the potential issue that exists here and to start thinking more about solutions. So we thought, regardless of what we thought was going on or not, there still wasn't an analysis that was systematic enough (that we had seen, at least) to draw attention to this issue, which we're hoping to do with this paper.

Kristin Hayes: Let's go back to the supply chains for a second, because you mentioned that earlier, and I know that, in the paper itself, you note that supply chains for seafood products are often—I think the words you use specifically are “complex” and “opaque.” Those are challenging things to have in one supply chain. I'm guessing that's one of the contributing factors that actually allows the seafood mislabeling to happen. Can you say just a little bit more about what makes those supply chains complex—particularly nontransparent and, I guess a personal curiosity question, but, are most of us who eat seafood—are we likely to have purchased or eaten something mislabeled at some point?

Kailin Kroetz: First, there's a very, very robust global market for seafood. This paper is focused on the United States because we have really high-quality data—and I'll talk a little bit about that as we dive deeper into the paper. But let's take the United States, for example.

My coauthor on this paper that we're talking about today, Jessica Gephart, led an effort to estimate what the percentage is that we import. There's uncertainty, and you can go check out her paper, if you want to know more about it. But we know that the percent that we import is very high, at around 65 percent. So, big picture, if we look at this from a US perspective, a lot of our seafood that we eat is imported.

The other thing that I think leads to these complicated supply chains is that there are a lot of points along the supply chain, from harvest to consumption. We have an entire harvest sector made up of fishers—often many people on fishing vessels. The product then needs to get processed; quite often, it gets exported and imported. There can be multiple middlemen along the supply chain. And then we can think about just the diversity of retailers that exist, and ultimately this product is going to show up in a grocery store or a restaurant. Throughout that supply chain, there are a lot of different individuals and organizations that have control over that product. And so, there are a lot of different points where that product could potentially be mislabeled—even accidentally. Certainly not all of this mislabeling is fraudulent. It's very easy in the harvesting and processing sectors, in particular, to just mix products up.

Kristin Hayes: Yeah, that's a good point. I'm sitting here thinking to myself about the difference between seafood and, say, beef or chicken—some other protein that we consume here in the United States. You're not going to confuse chicken for beef, but I can imagine that there are enough similarities between the look, just the texture—there are ways that these errors could in fact creep into the supply chains much more easily. Is that probably true?

Kailin Kroetz: Absolutely, Kristin, and let me chime in here with the technical term we would use when you're just thinking about different product forms, and different product forms are at different risk of mislabeling. You can think about—if you're looking at whole fish, you really have a high probability of differentiating between different species. But once you're looking at something like a fillet, or when we're thinking about ground-up fish, or if we're thinking about things that have been breaded—that's a lot harder, right?

I know you asked me a second question, so let me get back to that one: Have we eaten mislabeled seafood? I want to talk a little bit about US consumption and tying that in with individual consumption. One of the big points of our paper is that, historically when research was done, it was on this species-by-species basis. One thing that emerged for us is that you as an individual, or us as a country—we might consume something very infrequently, but it might have a really high mislabeling rate. For example, red snapper is something which has a very high mislabeling rate; often, it's farmed tilapia or other snappers. That's one way we could think about mislabeling: that rate is so high.

But on the other hand, another way that we can encounter mislabeled products is that there's a lot of products that we eat a lot—so, we might encounter a mislabeled product even if the rate is low, because we just eat so much of it. This other nuance—this is one thing we really wanted to pick up on within this paper. If you eat a large quantity (or if we as a country consume a large quantity), even if that mislabeling rate is low, the quantity of mislabeled product could be high. We think that's really important, and so an example of this case is white lake shrimp—these are often actually things like giant tiger prawn.

Can I offer just one more example?

Kristin Hayes: I love the examples!

Kailin Kroetz: I took a look at our data, and I came up with one for the DC listeners.

Close to home in DC, folks might be familiar with local blue crab. And if you talk to fishers, and if you talk to folks in the region, there's a recognition within the fisheries sector that, often, this local blue crab is not actually local blue crab—what you're seeing is swimming crab. Swimming crab from Indonesia is a pretty common substitute and something that we saw within our data as well.

Kristin Hayes: Fascinating. Kailin, I am very cognizant that I could ask you many, many questions, but let's dig into the research a little bit more and get to the meat of things before I go on and on about tiger prawns here.

So, you've said a little bit about what you and your coauthors were investigating and what you were trying to fill in the research gap that you had identified here. Can I start by asking a question about data and what data you actually used in these questions? I have to say I find that fascinating. How did you know what was being mislabeled, and how did you find the data that you needed to really look at it systematically?

Kailin Kroetz: Yeah. First, let me very precisely state what we started with as a research question. And this is a little bit on the technical side, but I think it's important.

Kristin Hayes: Our listeners love technical.

Kailin Kroetz: We framed this around: Do enabling conditions exist in the United States for mislabeling to result in negative impacts on marine populations and/or support consumption from poorly managed fisheries? We're using the terminology “enabling conditions” because we didn't actually go out and test the whole universe of seafood in the United States. That would be prohibitively expensive.

Kristin Hayes: That sounds like a large task. Okay.

Kailin Kroetz: We took more of an economist’s approach, which is: We're going to use the best available data, and we're going to try to make sense out of it. So, what we did—and I have to acknowledge a lot of research assistants and interns who are coauthors on this paper. A lot of folks did a lot of work, not only acquiring data from different sources, but then trying to link it all together. We used data from NOAA [National Oceanic and Atmospheric Administration] Fisheries on the trade side—FAO [Food and Agriculture Organization of the United Nations] production data. We used more technical information, like conversion rates from raw to processed fish products.

And we used two other sources that I think are most visible, and that probably listeners will be most interested in. The first thing that we used is Seafood Watch fisheries ratings. These are ratings that Seafood Watch assigns to different fisheries throughout the world. And we used the best available mislabeling data.

Let me clarify a little bit. Like I said, we couldn't go out and test all of the products in the United States. So my coauthor, Josh Donlan, compiled and published in Biological Conservation the most comprehensive data set of results of testing of seafood products that exists to date. Basically what he did was he put together from this variety of different journal articles and white-paper sources—a list of the expected species. So, what's on the label, the substitute species, and what is actually being consumed. We used that—it's the best available data on mislabeling, though of course it's not comprehensive. We could have a whole other podcast episode about how I would optimally design a sampling program to learn more.

Just to tie this back around, that's why we framed the question like we did. We're trying to understand whether enabling conditions exist. We can't say precisely that a piece of seafood is mislabeled, but as we created this data set, we can say as a whole, we find that enabling conditions do exist, for seafood mislabeling to be generating these impacts. Of course, others can dive in more, if anybody wants to take on this large-scale sampling project.

Kristin Hayes: Just to put a finer point on it, when you talk about the data set that Josh Donlan put together—this is that scientific testing process that you were talking about, right? Where someone's actually sampling on some, I guess, genetic basis what this product is versus what that product is—right?

Kailin Kroetz: Yeah. Let me just add, as well—like I mentioned earlier, there are groups that are doing this to test their technology, and that often was going to show up in the academic literature. But there are other groups like Oceana, who are doing this or have worked on this to raise awareness. The other place that you'll see this is often the popular press: if you live in a large city (you may be able to Google around), it seems like a popular thing for newspapers to publish an article related to, say, local sushi restaurants and what the products actually are.

Kristin Hayes: Interesting. Okay. I'd like to open this up to talk about findings—and I think there's a richness to these findings that you are far better equipped to discuss. So, what did you find?

Kailin Kroetz: Let me put my findings in three different buckets here. The first bucket—and this is probably the most important from a policy perspective—is the substitute products that tend to be imported. What we see is that, when we compare the expected versus the substitute products, expected products tend to be produced in the United States, and substitute products tend to be produced abroad. Now, this is really important when we think about things from more of a species-population perspective and a management perspective, because here in the United States, we have some of the best-managed fisheries that are generally well-regulated. Well-regulated from an environmental aspect, but also in terms of social aspects. There's a big concern now in the fisheries space related to slave labor and other social outcomes, as well.

Kristin Hayes: When we're talking about impacts overall—if you're moving production, or products are coming from a less-regulated or less-well-managed place, then that would increase the impact level that we're talking about, right?

Kailin Kroetz: For sure. It's probably a little bit more nuanced than that, because we have to think about consumer behavior and the counterfactual—if the products couldn't come into our market, where would they go?

But for us—and this is back to this use of the term “enabling conditions,”—we think that, at a minimum, this is something we should be thinking more about and be concerned about. So, that's the first bucket of the results.

Let me move on to the second one. The other thing that we found is that farmed products (produced via aquaculture) are important to consider. One of the things that we saw here is that there's actually a lot less data. There's been very little testing to differentiate farmed versus not. Our thought—and really, I guess, our ability—vis-à-vis the data that we were able to find and collect—allowed us to say that around 40 percent of our estimated mislabeled consumption could involve an aquaculture product. I would characterize this as really an area that could use more exploration. Because from a big-picture perspective, aquaculture products have a very different environmental impacts than wild caught—almost an apples-to-oranges comparison.

Now let me talk about the third bucket of results here. The last analysis that we did is we took these expected and substitute pairs that are both for wild-caught fisheries. Then what we did is we compared Seafood Watch scores between the expected and substitute, to see whether or not the scores were higher or lower in the expected versus substitute fisheries.

These Seafood Watch scores are divided into four different criteria. And essentially, what this allows us to do is talk about whether or not the expected or the substitute fishery performs better according to these metrics. Our four that we used were the impacts on the target species (what you're catching), the impacts on the other species (e.g., bycatch as you're fishing, and do you disturb other species or populations), and then two fisheries management related metrics: management effectiveness of that target species and habitat and ecosystem effects—so, a broader measure there. What we found is very convincing evidence that, on average, the expected species score better in terms of each of these four different criteria.

Kristin Hayes: So, if you get what you think you're getting, that expected product scores better in terms of these impacts on target species, other species, habitats, and management effectiveness—is that right?

Kailin Kroetz: Big picture, Kristin, what we found is that, on average, compared to the product on the label, these substitute products—they're from fisheries with less healthy stocks that generate greater impacts on other species.

Similarly, these substitute products are from fisheries with less effective management and with policies that are less likely to mitigate impacts of fishing on habitats and ecosystems.

Kristin Hayes: Okay. This is great. And thank you for talking us through these findings. It's clear that you were able to look at a number of different questions as you delved into these data. But one thing that I've learned from working at RFF for many years is that research almost always begets more research—more questions. I'd love to know how you're thinking about what you'd want to look at next, which would continue to shed light on this topic.

Also, you mentioned early on (and I'm sure our listeners would love to know, too) about how you and your coauthors were perhaps thinking about solutions for some of the challenges that you identified. Given the range of factors at play, the range of ways that seafood mislabeling can happen, I'm sure those solutions are not straightforward—but if there is a solution set that you thought about, I'd love to hear about that, too.

Kailin Kroetz: One of the things that we're trying to do is understand the landscape of different bottom-up and top-down approaches to mitigate mislabeling. This can be things like certification programs—many people may have seen or heard of the MSC [Marine Stewardship Council] certification program. If not, you can find that in a grocery store, as well.

I mentioned Seafood Watch ratings. This is the rating system that we used in our analysis, and you could go online and download a scorecard for different fisheries. Those might be examples that I would call bottom-up approaches that are targeted more toward consumers and retailers.

But then, on the other hand, there are top-down approaches that we could take, as well, to mitigate mislabeling impacts. One of the things I'm excited about as a potential solution—and I'll combine this with what I'm working on now—is a more unilateral traceability program. These are programs or policies that are regulating trade, essentially. The United States recently implemented the Seafood Import Monitoring Program. This is an example of a large unilateral traceability program, and we're now requiring additional documentation to better trace fish-product imports. It also supports inspection of some of the products that we import.

Kristin Hayes: The testing, perhaps, that we've talked about?

Kailin Kroetz: Spot on. I think the path forward here isn't to pick one, but it's some combination of these different mechanisms. That's something that we talk a little bit about at the end of the paper and we're working on following up on.

Kristin, the other thing that I want to touch on in terms of paths forward here is technology and technological innovation. Coming out shortly in the Review of Environmental Economics and Policy, myself along with Linda and Martin Quaas write a review article with a forward-looking perspective on, What is the future of wild caught fisheries? One of the big things that we highlight is the potential for technology to transform supply chains. When I think about mislabeling, this is one of the places that I'm really excited about technology and what's been happening recently. I think there's tremendous potential for technology to enable better monitoring; decrease illegal fishing activity; and improve traceability, which could reduce mislabeling.

Kristin Hayes: What sort of technologies are we talking about here?

Kailin Kroetz: This can include on-vessel cameras to actually monitor activities on boats. There's a big global fishing-watch program that is monitoring where especially large fishing vessels are located. On the traceability side, I think there's a lot of work being done here related to how we can best electronically tag and monitor these products through the supply chain.

Kristin Hayes: Interesting. I find this all so fascinating. I feel like the potential for technology to ameliorate many impacts is always something very promising, always something to watch. I've also read that's a very American thing to say, believing in the promise of technology, but we're both Americans, so we are allowed to.

Kailin Kroetz: Yes. Blockchains will solve everything. [Laughs]

Kristin Hayes: That's right. Well, Kailin, this has been so interesting. I really do feel like we could do a whole other podcast episode on this, because I don't know—I'm just dripping with questions for you. But thank you for this introduction.

With our limited time remaining, let me move to Top of the Stack, our regular closing feature. I'd love to ask you for your recommendations on good content—fish related or otherwise. So, Kailin, what's on the top of your stack?

Kailin Kroetz: Can I give you two, Kristin?

Kristin Hayes: Sure.

Kailin Kroetz: My more fun one is—like many people, I adopted a rescue dog during the pandemic.

Kristin Hayes: Oh, you got a pandemic pet. That's great. Okay.

Kailin Kroetz: Yes. I have a pandemic pet, Chase. My sister-in-law Lisa gave me a book, Inside of a Dog, to answer that question, which I think many of us have: What is he thinking right now? And how can I make his life better?

Kristin Hayes: That's so lovely. You must be the best pet owner then—the kind who really wants to understand and care. That's great.

Kailin Kroetz: My more serious recommendation is actually one that I feel like I'm behind the curve on, and maybe others are, as well. I've, I guess not been talking to as many people lately, but twice within the last couple months, people have discussed this book as if everybody should know it. And so, my second thing that I'm reading right now is The Ministry for the Future.

Kristin Hayes: Okay. Well, Kailin, those are great recommendations. I have a pet who I've had long before the pandemic, but I'm sure I could learn something about his inner life. And The Ministry for the Future also sounds fantastic. Thank you again for coming on and talking with me today, and I hope to talk to you again soon.

Kailin Kroetz: Thank you, Kristin. This was really fun.

Kristin Hayes: You've been listening to Resources Radio. Learn how to support Resources for the Future at rff.org/support. If you have a minute, we'd really appreciate you leaving us a rating or a comment on your podcast platform of choice. Also, feel free to send us your suggestions for future episodes.

Resources Radio is a podcast from Resources for the Future (RFF). RFF is an independent, nonprofit research institution in Washington, DC. Our mission is to improve environmental, energy, and natural resource decisions through impartial economic research and policy engagement. The views expressed on this podcast are solely those of the podcast guests and may differ from those of RFF experts, its officers, or its directors. RFF does not take positions on specific legislative proposals.

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