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Alaska fishing groups and concerned citizens refile emergency petition to the Alaska Board of Fisheries

May 17th, 2018

For Immediate Release: May 16, 2018

Contact Ricky Gease, (907) 262-8588, Ricky@krsa.com

Alaska fishing groups and concerned citizens refile emergency petition to the Alaska Board of Fisheries to halt hatchery increase of 20 million pink salmon egg take to existing Prince William Sound management plans

May 16, 2018 – Two days after the Alaska Board of Fisheries (BOF) failed (3-3 vote) an emergency petition from eight Alaska fishing groups urging the Board to write a letter of concern to the Commissioner of the Alaska Department of Fish and Game (ADFG) regarding implementation of an increase in the number of pink salmon eggs taken by 20 million by hatcheries in Prince William Sound (PWS). A similar emergency petition was filed with the BOF, this time requesting that the Board exercise its regulatory authority and stop the expansion.

The Alaska fishing groups, now joined by a coalition of concerned citizens regarding impacts on the Lower Cook Inlet of straying PWS hatchery pink salmon and representing interests of commercial fishing set netters and drift gillnetters, seafood processors, water taxis, and guided anglers, refiled the emergency petition on Wednesday, May 16.

Disappointed in the BOF inaction that failed to heed recent scientific publications where major red flags are being raised over the biological impacts associated with continued release of very large numbers of hatchery salmon into the North Pacific Ocean, concerned citizens in Lower Cook Inlet reached out to the original filers to find out what the next steps could be taken. “We were hopeful that maybe this time somebody would take the issue of massive straying of PWS hatchery pinks into Kachemak Bay seriously – once again we were disappointed, but not surprised by the procrastination of the BOF and ADFG on this issue,” said Nancy Hillstrand, a seafood processor in Homer. “It wasn’t hard to find a wide variety of people and businesses here to sign the new emergency petition – we see the negative impacts of straying pinks firsthand.”

The State of Alaska law mandates that hatcheries shall operate without adversely affecting natural stocks of fish, and that wild salmon stocks and fisheries on those stocks should be protected from adverse impacts from artificial propagation and enhancement efforts. In 2017, straying PWS hatchery pink salmon showed up in large numbers across the streams of Lower Cook Inlet, with some locations registering more than two-thirds PWS hatchery-origin of all pinks sampled.

In declaring a need for an emergency petition to forego expanding the capacity of hatchery pink salmon production, the new emergency petition asks that the BOF exercise its own authority to deny the increased 20 million egg take by PWS hatcheries. “The Joint Protocol on Salmon Enhancement between the BOF and ADFG was signed in 2002,” noted Ricky Gease, KRSA executive director. “In the face of mounting scientific reports documenting the negative impacts of the ever-increasing industrial hatchery salmon production in the North Pacific Ocean, inaction by the both the BOF and ADFG on this issue is inexcusable.”

The BOF has 30 days to review the new emergency petition. Two board members may decide to call a meeting to consider the request.

The full text of the emergency petition is included below.

About KRSA:

KRSA is a nonpartisan, nonprofit fishery-conservation organization of Alaskans that works to ensure the long-term health and sustainability of fish resources in the Kenai River and elsewhere in Alaska, through advocacy of sport and personal-use fisheries and the promotion of science-based fish management.

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Begin full text of the emergency petition:

Petition for finding of emergency and scheduling hearing on the adverse biological impacts that will result from recent amendments to Prince William Sound Private Non-Profit Hatchery Management Plans that add an increment of 20 million pink salmon egg take to existing permitted capacity

We, the undersigned organizations and individuals, strongly recommend the Alaska Board of Fisheries (BOF) make a finding of emergency and subsequently schedule a time certain to meet and exercise their statutory authority to limit the number of pink salmon eggs allowed to be taken and incubated by the Private Non-Profit (PNP) hatcheries in the Prince William Sound (PWS). Specifically, this petition asks the BOF to amend actions taken in Permit Alteration Requests made by the PWS Regional Planning Team to allow for an increase in the number of pink salmon eggs taken in 2018 by 20 million.

In accordance with 5 AAC 96.625 Joint Board Petition Policy, it is the policy of the boards that a petition will be denied and not schedule for hearing unless the problem outlined in the petition
justifies a finding of emergency. In accordance with state policy expressed in AS 44.62.270, emergencies will be held to a minimum and are rarely found to exist.

In this section, an emergency is an unforeseen, unexpected event that either threatens a fish or game resource, or an unforeseen, unexpected resource situation where a biologically allowable resource harvest would be precluded by delayed regulatory action and such delay would be significantly burdensome to the petitioners because the resource would be unavailable in the future.

Factors in support of finding of emergency:

  1. Hatchery permits are required for the construction and/or operation of a private non-profit salmon hatchery in Alaska. Hatchery permits specify the species and number of salmon that can be incubated at the hatchery, as well as the number released, release sites, broodstock sources, and other conditions of operation.
  2. BOF authority as it relates to hatcheries. AS Sec. 16.10.440 (b) The Board of Fisheries may, after the issuance of a permit by the commissioner, amend by regulation adopted in accordance with AS 44.62 (Administrative Procedure Act), the terms of the permit relating to the source and number of salmon eggs.
  3. The Joint Protocol on Salmon Enhancement (#2002-FB-215) entered into by the Alaska Board of Fisheries and the Alaska Department of Fish and Game (ADFG) on June 28, 2002 establishes a framework design to inform the public and coordinate department and board interaction on certain aspects of salmon hatchery policy and regulation.
  4. The State of Alaska law mandates that hatcheries shall operate without adversely affecting natural stocks of fish – 5 AAC 39.222. Policy for management of sustainable salmon fisheries. (c) (1) (D) effects and interactions of introduced or enhanced salmon stocks on wild salmon stocks should be assessed; wild salmon stocks and fisheries on those stocks should be protected from adverse impacts from artificial propagation and enhancement efforts.
  5. The total number of pink salmon eggs that were taken for rearing in PWS hatcheries in 2016 was 740 million. That same year, 643 million pink salmon fry of hatchery-origin were released into PWS.
  6. PWS fishermen have the highest hatchery fish catches. In 2017, 45 million salmon returned to the five hatcheries in PWS, accounting for 87 percent of the total salmon harvest. Ninety-three percent of pink salmon were hatchery-origin, and 68 percent of chum salmon were hatchery-origin. In all, PWS hatchery harvest added up to 62 percent of the total with a dockside value of $64 million.
  7. Pink salmon that showed up in streams across Lower Cook Inlet in 2017 weren’t all local stocks — in some streams, up to 70 percent were releases from PWS hatcheries. PWS hatchery-marked fish were present in every Lower Cook Inlet stream sampled. In Fritz Creek, 70 percent of the 96-fish sampled were from PWS hatcheries. In Beluga Slough, 56 percent of the 288-fish sampled were from PWS.
  8. In addition to the straying issues of PWS hatchery-origin pink salmon observed in Lower Cook Inlet, recent scientific publications (building on past published reports and internal ADFG reviews) have provided cause for great concern over the biological impacts associated with continued release of very large numbers of hatchery salmon into the North Pacific Ocean, including the Bering Sea and the Gulf of Alaska.
    1. “Numbers and Biomass of Natural- and Hatchery-Origin Pink Salmon, Chum Salmon, and Sockeye Salmon in the North Pacific Ocean, 1925-2015” Gregory T. Ruggerone and James R. Irvine 2018.
    2. “Population Viability Improves Following Termination of Coho Salmon Hatchery Releases” Kim K. Jones, Trevan J. Cornwell, Daniel L. Bottom, Staci Stein, and Kara J. Anlauf-Dunn 2018.
    3. “Transhemispheric Ecosystem Disservices of Pink Salmon in a Pacific Ocean Macrosystem” Alan M. Singer, Gus B van Vliet, Natalie Bool, Mike Crowley, Peter Fullagar, Mary-Anne Lea, Ross Monash, Cassandra Price, Caitlin Vertifan, and Eric J. Woehler 2018.
    4. “Pink Salmon Induce a Trophic Cascade in Plankton Populations in Southern Bering Sea and Around the Aleutian Islands” Sonia Batten, Greg Ruggerone and Ivonne Ortiz 2018.
    5. “Effects of Climate and Competition for Offshore Prey on Growth, Survival, and Reproduction Potential of Coho Salmon in Southeast Alaska” Leon D. Shaul and Harold J. Geiger 2016.
    6. “Changes in Body Size of Canadian Pacific Salmon over Six Decades” Kyla M Jeffrey, Isabelle M. Cote, James R. Irvine, and John D. Reynolds 2016.
    7. “Changes in Size and Age of Chinook Salmon Oncorhynchus tshawytscha Returning to Alaska” Bert Lewis, W. Steward Grant, Richard E. Brenner, and Toshihide Hamazaki 2015.
    8. “Alaska Department of Fish and Game Internal Review of Prince William Sound Aquaculture Corporation” Bert Lewis, Jeremy Botz, Steve Moffitt, Glenn Hollowell, Dan Gray, Jeff Regnart, Sean Palmer, Craig Farrington, and Bruce White 2009.
    9. “Feeding Ecology of Pacific Salmon (Oncorhynchus spp.) in the Central North Pacific Ocean and Central Bering Sea, 1991-2000” Nancy Davis 2003.
    10. “Evaluating Alaska’s Ocean-Ranching Salmon Hatcheries: Biologic and Management Issues” Environment and Natural Resources Institute, UAA 2001.

In response to arguments against denial of additional capacity of egg take and rearing of hatchery pink salmon:

  1. Regulatory action requested is not clear – To be unequivocal, the regulatory action requested is that the BOF exercise its authority provided in AS 16.10.440(b) and through use of the Administrative Procedure Act amend the 2018 PAR to deny allowing for the taking of an additional 20 million pink salmon eggs by PWS PNP’s.
  2. BOF should look at this issue more broadly and not act on this specific request now – The respective obligations of the BOF and ADFG to wild stock preservation and authorities under the law are unambiguous. In the face of compelling science-based evidence of ocean competition issues of wild and hatchery-origin salmon and documented straying of hatchery-origin PWS pink salmon into Lower Cook Inlet, the fact that the BOF and ADFG have until now neglected to follow through on the Joint Protocol signed in 2002 is not a justifiable pretext for the BOF to refuse to act to deny an incremental increase in PWS hatchery pink salmon production. The promise of a more comprehensive approach in the future does not excuse the respective responsibilities of the BOF and ADFG for due diligence today.
  3. The Regional Planning Team (RPT) process is a public process and it is unfortunate that the authors of this petition did not participate and make their concerns known – The RPT is about as closed, opaque and esoteric as any process deemed “public” can be. Whereas the BOF process is open, transparent and accessible to the public, both in person and online, the RPT is the opposite. In fact, the Joint Protocol on Enhancement was entered into in part precisely because both the BOF and ADFG recognized the shortcomings of the RPT process.
  4. It is unfair at this point to deny the PNP as it has made an investment in the infrastructure necessary to accommodate the additional 20 million pink salmon eggs and rearing needs – Here, where one must weigh the risk to sustainability of the State’s wild stocks of salmon against the private investment, the law is clear, wild stock integrity comes first.

Conclusion:

  1. It is certainly unforeseen, unexpected and poses a threat to fishery resources that ADFG, the state agency charged with stewardship of the state’s salmon resource, would agree to an amendment to the Annual Management Plans for Private Non-Profit Hatcheries in Prince William Sound, providing for a substantial increase in the taking of pink salmon eggs when up to 70 percent of all pink salmon sampled on spawning streams of Lower Cook Inlet in 2017 were of Prince William Sound hatchery origin.
  2. It is certainly unforeseen, unexpected and poses a threat to fishery resources that the BOF and ADFG would continue to ignore the Joint Protocol on Salmon Enhancement (#2002-FB-125) entered into on June 28, 2002 and fail to hold public meetings designed to provide an opportunity for the board and the public to receive reports from ADFG on hatchery issues, including most recent scientific research and production trends.

The relief sought by this Emergency Petition is to have the Alaska Board of Fisheries deny an increase of 20 million pink salmon eggs taken by the PNP’s in PWS, through amendment to the recent April 2018 Permit Alteration Request made by the PWS Regional Planning Team and approved by ADFG, by exercising its regulatory authority granted to them in AS Sec. 16.10.440 (b) and the Administrative Procedures Act.

Respectfully,

Concerned Citizens for Lower Cook Inlet

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