Comment on ESA Listing of Chinook by September 6
In response to a petition submitted by the Wild Fish Conservancy on January 11, 2024, the National Marine Fisheries Service (NMFS) issued a 90-day finding in May to list Alaska Chinook salmon as a threatened or endangered species under the Endangered Species Act (ESA). This finding has triggered a status review that will ultimately result in a decision about whether or not to list Gulf of Alaska Chinook stocks accordingly. The petition submitted by the Washington state based environmental group is riddled with inaccuracies and misunderstandings about Chinook Salmon that spawn in the rivers of Southeast Alaska, Prince William Sound, Cook Inlet, Kodiak and the Alaska Peninsula.
NMFS is taking public comments on the petition until September 6 and it is critical it hears from Alaskans about this reckless and uninformed request. Comments can be submitted here via the Federal eRulemaking Portal but before you comment, please review the resources below.
Read AMCC’s Brief Analysis below:
The petition filed by the Wild Fish Conservancy on January 11, 2024, is flawed and riddled with inaccuracies to a point that it undermines the integrity of the Environmental Species Act (ESA) process which is considered one of the most important wildlife conservation laws in the United States. AMCC does not support the petition and is very concerned that a threatened or endangered ESA-listing transfers the management of the listed units and their critical habitats from the State to the federal government.
The petition is structured to use a valuable conservation law to meet its own self-serving agenda to end commercial harvest of wild caught salmon in the Gulf of Alaska (GOA) under the guise of protecting Pacific Northwest wild salmon stocks. Contrary to habitat degradation in the Pacific Northwest referenced in the petition, freshwater habitat is relatively pristine for most major GOA Chinook Salmon-producing watersheds. Alaska’s freshwater and marine habitats remain largely intact and their pristine value is clearly recognized in the suite of protections afforded them.
Species are listed as endangered or threatened under the ESA to protect them from extinction, GOA Chinook Salmon are not in danger of extinction. The ESA further defines an endangered species as one that is in danger of extinction in all or a significant part of its range, while a threatened species is one that is likely to become endangered in the near future. Again, GOA Chinook Salmon are not in danger of extinction throughout its range (see graphic of ADF&G Chinook range) and no “reasonable person” would conclude that GOA Chinook salmon are at risk of going extinct now or in the foreseeable future. AMCC recognizes the need for conservation measures when stocks are struggling to meet lower escapement goals, and the Alaska Department of Fish and Game (ADFG) has many tools and regulations in place to protect and conserve Chinook Salmon during times of low abundance.
We fully support the actions ADFG is taking to restore this fish back to its former abundance levels. The listing would dismantle the comprehensive state management systems in place, virtually saying that NMFS believes state management is insufficient to protect the stocks from going extinct. Sustainable fisheries management is an integral component of the State of Alaska constitution. Alaska assumed management of the salmon fisheries in 1960 with the creation of the Department of Fish and Game, just one year after statehood. At the time, many of the salmon runs around Alaska were severely depressed and salmon fisheries were in desperate shape. Through sophisticated in season management and a ‘fish first’ commitment, Alaska rebuilt salmon runs from abundances that were far lower than they are today. The salmon returning to Alaskan streams and rearing in Alaskan waters are the basis for one of Alaska's most important industries and underpin a traditional subsistence lifestyle in rural portions of the State where access to grocery stores and supplies is not easy.
The State of Alaska has made and continues to make substantial investments in salmon research to better understand the causes of recent declines, identify potential solutions and consider how to better incorporate climatic variability into fishery management. The investments and research are actions to ensure the long-term health of Alaska salmon stocks. No one is more committed to the health of the salmon resource than the State and people of Alaska.
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1 When an ESA petition is filed, the National Marine Fisheries Service (NMFS) has 90 days to respond. A 90-day finding doesn't indicate that the petition is warranted, the finding only indicates that the petition action may be warranted and that a full review should occur.