On January 11, 2024, Wild Fish Conservancy formally petitioned NOAA to grant federal ESA protections for Chinook from rivers that flow into the Gulf of Alaska. On May 24, 2024, NMFS responded with a positive finding, confirming the petition contained substantial information indicating ESA-listing and protection may be warranted. The initial finding triggered an in-depth review, including a formal public input process requesting relevant commercial or scientific information.

NOAA had one year, until January 11, 2025, to review the data on Gulf of Alaska Chinook salmon and determine whether ‘threatened’ or ‘endangered’ status under the ESA is warranted. The Conservancy is now signaling its intent to sue NOAA for missing this legally required deadline and further delaying protections for declining Chinook populations that may be at risk of extinction.

“Over the last year, native communities and Alaskans participating in the listing review process have expressed relief and optimism that this comprehensive analysis is finally taking place to address the decline of the local Chinook populations they work so hard to protect,” says Emma Helverson, Executive Director of Wild Fish Conservancy. “It is clear Alaskan communities want answers and are ready to begin implementing solutions through the recovery planning process. Tangible actions, additional resources, and stronger protections are what these fish and the communities who depend on them desperately need.”

Despite their historical abundance, data from the state of Alaska demonstrates persistent declines in Chinook abundance, size, age, diversity, and spatial structure. Many are surprised to learn some Alaskan Chinook populations are in even worse condition than other Pacific Northwest populations already listed under the ESA. Alaska has already recognized many of these stocks as ‘species of concern’ over the last decade, due to their continued decline in the face of the state’s attempted regulatory actions.

In many cases, the number of Chinook salmon officials forecast to return are well below the minimum number of fish needed to reproduce at a rate to simply replace themselves, let alone to recover the stock’s abundance.  Compounding the problem, actual returns frequently fall even lower than predicted by the state. Over time, steadily declining returns have resulted in consecutive years of emergency fishery closures for in-river commercial, recreational, and subsistence fisheries, including for indigenous communities. Meanwhile, Alaska’s government continues to authorize large-scale commercial ocean fisheries to harvest or kill as bycatch Chinook from these same populations; threats identified in the petition.

The Kenai River, world-renowned for its Chinook salmon, hit a historic low in 2024. The early-season count showed just 1,365 fish returning—half of what officials modeled and the fifth consecutive year of missed forecasts. The late-season numbers were equally concerning, with only 6,930 Chinook returning, a far cry from the historical average of ~28,000 over the last four decades. Also alarming, the river that once produced the world’s largest Chinook has now gone three straight years without seeing any of its oldest and largest age-7 salmon return.

On the west side of Kodiak Island in the Karluk River, goals to maintain the population require at least 3,000 Chinook to return annually. In 2024, only 76 fish came back to spawn. The Ayakulik River, the largest river system on the island, saw only 354 Chinook return to spawn, just 7% of that watershed’s population goal of 4,800.

“Government officials, seafood certifiers, and the fishing industry continue to assure the public that Alaska’s Chinook are well managed, but the data tells a different story. When fishery managers continue to stubbornly defend businesses as usual, further harm is inevitable and emergency fishery closures should be expected,” says Conrad Gowell, a biologist with Wild Fish Conservancy and co-author of the petition. “The longer NOAA waits to take appropriate action, the more severe the social, economic, and environmental consequences will be.”

Yesterday’s notice follows the agency’s admission that its review process is significantly delayed. After the Wild Fish Conservancy inquired about the review status prior to the one-year due date, NOAA Fisheries said that more time would be needed. The agency’s failure to comply with this deadline continues NOAA’s troubling pattern of disregarding the ESA and the urgent reality that species on the brink of extinction don’t have time to wait. These deadlines are written in law to ensure recovery actions can be implemented in a reasonable timeframe to prevent extinction from occurring.

NOAA has also failed to issue legally required final determinations on ESA listing petitions for Olympia Peninsula steelhead, Oregon and California coast Chinook, and Washington coast Chinook, decisions that are now overdue by one or more years. As these imperiled species continue to decline, NOAA’s repeated failures expose systemic dysfunction within the agency and emphasize the urgent need for yesterday’s action.

“The public should not have to take legal action to compel federal agencies to follow the law, but the dire crisis facing Alaska’s Chinook populations leaves us no other choice,” says Helverson. “These aren’t arbitrary timelines or bureaucratic red tape, they are essential safeguards to prevent extinction. NOAA isn’t just missing a deadline—it’s pushing Alaskan Chinook closer to extinction and starving the ecosystems and communities that rely on them.”

Specifics on the data submitted, frequently asked questions, and the full petition are available on Wild Fish Conservancy’s website. Information on the federal listing process under the Endangered Species Act is available on NOAA Fisheries’ website.

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Further Reading:

• After Chronic Decline, Feds Agree Alaskan Chinook May Require Protection under the Endangered Species Act – Wild Fish Conservancy Northwest
• Conservation group petitions for Alaska king salmon to be listed as an endangered species – The Columbian
• Washington conservation group proposes listing Alaska king salmon under Endangered Species Act – Alaska Public Media 
• Alaskan King Salmon May Receive ESA Listing – Meat Eater Conservation News

Wild Fish Conservancy is represented in this matter by Kampmeier & Knutsen, PLLC, of Portland, Oregon and Seattle, Washington. kampmeierknutsen.com

Wild Fish Conservancy is a nonprofit conservation organization headquartered in Washington State and working from California to Alaska to preserve, protect and restore the northwest’s wild fish and the ecosystems they depend on, through science, education, and advocacy. wildfishconservancy.org