NOAA-approved harvest plan threatens federally protected Chinook and killer whales

NOAA-approved harvest plan threatens federally protected Chinook and killer whales

Overharvest of Chinook salmon in S.E. Alaska threatens the coast-wide survival of wild salmon, Southern Resident killer whales, and coastal fishing communities

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Jan 09, 2020 | The Wild Fish Conservancy sent a legal notice today warning that NOAA and the US Department of Commerce are failing to protect federally-listed salmon and Southern Resident killer whales, as required by the Endangered Species Act.

At issue: overharvest of Chinook salmon in the Southeast Alaska troll fishery and the harm it causes to Southern Resident killer whales and wild Chinook. Nearly all of the Chinook harvested in the fishery were born in rivers from British Columbia to Oregon. Kurt Beardslee, executive director of Wild Fish Conservancy (WFC) explained: “It is irresponsible for NOAA to authorize this harvest in Alaska when they know it undermines efforts to restore imperiled wild Chinook populations in Washington, British Columbia, and Oregon rivers, and contributes to the starvation of endangered Southern Resident killer whales and fishing communities all along the coast.”

The Endangered Species Act requires NOAA scientists to ensure that their management of the Southeast Alaska Chinook troll fishery does not cause further decline of these federally-listed salmon and the Southern Resident killer whales (SRKW) that rely upon them. The most recent NOAA review, called a Biological Opinion, determined: “Under the existing management and recovery regimes over the last decade, salmon availability has not been sufficient to support SRKW population growth.” As a result, the analysis concluded that current management was inadequate: “more would be required to mitigate the effects of harvest and other limiting factors that contributed to the reduced status of Puget Sound Chinook salmon and SRKWs.” WFC’s letter warns that continuing to implement the fishery despite these findings—without demonstrating that the mitigation proposed would sufficiently offset the harm the fishery does to salmon and Southern Resident killer whales—violates NOAA’s legal obligations.

“Most people don’t realize that over 97% of the Chinook salmon caught in the ocean off Southeast Alaska are not from Alaska, they’re actually from rivers in British Columbia, Washington, and Oregon. These salmon are not Alaskan salmon, they belong to the rivers and peoples of the entire coast, as well as the killer whales and coastal ecosystems that depend on them,” said Beardslee.

After they leave their home rivers from California to Alaska, Chinook salmon migrate along the coast for years, feeding, growing and mingling with salmon from other regions in the rich waters off the coast of Alaska before migrating home through the feeding grounds of Southern Resident killer whales, and ultimately back home to the rivers where they breed. Data from the Pacific Salmon Commission show that only 3% of the Chinook caught in Southeast Alaskan ocean waters each year are actually from Alaskan rivers; roughly half are from the Columbia River and the remainder come from other rivers in British Columbia, Washington, and Oregon. As the Chinook migrate south along the coasts of British Columbia, Washington, and Oregon, they are the much-needed primary prey for the 73 surviving Southern Resident killer whales.

“Fishermen are not at fault,” said Beardslee. “NOAA has failed fishermen, salmon, and orcas for decades by authorizing Southeast Alaska’s overharvest of non-Alaskan Chinook. Fishery managers and NOAA could resolve this by moving Southeast Alaska’s Chinook fishery in or near the Alaskan rivers where their Chinook were born, allowing Chinook from down the coast to migrate back to their home rivers along the coast, and giving Southern Resident killer whales a chance to feed.”

WFC’s letter alleges that NOAA’s Biological Opinion wrongly relies on insufficient, unproven, and nonexistent mitigations for the harm done to Chinook and Southern Resident killer whales. The Biological Opinion offers no scientific evaluation of whether the promised measures would restore wild Chinook populations or the large Chinook that killer whales depend upon. Furthermore, no such funding currently exists for the hypothetical mitigation, and the effects of any such mitigation measures would not be realized for decades.

WFC’s notice gives NOAA and the Department of Commerce 60 days to correct the Biological Opinion, acknowledge that current fishery management does not protect endangered species, and uphold their duty to protect these endangered and threatened species.

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


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