The December letter by Tribal groups asking for emergency action to protect Bering Sea salmon follows this posting — 

January 18, 2022

The Honorable Gina Raimondo

Secretary of Commerce

United States Department of Commerce

1401 Constitution Avenue, N.W.

Washington, DC 20230

RE: Emergency Action Request, Bering Sea Chinook and Chum Salmon

Dear Secretary Raimondo,

The undersigned represent the six non-profit Western Alaska Community Development Quota (CDQ) Program entities formed in 1996 pursuant to the Magnuson Stevens Fishery Conservation and Management Act, 16 U.S.C. 1855(i)(1) et seq (the “MSA”). The CDQ program is a joint federal and State of Alaska program that provides jobs, infrastructure benefits, economic development initiatives, scholarships and training to Western Alaska communities.1

1 Information about the CDQ program: www.wacda.org, https://alaskafisheries.noaa.gov/fisheries/cdq.

2 16 U.S.C. 1855(i)(1)(A).

3 For example: https://www.census.gov/quickfacts/kusilvakcensusareaalaska; https://www.census.gov/quickfacts/fact/table/aleutianseastboroughalaska/PST045221; https://www.census.gov/quickfacts/bristolbayboroughalaska;

https://www.census.gov/quickfacts/lakeandpeninsulaboroughalaska;

We wish to share the depth of our concern for the salmon failures presented in the letter dated December 21, 2021, by Western Alaska entities requesting that emergency action be taken by the Department of Commerce to address Chinook and Chum salmon bycatch. Our Western Alaska residents are feeling the devastating effects of the 2020 and 2021 collapse of the Chum salmon run in many Western Alaska rivers, and the persistent low returns of Chinook salmon in these same rivers is a concern to us all.

However, we oppose this emergency action request as it would overwhelmingly harm the CDQ Program. We also are concerned that this emergency action request does not include a public comment process and that important voices in this issue may not be heard.

The CDQ program’s express statutory purpose is to provide jobs, infrastructure benefits, economic development initiatives, scholarships, and training to the more than 30,000 residents of 65 Western Alaska communities2. The CDQ program’s communities include those in the Aleutian and Pribilof Islands, Bristol Bay, the Yukon-Kuskokwim Delta region, and Norton Sound. The CDQ Groups are organized by the MSA into six regions which are represented by six not-for-profit organizations. Residents in our member communities are predominantly Alaska Native (Aleut, Yup’ik, and Inupiaq), and every one of our communities is home to one or more federally recognized Tribes. Western Alaska experiences substantial levels of poverty3 with several

4 Draft 2019 “Economic Impacts of the Western Alaska Community Development Quota Program” prepared by the McDowell Group, Anchorage, Alaska (report to be updated and finalized early 2022).

5 Federal Regulations: “The goals and purpose of the CDQ program are to allocate CDQ to eligible Western Alaska communities to provide the means for starting or supporting commercial fisheries business activities that will result in an ongoing, regionally based, fisheries-related economy.” 50 CFR 679.1 (e). State Regulations: “The Western Alaska Community Development Quota Program was established by the federal government with the purpose of providing persons residing in western Alaska communities a fair and reasonable opportunity to participate in the Bering Sea/Aleutian Islands (BS/AI) fisheries, and to promote the economic well-being of local coastal communities in relation to Bering Sea fishery resources.” Introduction to Western Alaska Community Quota Program Regulations, Nov. 18, 1992.

6 https://www.npfmc.org/bsai-salmon-bycatch/salmon-bycatch

7 16 U.S.C. 1855(i)(1)(E)(i).

communities still lacking piped water and sewer systems. Local jobs are scarce, especially outside of government. People practice subsistence hunting and fishing to feed their families.

As an example of the CDQ Program’s impact in Western Alaska, in 2017 our program directly accounted for 20% of our region’s employment and labor income. It is also directly linked to approximately 2,100 jobs and $145 million in labor income and provided $2.5 million in educational funding to 1,660 students. In addition to job creation and infrastructure investments, our program also funds a wide range of community infrastructure and support programs, reflecting regional and community priorities including career and education fairs, small business grants, elder support programs, early childhood education and extracurricular activities for youth, and cultural celebration and enrichment.4 The program has a strong record of creating and expanding commercial opportunities and supporting subsistence fisheries in our region. CDQ groups have invested in and operated shoreside processing plants, provided loan and grant programs for equipment and permit purchases, and offered vocational and training opportunities.

The CDQ groups’ primary source of income is from harvesting activities in the fisheries of the Bering Sea and Aleutian Islands (“BSAI”). The CDQ program’s investment and operational focus on the BSAI is mandated by both state regulations and the MSA.5 The program’s goal when established by the State of Alaska in 1992 was to bring at least a portion of the fisheries wealth of the Bering Sea to the Alaskan communities along its shoreline and allow those communities to create a sustainable fishery-related economy. The CDQ program is a hugely successful and important economic development program, unique to Alaska and the United States.

For most CDQ groups, the main revenue source is their portion of the annual 10% allocation of the harvestable amount of Bering Sea Walleye Pollock, as well as further investment in Bering Sea pollock fishing vessels. This harvest is conducted primarily on at-sea catcher processors that are subject to extensive regulations regarding the harvest of salmon as bycatch.6 Pollock is the anchor fishery of the CDQ Program and revenue derived from this fishery source accounts for approximately 70% of every CDQ dollar spent in Western Alaska. Our program is absolutely dependent upon the direct revenue generated from pollock to continue to provide benefits and programs to our residents. The pollock fishery is also critical to the viability of many shoreside operations throughout the BSAI that support our numerous communities and small boat operations and allow for continued participation in and access to local fisheries.

It is important to note that the CDQ Program is a regional Western Alaska program. The MSA requires the CDQ entities to be under their Western Alaska communities’ local control and most groups have most, if not all, of their Board of Directors living in their member communities.7 Indeed, many of the Western Alaska tribal members are heavily involved in the CDQ Program,

sitting on their boards and co-investing and managing in-region activities. Through the structure mandated by the MSA, the CDQ program remains accountable to its residents.

The emergency action request from the Western Alaska groups that proposes zero chinook salmon bycatch in the pollock fishery would immediately shut down BSAI pollock fishing and eliminate the source of much of the funding for in-region expenditures by the CDQ Program. The potential cost to Western Alaska and the CDQ program is enormous. Again, we believe that all stakeholders must do everything possible and reasonable to reverse the decline of these salmon runs, but we also believe that eliminating the pollock fishery would not meaningfully address the failure of these salmon runs.

The way forward is for all Western Alaska stakeholders in the salmon fisheries, commercial and subsistence harvesters, as well as those taking salmon in the BSAI as bycatch, to determine the several causes of these runs’ decline and take action to reverse them. We think that any consideration of further Chinook bycatch cap limitations or the imposition of a Chum salmon bycatch cap must very carefully analyze both the potential for any meaningful benefits to the salmon resource and the impacts of possible constraints on other fisheries. The best path is through the North Pacific Fishery Management Council process which has the extensive scientific resources and regulatory responsibility to address any part of this issue.

In conclusion, the cost of shutting down the BSAI pollock fishery to Western Alaska would be enormous. The CDQ groups share the petitioners’ desire to return healthy salmon runs to Western Alaska; we serve the same people. We can commit to work with our residents to achieve this result, while hoping to avoid costly and unnecessary disruptions to our CDQ benefits programs upon which our residents rely.

Thank you for considering our views.

Sincerely,

Cc: Dr. Richard Spinrad, NOAA Administrator

Janet Coit, NMFS Assistant Administrator

Doug Mecum, NMFS Alaska Regional Administrator

Senator Lisa Murkowski, U.S. Senate Senator Dan Sullivan, U.S. Senate Representative Don Young, U.S. House of Representatives

 

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