Council Members,

In response to concerning salmon bycatch and genetic stock composition data from the North Pacific Fishery Management Council (NPFMC) and the Alaska Department of Fish and Game (ADF&G), I am calling for reform of ocean fisheries management under the NPFMC and ADF&G. As controversy mounts regarding bycatch and interceptions of salmon under NPFMC and ADF&G oversight, I urge this council to adopt policies that dramatically reduce mortality of our salmon in mixed-stock ocean fisheries and maximize the return of these fish to our depleted watersheds, river-based and adjacent fisheries, and the communities that depend on them.

In recent decades, it has become abundantly clear that the status quo of ocean fishery management under the NPFMC and ADF&G is wildly insufficient at maintaining healthy salmon populations and upholding public trust responsibilities. Unsustainable bycatch in trawl fisheries, excessive salmon interceptions in Alaska’s mixed-stock ocean fisheries, chronic failure to meet spawning goals across the coast, moratoriums and severely limited subsistence and river-based fishing opportunities, struggling local economies, and the continued decline of our king salmon demand immediate intervention.

The NPFMC was established by the Magnuson-Stevens Fishery Conservation and Management Act (MSA) to manage marine fisheries off the coast of Alaska in efforts to prevent overfishing, minimize bycatch, increase long-term economic and social benefits, and ensure equitable fisheries. ADF&G, which implements and manages marine fisheries overseen by the NPFMC, similarly has a mission to protect, maintain, and improve the fish resources of the state, and manage their use and development in the best interest of the well-being of the people, consistent with the sustained yield principle and constitutional public trust responsibilities.

Despite the guiding principles and missions of the NPFMC and ADF&G, fisheries data and the experiences of local communities across the coast show that these management bodies have failed to meaningfully reduce bycatch and interceptions, provide for equitable fisheries, ensure the well-being of the people, halt overfishing, and maintain healthy spawning levels for king salmon populations across watersheds of the coast:

• Western Alaska: Yukon kings have fallen to less than 10 percent of their historical average of 150,000 adults in the upper basin. Commercial and sport fisheries directed at king salmon in the Yukon were suspended for seven years, extending to 2030; subsistence fishing remains severely constrained, with closures occurring every summer since 2021.
  
  
• Alaska Peninsula: Spawning goals for Chignik River kings have been missed seven of the last nine years, with returns hitting a record low of 267 fish in 2023. Subsistence users have faced severe fishing constraints or closures, and in 2026, local communities could not keep king salmon around Chignik.
  
  
• Cook Inlet: The Kenai River produced the all-tackle world-record king salmon in 1985, and it has now been closed to king salmon sport fishing for the last four summers. Late-run Kenai kings fell to a record low of 6,906 spawners in 2024. East-side commercial setnetters did not fish at all in 2023–2024.
  
  
• Southeast Alaska: The Stikine River has fallen short of its spawning goal nine years in a row (2016–2024), and other rivers—such as the Situk, Chilkat, Unuk, Alsek, and Taku—have also routinely missed spawning goals. River-based and adjacent communities have faced significant fishing constraints, and federal managers have closed the Stikine subsistence king salmon fishery every year since 2017.
  
  
• Pacific Northwest: Spawner escapement on the Washington Coast, and elsewhere, has trended downward, and spawning goals have been missed repeatedly in various watersheds including Grays Harbor, the Queets, and the Hoh. River-based and adjacent fisheries have faced severe restrictions and closures while ocean fisheries in Alaska have continued, harvesting and killing over four times as many Washington Coast kings than all local Tribal, commercial, and recreational fishers combined.
  
  

While communities in and near these watersheds, among many others, have made numerous sacrifices to recover their local salmon populations—giving up subsistence, commercial, and recreational fisheries—tens of thousands of king salmon bound for our depleted rivers across the coast are intercepted and killed annually miles from home in industrial-scale, mixed-stock ocean fisheries at the authorization of this council. 

Mortality of our salmon in these Alaskan ocean fisheries reduces spawning returns, undermines conservation efforts, and limits fishing opportunities for river-based and adjacent communities. This demonstrates an unacceptable imbalance in the sharing of fishing privileges and the conservation burden for salmon populations across the West Coast: while communities in or near their salmon watersheds bear the cost of conservation through years of closed subsistence, sport, and commercial fisheries, unsustainable ocean-based fisheries that kill mixed stocks of king salmon and other species bound for our watersheds are authorized to continue, receiving the bulk of the fishing privileges for our salmon.

Whether you desire the return of subsistence harvests on the Yukon, Kuskokwim, and Chignik watersheds; the reopening of sport and commercial fisheries; a future for river-based commercial fishing families and salmon-dependent communities; or the recovery of our king salmon runs—the NPFMC’s decisions are immensely consequential to the people of Alaska and the Pacific Northwest.

Given what is at stake, I urge you to implement substantial reforms to ocean fisheries management under the NPFMC and ADF&G that improve stock-specific accounting of fisheries mortalities; advance a cohesive strategy among management bodies to manage for all salmon mortalities; reduce bycatch and interception of king salmon in unsustainable mixed-stock ocean fisheries; and increase the return of these fish to our local watersheds, river-based and adjacent fisheries, and the communities that depend on them. Specifically, I am calling for the following:

1. Lower salmon bycatch limits in the Gulf of Alaska and Bering Sea groundfish fisheries.
   
   
2. Reduce ocean fishery interceptions of salmon and uphold conservation and equity principles of the MSA and the provisions of the Endangered Species Act (ESA). Provide additional oversight to ADF&G-managed ocean salmon fisheries and ensure compliance with federal law.
   
   
3. Provide complete and timely genetic identification of salmon bycatch and interceptions, so that affected communities across the coast know which rivers those fish were bound for.
   
   
4. Formally request that NOAA Fisheries facilitate a joint cumulative harvest and equity analysis for ocean fisheries and individual salmon populations. For the first time, establish a cohesive database and reporting system that fully accounts for all salmon harvest and bycatch mortality of individual salmon populations that occurs in various ocean fisheries overseen by the Pacific Salmon Commission (PSC), the NPFMC, and the Pacific Fishery Management Council (PFMC) to improve our understanding of total harvest-related mortality, the distribution of fisheries mortalities, and management’s achievement of equity and conservation provisions of the MSA and ESA.
   
   
5. Manage ocean fisheries with a full understanding of the total quantity of harvest-related mortality that actually occurs (including directed harvest, incidental harvest, and bycatch mortality). By using all available data from the NPFMC, PSC, and PFMC, fisheries management bodies can make more informed decisions to better conserve individual salmon populations and promote equitable fisheries across the coast.
   
   

The public will no longer accept a system in which industrial-scale ocean fisheries harvest the majority of our king salmon while local watersheds and associated communities across the coast bear the costs of recovery efforts, fishing restrictions, and declining salmon populations. Strong leadership, better data, and responsible management are needed to ensure the NPFMC and ADF&G better serve the people, our fisheries, salmon, and all future generations.

Thank you for acting upon these concerns and upholding your public trust obligations.