289th Session of the Pacific Fishery Management Council
Submit written comments by September 16 at 5:00 PM.
Submit written comments by September 16 at 5:00 PM.
The Pacific Fishery Management Council will meet in person in Vancouver, Washington, for its 289th Session, with live-streaming and remote options for participation available, including opportunities for public comment.
Members of the public may provide testimony, either in person or online.
It’s critical that the Council hear directly from the people its members are appointed to represent—not just agencies and industry interests.
We’ve made it easy for you to provide testimony with step-by-step instructions for providing written or oral testimony, including sample comments you can use as written or personalize to reflect your own perspective.
IMPORTANT: Written comments must be submitted through the Pacific Fishery Management Council’s E-Portal. Please review the instructions below before accessing the portal. The deadline to submit written comments is June 9 at 5:00 PM.
Step 1: Access the E-Portal and select agenda item B1 (Comments on Non-Agenda Items) to open the comment submission form for that agenda item.
Step 2: Review the Sample Comments below and submit as written or personalize it to reflect your own perspective. Please Note: Comments exceeding 4,000 characters must be uploaded through the online portal submission form as an attachment.
Step 3: Complete the remaining required fields and click “Submit.”
Sign up for oral testimony through the Council’s E-Portal beginning September 17 at 8:00 AM.
Step 1: Access the E-Portal and select agenda item B1 (Comments on Non-Agenda Items) to open the oral testimony sign-up form for that agenda item.
Step 2: Review the Sample Comments below and share as written or customize it to reflect your unique perspective. Note: Comments under 4,000 characters can be copied and pasted directly into the submission form’s comment field. Comments exceeding 4,000 characters must be uploaded as an attachment.
Step 3: Fill out the required fields, including how you plan to present your oral testimony (in person or remotely), and click “Submit.”
Step 4: If you are providing testimony remotely, review the Pacific Fishery Management Council’s short instructional video for guidance. Participants attending the session in person will be called to the public testimony table when it is their turn to speak.
Note: To submit your comment, access Council’s E-Portal and select agenda item B1 (Comments on Non-Agenda Items).
Council Members,
I urge the Pacific Fishery Management Council (PFMC) to adopt bold positions that Let Our Salmon Come Home to the ecosystems, watersheds, and communities that depend on them.
Pacific salmon are managed by the PFMC, the North Pacific Fishery Management Council (NPFMC), and the Pacific Salmon Commission (PSC). The two Councils act under the Magnuson-Stevens Act (MSA); the PSC acts under the Pacific Salmon Treaty. All three make decisions that fall on the same fish, yet none of these management bodies effectively accounts for the cumulative effect of their decisions on salmon populations—or on the communities, Indigenous nations, and states that depend on their return. This fragmentation produces flawed calculations, outcomes that fail to promote conservation, and inequity that no single body is held responsible for addressing.
National Standard 4 (NS4) of the MSA requires that harvest allocations be fair to all fishers, reasonably calculated to promote conservation, and structured to prevent any entity from acquiring an excessive share. The second requirement is most directly at issue. An allocation cannot be reasonably calculated to promote conservation when the analysis supporting it omits a material share of the mortality. Where thousands of a stock’s mortalities occur beyond a Council’s jurisdiction and are absent from the accounting, nobody can demonstrate that its allocation satisfies NS4. This is not a dispute about who deserves the fish. It is a gap in the arithmetic, and one this Council can ask to have closed.
Each year, thousands of Chinook are taken as bycatch in U.S. groundfish trawl fisheries and harvested in seine and gillnet fisheries across the Pacific. Unlike the reported Pacific Salmon Treaty troll fisheries, these mortalities are not accounted for by the PSC’s Chinook Technical Committee, underestimating the mortality distributions essential to determining whether the conservation and equity provisions of NS4 are met. These shortcomings show in the data across watersheds in Oregon, Washington, California and Idaho: declining Chinook escapement, missed escapement targets, periods of overfishing, and fishing restrictions for local communities.
A clear example of this is on the Washington Coast. NOAA Fisheries declared Queets River spring/summer Chinook overfished in fall of 2023 and proposed a rebuilding plan in February 2026. That plan finds that a large portion of the stock’s fishing mortality likely occurs in Southeast Alaska and British Columbia, with little taken in Council-area fisheries off Washington, and concludes that closing Washington’s ocean fisheries entirely would not meaningfully change the outcome. That is not a reason for complacency. It is the clearest statement of the problem: local fishermen and Tribes absorb restrictions that produce little recovery benefit, because the vast majority of all harvest-related mortality occurs outside this Council’s reach.
I urge the PFMC to:
Please Note: The sample comment below exceeds 4,000 characters and must be uploaded through the E-Portal’s comment submission form as an attachment.
Council Members,
I urge the Pacific Fishery Management Council (PFMC) to adopt bold positions that Let Our Salmon Come Home to the local ecosystems, watersheds, and communities that depend on them.
Today, Pacific salmon are managed by the PFMC, North Pacific Fishery Management Council (NPFMC), and the Pacific Salmon Commission (PSC). The two Councils act under the Magnuson-Stevens Act (MSA); the PSC acts under the Pacific Salmon Treaty, and its legal obligations differ accordingly. All three, however, make decisions that fall on the same fish. Each body makes harvest decisions based on a complex set of jurisdictions, data periods, and its own stakeholder process. None is required to account for the cumulative effect of their decisions on individual salmon populations—or on the communities, Indigenous nations, and states that depend on the return of those fish to local watersheds. This fragmentation results in flawed calculations, outcomes that fail to promote conservation, and systemic inequity that no single body is held responsible for addressing.
National Standard 4 of the MSA establishes binding equity and conservation requirements for fishery management plans prepared under the Act. Its intent is to ensure that when harvest privileges are allocated among competing users—commercial, recreational, subsistence, and Indigenous communities—those allocations 1) reflect fairness to all fishers; 2) are reasonably calculated to promote conservation; and 3) are structured to prevent any single entity from acquiring an excessive share of the fishery resource. The second requirement is most directly at issue here. An allocation cannot be reasonably calculated to promote conservation when the analysis supporting it omits a material share of the mortality. Where thousands of a stock’s mortalities occur in fisheries beyond a Council’s jurisdiction and are absent from the accounting entirely, no participating body can demonstrate that its allocation satisfies National Standard 4. This is not a dispute about who deserves the fish. It is a gap in the full lifecycle and migratory pathways of Chinook salmon, and it is one this Council can act upon.
At present, cumulative salmon mortalities that occur in fisheries across the Pacific Ocean are not fully accounted for in analyses by the PFMC, NPFMC, and PSC. Each year, thousands of Chinook are taken as bycatch in U.S. groundfish trawl fisheries, harvested in seine and gillnet fisheries, and taken as illegal, unregulated, and unreported catch across the Pacific. Unlike the Pacific Salmon Treaty troll fisheries, whose catch is reported, these mortalities are not accounted for in analyses by the PSC’s Chinook Technical Committee, resulting in the underestimation of mortalities and insufficient calculation of mortality distributions that are essential to determining the achievement of both conservation and equity provisions under National Standard 4.
Lacking a cumulative analysis of fisheries mortalities, harvest decisions made by the PFMC, NPFMC, and PSC that frequently maximize the use of ESA-impacts are not reasonably calculated to achieve conservation limits. The shortcomings of our fragmented system of salmon management are reflected in the data across watersheds in Oregon, Washington, California, and Idaho, with declining trends in Chinook escapement, numerous years of missed escapement targets, periods of overfishing, and fishing restrictions for local communities.
One clear example is provided on the Washington Coast. In the fall of 2023, NOAA Fisheries declared Queets River spring/summer Chinook overfished, and proposed a rebuilding plan in February 2026. That plan finds that the vast majority of the stock’s fishing mortality likely occurs in Alaska and British Columbia ocean fisheries, with only a minor portion taken in Council-area fisheries off Washington. It further concludes that Council-area fisheries have limited effect on the stock’s rebuilding trajectory. That conclusion is not a reason for complacency. It is the clearest available statement of the problem: local fishermen and Tribes absorb restrictions that produce little recovery benefit, because the fishing mortality that matters the most is occurring outside this Council’s reach.
Lacking full accounting of fisheries mortalities, each management body further underestimates the severe systematic inequity that is already evident within the publicly available harvest allocation data. For example, fisheries operating out of Alaska under the approval of the NPFMC harvest Chinook salmon of which up to 98% originate from rivers outside Alaska. These Southeast Alaskan fisheries routinely take a share of Washington Coast and Oregon Coast Chinook that bears no rational relationship to any conservation objective for those stocks, and that is not accounted for in the analyses supporting harvest decisions in this Council’s area. Pacific Salmon Commission (2026) data show that over the most recent 20-year period, 47% of the total harvest of Grays Harbor fall Chinook occurred in Southeast Alaska–only 23% occurred in Washington fisheries.
Lacking cumulative accounting of Chinook harvesting, publicly available data already paint a damning picture of inequity in the allocation of these stocks. Nevertheless, when considering the many thousands of harvest-related mortalities that are unaccounted for in Alaskan waters by the PFMC, NPFMC, and PSC, we cannot reasonably calculate the enormity of this equity and conservation problem for ecosystems, watersheds, and communities across the Pacific Coast.
In closing, I urge the PFMC to:
