ACTION ALERT

COMMENT ON POTENTIAL GULF OF ALASKA CHINOOK SALMON ENDANGERED SPECIES ACT (ESA) LISTING

COMMENT DEADLINE: SEPTEMBER 6, 2024

 RDC Comment Letter

A petition was submitted on January 11, 2024, to the National Marine Fisheries Service (NMFS) by the Wild Fish Conservancy, a Washington state-based environmental group, requesting critical habitat of any Gulf of Alaska (GOA) Chinook Salmon subpopulations be listed and designated under the Endangered Species Act (ESA). NMFS recently issued a positive 90-day finding on this petition, which starts a formal status review under the ESA. The result of the status review will be a decision on whether to list any or all GOA Chinook Salmon stocks as threatened or endangered under the ESA. On June 3, the Alaska Department of Fish and Game (ADF&G) sent a letter to the National Oceanic and Atmospheric Administration (NOAA) resulting in the comment period on this finding being extended to September 6, 2024.

Background: The massive area under review includes Chinook Salmon that spawn in the rivers of Southeast Alaska, Prince William Sound, Cook Inlet, Kodiak, and the Alaska Peninsula. The positive finding indicates that NMFS believes the petition provides substantial enough information that an ESA listing for these Chinook stocks may be warranted.

NMFS acknowledges in the 90-day finding that the petition has “numerous factual errors, omissions, incomplete references, and unsupported assertions and conclusions within the petition,” which should have disqualified the petition from consideration under NMFS’s regulations. Despite that, NMFS proceeded with making the positive 90-day, citing uncertainty around the cause of missed ADF&G escapement goals in recent years and evidence of decreasing size and age of Chinook at maturity.

More Info Links:

How to Submit Comments: Comments are open until September 6, 2024.

  1. Online: Visit https://www.regulations.gov and enter NOAA-NMFS-2024-0042 into the search box. Or go to this link: Endangered and Threatened Species: 90-Day Finding on a Petition to List Gulf of Alaska Chinook Salmon.
  • Click on the proposed rule titled “Endangered and Threatened Species: 90-Day Finding on a Petition to List Gulf of Alaska Chinook Salmon” then click on the “Comment” icon underneath the title, complete the required fields, and enter or attach your comments.

Points to Address in Your Comments:

  • The petition should never have been accepted: As NMFS acknowledged, the Wild Fish Conservancy’s petition did not present “a complete, balanced representation of the relevant facts, including information that may contradict claims in the petition,” (50 C.F.R. § 424.14(d)(5)) as called for in the regulations for ESA listing petitions. NMFS never should have accepted the Wild Fish Conservancy’s petition to list GOA Chinook salmon under the ESA as a “reasonable person” should not conclude that GOA Chinook salmon are at risk of going extinct now or in the foreseeable future.
  • ADF&G has and will continue to provide better management than a Federal alternative under ESA: The ESA is an inappropriate tool to address a downturn in Chinook productivity. The State of Alaska has a proven track record of sustainably managing the state’s salmon stocks. Alaska has rebuilt salmon runs from abundances that were far lower than they are today. Alaska’s salmon management was designed, and is carried out, to avoid the health of stocks ever being jeopardized again like they were under pre-statehood federal management.
  • NMFS should be wary of using models that can be extrapolated to reach any desired conclusion: The use of long-term climate models to predict the status of Chinook stocks into the future requires a host of assumptions that may or may not be accurate.  Listing a species under the ESA based solely on projections that it will suffer from speculative habitat loss in 100 years removes all meaningful barriers to listing under the ESA.

Thank you for your participation

COMMENT DEADLINE: SEPTEMBER 6, 2024