National Standards Guidelines
September 20, 2023: Last week marked a significant moment in fisheries management advocacy, with thousands of Alaskans and Americans alike, along with an array of diverse groups including Tribal Governments, fishing industry associations, municipalities, Community Development Quota (CDQ) organizations, sportfishing enthusiasts, and Alaskan small businesses, voicing their concerns to the Biden Administration and the U.S. Secretary of Commerce. The collective call to action was for updates and enhancements to the management guidelines governing the pollock trawl fleet and their massive bycatch.
The groups voicing these concerns included the Kuskokwim River Inter-Tribal Fish Commission, Bering Sea Fishermen’s Association, Alaska Bering Sea Crabbers, Native Peoples Action, SalmonState, Alaska Longline Fishermen’s Association (ALFA), The Boat Company, Bear Trail Lodge, DeepStrike Sportfishing, Central Bering Sea Fishermen's Association, and Representative Mary Peltola.
Thank you to all who submitted your comments!
Read the press release here.
Alaska Roadless Rule
The most recent public effort, which was completed just over two years ago, resulted in a recommendation from a broad-based stakeholder committee to make all Tongass inventoried roadless areas off-limits to logging. This came after a thorough review of Tongass economics, ecology, and human use and after countless hours of research, public input, and discussion.
At the request of Governor Dunleavy, the Forest Service has launched yet another reconsideration of Tongass management and the Roadless Rule. That request has resulted in six alternatives: the status quo (Alternative 1), which would retain protections for Alaska’s roadless forest, and five alternatives that allow logging on 185,000 acres of Tongass National Forest that are currently off limits to logging.
Where Governor Dunleavy sees board feet, most Southeast residents see a complex forest ecosystem—in fact, the largest temperate rainforest in the world, 16.9 million acres that host 14,000 miles of anadromous salmon habitat, 12,000 square miles of estuarine habitat, 20,000 lakes and 40,000 miles of river. This richly productive habitat returns goods and services every year, year after year, provided the forest is not destroyed for the trees.
The Alaska Sustainable Fisheries Trust’s SeaBank Annual Report captures the economic value of the Tongass goods and service:
Southeast is the state’s largest salmon producing region in terms of volume, with over 53 million salmon returning every year.
Annual commercial fisheries dividends include 300 million pounds of seafood/year; 10,000 jobs; $700 million total economic impact on Southeast communities.
Tongass lakes and rivers are worth an estimated $363 million in fishery/ recreation assets and regulating services.
Tongass coastal wetlands provide $22.3 billion in ecosystem services.
The 11 million acres of Tongass rainforest annually provision $13 billion in ecosystem services—including water regulation, wildlife/fish habitat, and carbon sequestration
All that value depends on the natural capital of the Tongass—the forest, the rivers, the estuaries– remaining intact—in other words, a forest, not board feet. Weigh that against the value of harvesting the board feet: Since 1982, timber harvest on the Tongass has COST U.S. taxpayers $1.5 billion in subsidies.
Decision-makers have argued that removing the roadless protections will not necessarily lead to more timber harvest, but instead simply remove barriers to non-timber projects. Of the 58 Alaska non-timber projects that have sought permitting exemptions since implementation of the Roadless Rule, 58 permits have been granted.
Predictably, logging and road building impacts under any of the proposed alternatives to status quo (Alternative 1), will be concentrated on Southern SE Alaska and Prince of Wales in particular. These are the most productive forests in the Tongass and the region with roadless areas adjacent to already roaded areas. These are also the top regions in southeast Alaska for coho and pink salmon production. These areas have already suffered habitat loss at a much greater rate than other portions of southeast Alaska. Prince of Wales Island in particular is the most productive island ecosystem in southeast Alaska for pink, coho and sockeye salmon, providing over a thousand miles of pink salmon streams and 1,904 stream miles of coho habitat. In fact: roughly a third of the river systems identified by ADFG as the Primary Salmon Producer watersheds are on Prince of Wales.
The Forest Service and landowners have logged the 1.5 million acres on North Central Prince of Wales Island area so intensively that only 15 percent of the watersheds consist primarily of intact habitat.
The Forest Service now plans to remove nearly two-thirds of a billion board feet of timber from old-growth and recovering, immature second-growth forests over the next fifteen years and add 122 miles of new road construction in fish habitat.
In southeast Alaska, watersheds damaged by intensive logging and road construction take over a century to recover. Logging recovering forests will permanently degrade aquatic habitat. The new logging will increase sedimentation, reduce summer stream flows, and add 436 stream crossings to the 477 barrier culverts on the island that block nearly 100 miles of spawning habitat.
Harvest data from 2017 and 2018 indicate that productivity from Prince of Wales Island watersheds is declining at a faster rate than other portions of southeast Alaska, raising serious questions about whether effects from recent timber sales are adding to losses associated with declines in marine productivity.
The most staggering recent decline in pink salmon harvests was in Alaska Department of Fish and Game fishery regulatory district 2 – populations that spawn in north central Prince of Wales Island watersheds that once formed the most productive pink salmon ecosystem in southeast Alaska.
The 2000 Roadless Area Conservation final Environmental Impact Statement (EIS) identified numerous risks to aquatic habitat associated with timber road construction, including increased sediment, degraded water quality, habitat fragmentation, and high temperature regimes. Road construction in inventoried roadless areas is likely to add to existing habitat loss. There are currently 1,100 stream crossings, mostly failed culverts, on Forest Service lands alone in southeast Alaska that function as small dams, blocking 250 miles of important stream spawning habitat. The recently released draft EIS, which informs this decision, notes that: “roads pose the greatest risk to fish resources on the Tongass” (p. 3-112), but then goes on to claim that exempting the Tongass from the Roadless Rule would have “negligible” effects on fish habitat (p. S-15). Consequently, according to the DEIS (p. 3-51), “While there would be some variation in the level of protection, these variations are not expected to affect the fishing industry.” This statement is unsubstantiated.
The impacts of losing additional spawning and rearing habitat in southeast Alaska aquatic ecosystems are substantial given current population vulnerabilities. Further declines in salmon productivity may result in prolonged periods of fishery closures, risking the viability of hundreds of Alaska resident-owned small fishing businesses, southeast Alaska salmon processors, and the communities and support businesses that rely on the fishing economy. These impacts will be heightened by climate change.
Every Southeast resident–and especially every Southeast fisherman–should consider what is at risk with the proposed roll-back of the Roadless Rule.
You can comment on the Roadless Rule alternatives until December 17th by following this link.
National Issues
The Magnuson-Stevens Fishery Conservation and Management Act (MSA) is the primary law governing off-shore fisheries in the United States. It was first passed in 1976, and has undergone a series of amendments strengthening the MSA's power to rebuild fish stocks and enforce sustainable, conservation-minded fisheries management.
The law is up for renewal this year, but re-authorization bill H.R. 1335 threatens to stagnate the process of revitalizing our fisheries, or even to undo past gains. H.R. 1335, which passed the House last fall, introduces a language of "flexibility" into the timeline for rebuilding fish stocks, which may make things easier on fishermen in the short term but is an incredibly risky strategy in the long run.
ALFA has joined forces with the Alaska Marine Conservation Council and three other small-boat commercial fishing groups to form the Fishing Communities Coalition, an alliance advocating for a more robust Magnuson-Stevens Act that will take on the issues important to sustaining our nation’s fisheries for the future. The FCC is working to educate Congress on the importance of sustaining coastal economies by protecting healthy marine fisheries, and ALFA members traveled to D.C. this fall to assist with this effort.
FCC's aims include:
Preventing overfishing and rebuilding overfished stocks.
Reducing bycatch and protecting directed fisheries (Alaska’s halibut fishery, for example)
Advancing electronic monitoring as an alternative to observers.
Supporting local access to fisheries through permit banks, trusts and community fishery associations.
ALFA is also a member of the Marine Fish Conservation Network, which is a broad-based coalition of environmental groups, aquaria, commercial and recreational fishing organizations with a shared agenda of promoting healthy oceans, productive fisheries and community-based fishermen. Through both coalitions we are working to build partnerships with the slow foods/sustainable seafood movement and to engage restaurants, chefs and consumers in promoting sustainable fisheries and strong fishing communities. A Senate MSA bill is not expected until after the presidential elections, which gives fishermen time to build new champions in Congress. ALFA will continue to work with coalition partners and policy-makers to advocate for this important law. We hope to bring ALFA members to the New Orleans Slow Foods celebration, the Boston Seafood Show, and DC in March as part of this effort.
For more updates and information, visit the Fishing Communities Coalition or Marine Fish Conservation Network websites.
View this handout on the MSA reauthorization from the Marine Fish Conservation Network.