Board of Fish Hatchery Meeting Talking Points for Testimony

Comments due September 29th

Submit Via https://www.adfg.alaska.gov/index.cfm?adfg=fisheriesboard.meetinginfo&date=10-14-2023&meeting=anchorage

This will be an 8-hour meeting in Anchorage at the Egan Center.  A live-feed of the meeting will be available on YouTube.  Remote testimony is not permitted.  Persons wishing to testify must be at the meeting. Questions or comments should be submitted into the public record by September 29th. As this is a Committee-of-the-Whole meeting, it will be non-regulatory.  No action will be taken by the Board but recommendations can be carried forward to future Board meetings.  

The only purpose of the Board of Fisheries Hatchery Committee meeting is to provide an annual review of the Alaska PNP (Private-Non-Profit) hatchery system related to the Board’s responsibility and authority. This includes research reports and hatchery production review. This meeting does not apply to any other hatchery management.  

Brief History  

The Board of Fisheries was established under Alaska Statute 16.05. 221. While the Alaska Department of Fish and Game was established when Alaska became a state in 1959, the Board of Fisheries was not established until 1975 with the goal of allocating salmon to users. The Board of Fisheries was created for purposes of conservation and development of the fishery resources of the state to ensure that fish stocks in the state shall be managed consistent with sustained yield of wild fish stocks as the priority (AS 16.05.730) 

The Alaska Hatchery Act establishing the PNP Hatchery system was adopted in 1974.  Section 1. INTENT. It is the intent of this Act to authorize the private ownership of salmon hatcheries by qualified nonprofit corporations for the purpose of contributing, by artificial means, to the rehabilitation of the state’s depleted and depressed salmon fishery. The program shall be operated without adversely affecting natural stocks of fish in the state and under a policy of management which allows reasonable segregation of returning hatchery-reared salmon from naturally occurring stocks. 

The PNP hatchery program has grown enormously since then and has outlived its stated purpose. There are many questions about hatchery impacts on wild stocks all over the Pacific Northwest and that includes Alaska. 

State of Alaska law (Policy for management of sustainable salmon fisheries – 5 AAC 39.222) mandates that hatcheries shall operate without adversely affecting natural stocks of fish. Assessing that impact is the Board of Fish responsibility.  However, except for a 1977 authority given to the Board of Fisheries for salmon broodstock releases under a hatchery permit, there was no annual Board oversight on hatcheries between 1974 and 1999. In 1999, the first Board of Fish hatchery committee was established. The committee did not meet until 2001 but only for two years to establish protocols. Between 2003-2018 there were no Board hatchery meetings.  In 2018, the Board adopted the Committee of the Whole (entire Board) which met for a full day since, except 2021 due to Covid. This means that for most of the 49 years of the PNP hatchery program, there was no public review or Board of Fish oversight.  

Some suggested recommendations for the Board at this meeting: 

(1) Egg production is at the heart of the Board of Fish authority over hatcheries and it is the heart of the current problem with over-production of pink and chum salmon that may be threatening wild stock. This needs a broader discussion to provide information to the Board at a regulatory meeting.  Request a full disclosure going back to 1974 of the regulations relating to egg production, including legislative mandates. 

(2) We need independent science. Create an independent science review team, outside of the Alaska Department of Fish and Game, to assess impacts of hatcheries on Alaskan wild stock 

(3) Allow future Hatchery Committee meetings to provide for Zoom presentations by invited scientists, etc. 

(4) Provide for full analysis of hatchery straying research to date for both pink and chum salmon 

(5) Request a full cost-benefit analysis of hatcheries in Alaska.  This is likely a legislative request but should be discussed at the hatchery meeting. 

(6) Request an analysis of Alaska hatchery impacts specifically on BBAYK stocks.  This would include the impact of young BBAYK chum salmon that migrate to the Gulf of Alaska to feed. (Note:  all Alaska PNP hatcheries are the Gulf of Alaska; the request would be a genetic analysis of interaction with BBAYK wild stock at all life stages.)

Resources: 

Maps of Alaska PNP hatcheries https://www.adfg.alaska.gov/static/fishing/PDFs/hatcheries/ak_hatch.pdf

Annual enhancement reports https://www.adfg.alaska.gov/index.cfm?adfg=fishingHatcheriesOtherInfo.reports

ADF&G Hatchery web links https://www.adfg.alaska.gov/index.cfm?adfg=fishinghatcheries.main

 

Legislation and related policies   

Alaska Salmon Hatchery and Enhancement Statutes  https://www.adfg.alaska.gov/static/fishing/PDFs/hatcheries/hatchery_statutes.pdf

Alaska Salmon Hatchery and Enhancement Regulations https://www.adfg.alaska.gov/static/fishing/PDFs/hatcheries/regulations.pdf

AS 16.10.375- AS 16.10.560 – Alaska Hatchery Act 1974

Board authority, findings, regulations 

5 AAC 39.222 – Policy for the management of sustainable salmon fisheries

5AAC 40.005 -.40.990 Private Nonprofit Salmon Hatcheries

5AAC 41.001 – 41.100 Transportation, Possession and Release of Live Fish; Aquatic Farming