March 20, 2012
Southeast Regional Citizens Advisory Committee
U.S. Fish and Wildlife Service Office of Subsistence Management
3601 C St., Suite 1030
Anchorage, AK 99503
Dear Southeast Regional Advisory Committee Members,
United Fishermen of Alaska is the largest statewide commercial fishing trade association,
representing 37 commercial fishing organizations participating in fisheries throughout the state and its
offshore federal waters, and hundreds of individual fishermen.
UFA has a longstanding policy of supporting the Board of Fisheries process. Many
of Alaska’s commercial fishermen and UFA’s members are also federally qualified subsistence users
of fish and wildlife. We stand united across the state in our support of the Board of Fisheries process
and State management and in opposition to federal intervention through extraterritorial jurisdiction in
any waters of Southeast Alaska.
Although this is a long, complicated topic, especially concerning the Kanalku Lake sockeye system,
which had its first dynamite blasting for fish passage in 1968, we would like to briefly make a few
points to clarify our position on the issue of Kootnzawoo, Inc.'s petition.
1. There is no basis for a claim. The state of Alaska manages state waters fisheries. Both the
Chatham Strait purse seine fishery and the local Chatham Straits subsistence fishery are state
waters fisheries. There has been no interference with a Federal subsistence fishery.
2. The sockeye systems in Chatham Strait have been in good shape in the past decade with the
exception of Kanalku, which has experienced the most robust rebound to the two largest
years that have ever been counted in the history of Angoon- 2009 and 2010.
2009 and 2010 provided excellent examples of why seine fleet harvest isn't an issue with the health of
Kanalku or the other sockeye systems in Chatham Strait. In 2009, the seine fleet fished one of the
highest boat days ever in the Angoon region. In 2010, the seine fleet fished zero days in the Angoon
region. The return to Kanalku both years exceeded 3000 sockeye; clearly the intensity of seine effort
in the area did not affect the return of Kanalku sockeye.
3. There has never been a single Kanalku sockeye salmon tagged or otherwise marked identified
as having been harvested by a seiner. Not one.
4. The USFS permitted logging to the creek at Kook Lake. A recent survey found that
streamside erosion associated with logging had caused a large log to fall into the creek and
completely block passage of sockeye.
5. The Kanalku system needs a fish ladder. The USFS has documented that up to 70% of the
sockeye die in some years between the creek and the lake. Obviously years of lower
hydraulic pressure, such as 2009 and 2010, result in less fish loss than the years of higher
water flows, but there is still a major need for fish passage. The USFS aptly documented this
with a study in 2011.
6. Ironically, just as Kook Lake fell victim to a log blockage of the cavern (Kook Lake services
an underground sockeye stream that can be entirely blocked by logs or woody debris),
Kanalku also had a major logjam issue about a decade ago. Local residents claim it took
over a year to remove the log that was blocking sockeye passage.
This is a specious and confrontational petition without merit. UFA asks that you dispose of this issue
and move along to other management or social issues on which we can work together in the great
Until the Board of Fisheries decisions are shown to interfere with federal subsistence priority, there is
simply no legal basis for bypassing state management in Alaska’s salmon fisheries.
The Commissioner of the Alaska Department of Fish and Game has the authority to make emergency
orders to change the regulations during the season or to make changes for the future.
Only after the state’s authority and ability to manage its fisheries has been scientifically proven to
interfere with the subsistence fishing priority would justification exist for federal intervention. Such
federal intervention would be likely to affect hundreds or even thousands of individuals who work in
fishing and seafood processing jobs in the affected area.
United Fishermen of Alaska feels that there is no compelling factual or scientific reason at this time to
justify the unprecedented and drastic imposition of federal extraterritorial jurisdiction. Extraterritorial
jurisdiction is an extreme measure to be considered only as a last resort when all other measures to
ensure subsistence harvests have failed. Alaska’s system of fisheries management has an unsurpassed
reputation and serves as a model for the world. As the world leader in fisheries management, the
State of Alaska should be given deference to manage its resources until it has been proven to have
failed in its obligations to federal subsistence users.
Thank you for the opportunity to provide our comments on this most serious issue.
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