Raincoast submits feedback to US Fisheries Service on the harvest of Chinook salmon in southeast Alaska

Mitigation in the Biological Opinion fails to address impacts to Southern Resident killer whales and Chinook salmon recovery.

In March 2024, Raincoast submitted feedback to the National Marine Fisheries Service (NMFS) expressing concern about Chinook fisheries in southeast Alaska that remove prey for endangered Southern Resident killer whales. Further, the solution posed to remedy this problem is more production of hatchery salmon. However, more hatchery salmon have not solved the prey problem for Southern Resident killer whales so far, and will likely do little to compensate for the loss of this food source. Chinook salmon from hatcheries, especially those in Puget Sound, have been getting smaller for decades. The average size of these Chinook is now below the size range that is targeted by killer whales.

Raincoast’s submission also speaks to NMFS’s “Biological Opinion” for Southern Residents, a document that must be drafted for species listed under the Endangered Species Act if an activity (in this case, a fishery) can foreseeably harm an ESA-listed species. We are concerned that:

  • NMFS has failed to act on the 50-year decline in size-at-age and age-at-maturity in Puget Sound hatchery Chinook. As such, these young, small fish are not adequate prey for SRKW, and they fail to remedy the ‘take’ of SRKW prey in the SEAK Chinook fishery.
  • NMFS has not conducted adequate analysis to conclude there is a benefit to SRKW from the Prey Increase Program (PIP), particularly from Puget Sound hatchery production, 
  • NMFS has not demonstrated that the Prey Increase Program is a remedy to the ‘take’ of Chinook in SEAK fisheries.

Download Raincoast comments on NMFS’s Incidental Take Statement on PST Chinook fisheries in Southeast Alaska (PDF).

Raincoast also joined forces with the Wild Fish Conservancy (WFC) to submit comments on broader problems with the documents used as a basis to issue an “Incidental Take Statement” for the harvest of Chinook in southeast Alaska. Download comments on the draft Environmental Impact Statement (PDF).




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Coastal wolf with a salmon in its month.
Photo by Dene Rossouw.