Response to NOAA survey on bycatch

by Nels Anderson Jr.

To the NOAA (National Oceanic and Atmospheric Administration): Aug 26, 2023

My experience tells me that a lot of the info that you folks present is based on incomplete data regarding bycatch numbers. I don’t believe that we have a robust enough observer program that is sufficient to get accurate counts of how many chum and king salmon are being caught as bycatch and discarded as WANTON WASTE.

In your article you don’t mention the Area M fishery and the number of chums and kings that are caught and discarded or otherwise disposed of.

You base too much of your theory on the decline of chum and king salmon on climate change. I think that is erroneous and cannot be proven with scientific facts to validate your case.

What is happening in the Bering Sea and the Gulf of Alaska fisheries is WANTON WASTE.

Arguing that climate change is the primary culprit to blame for chum and king salmon is blatantly devoid of any science that can demonstrate and prove that lower numbers of chum and king salmon returning to their streams of origin in Bristol Bay and the Western coast of Alaska is caused by climate change only.


The Bering Sea and Gulf of Alaska may be on the brink of collapse and delays on mitigation, phased in full utilization, serious caps on king salmon, chums, halibut AND eliminating WANTON WASTE and bycatch will guarantee ecosystem failure and collapse from which we will never be able to recover from.

Your argument focuses on climate change as the single factor causing the lower returns of chum and king salmon to Bristol Bay and Western Alaska rivers. It is NOT the only factor.

Bycatch, WANTON WASTE discarding practices, climate change , hatchery fish, ocean acidification, retreating ice edge, warming river systems , limited feed for larger populations in pacific / North Pacific , industrial activity along major river systems … all contributing factors to the decline in wild capture species.

I’m hoping honorable US Representative Mary Peltola will act decisively at the federal level and force meaningful action from the Alaska governor and legislature, NOAA, NPFMC and the Gulf of Alaska and Bering Sea fishing industry.

Our country needs long term protection of our Bristol Bay Watershed, which produces the largest salmon runs on the planet, with actions for long term protection which needs to be expanded to include the long term ecological health of the Bering Sea since our immature salmon migrate out there to mature before coming back to our Bristol Bay Watershed.

Since we know that over the past 10 years, the Bering Sea and Gulf of Alaska trawl fleets have caught, killed, and discarded approximately 141 million pounds of salmon, halibut, crab, and sable fish per year.

We should be stopping this wanton waste by whatever means possible at our disposal. Much of the salmon kills are from our Bristol Bay Watershed and Western Alaskan streams so it makes sense to expand our efforts to include stopping wanton waste in the Bering Sea and the Gulf of Alaska.

The Bristol Bay Watershed and our Bering Sea are joined together by salmon movement from the Bristol Bay Watershed to and from the Bering Sea every year.

IF the Bering Sea and Gulf of Alaska are destroyed by WANTON WASTE fishing practices, both ecosystems will collapse.

The Bering Sea and Gulf of Alaska ecosystems are reeling.

For the first time in history, the Bering Sea snow crab fishery has been shut down for the 2022/23 season. And for the second straight season, the 2022/23 Bristol Bay red king crab fishery is closed as well. Yukon River Chinook salmon are forecasted to return in low numbers in 2023, and the chum salmon return is uncertain – leading state managers to close subsistence fishing in the Lower Yukon.

Bristol Bay king salmon are now designated as a species of concern because of their low returns to their rivers of origin.

Meanwhile, trawlers pursuing pollock for fish sticks and fake crab continue to indiscriminately catch massive amounts of a multitude of fish species including salmon, crab and halibut. This harvest of non-targeted species, called bycatch, cannot be sold to market, is oftentimes considered “waste,” and is dumped overboard.

While nearly every other sector of the Bering Sea based fishery suffers, the largest, most wasteful one continues full steam ahead. This must change. I urge NOAA fisheries to update guidelines for National ByCatch Standards to better address bycatch, WANTON WASTE fishing practices, environmental changes, and inequity in federal fisheries management.

In conclusion, failure to act is a direct attack on the Tribal customary, historical, and traditional Subsistence use of salmon, halibut, and cod in Bristol Bay and the Gulf of Alaska. Continued flawed management practices and failing to adopt serious and meaningful mitigation and intervention will guaranteed the collapse of the Gulf of Alaska and Bering Sea Ecosystems and the USA will lose a significant source of protein that our country and world needs for food.

Nels Anderson, Jr.

Curyung Tribal Member USAF Veteran

Example: 9075434113

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