Letter to ADF&G
Post Office Box 1229 / Sitka, Alaska 99835 /907.747.3400 / alfastaff@gmail.com
Commissioner Doug Vincent-Lang Alaska Department of Fish and Game Dfg.com.fisheriesdisasters@alaska.gov
May 11, 2022
Dear Commissioner Doug Vincent-Lang
I am submitting these comments from the Alaska Longline Fishermen’s Association in response to the department’s call for comment on distribution of the federal Fishery Disaster funds. ALFA is a multi-species gear group that includes trollers, gillnetters and seiners as well as fixed gear fishermen. Our organization is based in Sitka and while we have members who target sablefish and halibut in all Gulf of Alaska and some Bering Sea areas, most of our members who target salmon operate off Southeast Alaska. For this reason, our comments on the salmon disaster relief funding are addressed to the distribution of Southeast salmon disaster funds.
ALFA understands that $55,928,849 has been designated for the 2020 Norton Sound, Yukon River, Kuskokwim River, Chignik, and Southeast Alaska salmon fisheries, and 2021 Yukon River salmon fishery. In the past, affected fishermen have been the primary recipients of federal disaster relief funds and we support a similar approach in this instance. We recognize the necessity of moving this money quickly to meet subsistence needs; we also support strong disaster relief to commercial fishermen who kept working during covid to provide high quality protein to the nation despite significant risks and substantially increased operational costs. Finally, since this disaster disbursement is significantly larger than any past distributions, we ask that the Department also consider investment in fisheries research and working waterfront infrastructure. If properly directed, these investments will build resilience into the fisheries to buffer against future disruptions or fishery disasters.
1) In terms of allocating money to individual fisherman, we ask that you observe the following principles: a. Income, not numbers of fish or pounds of fish (even if considered on a species-by-species basis) is the only way to generate a fair comparison due to the extreme variation in price during different times of year and in different fisheries. For example, trollers invest in tremendous amounts of onboard labor to raise the value of their catch, focusing on quality over quantity. Dressed troll-caught winter king should not be compared to net-caught summer fish landed in the round on any basis other than value. Likewise, the “value” of a species should not be calculated by averaging across fisheries, as has been done by the State in the past. This averaging significantly diminishes compensation to a low volume/high quality fishery such as the troll fishery. In short, compensation to each fishery should reflect impacts to that fishery.
b. Year-to-year income for individual fishermen and even collectively for a gear group is notoriously volatile. To create a base period with any fewer than eight years could distort an individual’s catch history. As in the past, there would need to be some provision using fleet-wide averages in place of income in years that an individual did not fish. Specifically, due to the terms of the most recent Pacific Salmon Treaty agreement, the 2017-2019 troll Chinook catches were restricted to a lower limit than in any year since 1911. A short base period would penalize the troll fleet for Alaska’s adherence to a punitive international agreement by giving these years undue weight.
c. Fishermen who purchased a license and fished for the first time in 2020 or shortly before should be compensated for the impact to their anticipated earnings. A new entrant’s lack of base years should not reduce their disaster compensation.
2) In addition to payments to individual fishermen, Disaster Relief funds can also be used for research to improve fisheries in the future; ALFA supports consideration of also dedicating Disaster Relief funds to support working waterfront infrastructure. Relative to research, ALFA supports using these funds to support the continuation of the Unuk River and Keta River Chinook hatchery broodstocks. These programs were developed at great investment by the National Marine Fisheries Service at their Little Port Walter facility. Unfortunately, that program is in the process of being closed because NMFS considers the program to be a low priority. Without outside intervention this would mean the demise of these broodstocks and loss of this time-consuming and expensive investment. With wild Chinook stocks struggling throughout the state, any knowledge that can be gained through careful study of stock diversity has the potential for benefits far beyond the historic harvest of these releases.
3) Relative to infrastructure: OneUSDA recently solicited proposals from Southeast communities, Tribes and non-profits that would build resilience and sustainability in the region. In response, OneUSDA received proposals requesting working waterfront infrastructure repairs or upgrades totaling over $50 million. Clearly working waterfront infrastructure is inadequate or at risk throughout Southeast. For example, Sitka, with the largest small boat fleet in Alaska, is currently without a haulout or boatyard. Investment in fishery specific working waterfront would buffer the fleet against future disruptions and seems a prudent use of fishery disaster funds. The state could establish a fishery specific working waterfront or (sea)food security fund and solicit grant requests from municipalities, Tribes, or qualified non-profits to address this clearly identified need.
Above all, ALFA asks that the State move quickly to disburse funds to the subsistence, sport and commercial fishermen financially harmed by covid 19. ALFA recommends that the disbursement to individual fisherman include 60 -80 percent of the disaster relief total, with 20-10 percent of the total supporting research and 20-10 percent designated for working waterfront projects. Again, our comments are directed at the Southeast Alaska Salmon disaster disbursement. We recognize other regions may have different priorities
Thank you for soliciting comments and for your consideration of our recommendations. Sincerely,
Linda Behnken, Executive Director, ALFA