Statewide Board of Fish

Dear Chair Carlson Van-Dort and Members of the Board,

We, the undersigned organizations, businesses, fishermen, municipalities, Tribal entities, and community leaders from across Alaska, write in opposition to Proposals 170, 171, and 172.

Alaska’s hatchery system is not a blunt instrument. It is a precision tool. For decades, hatcheries have operated under one of the most rigorous oversight systems in the world, with detailed permits, genetics review, monitoring requirements, tagging, reporting, and ongoing evaluation by the Alaska Department of Fish and Game. The Board of Fisheries plays an important role in this framework, including amending specific permit terms such as egg take when supported by science and regional review. But Proposals 170–172 do not offer targeted, permit-specific adjustments. Instead, they impose sweeping, statewide reductions untethered from localized performance, watershed-level data, or community consultation.

Hatchery systems are regionally designed and locally governed. Across the Gulf of Alaska, hatcheries function as integrated systems where pink and chum salmon production supports research capacity, monitoring infrastructure, sport and subsistence access, cost recovery that funds operations, and long-term datasets that inform salmon science statewide. Abrupt, across-the-board cuts destabilize that entire framework without demonstrating that such reductions would meaningfully improve ocean conditions or distant wild stocks.

If adjustments are needed, they should be precise, data-driven, and regionally informed. Alaska already has the tools to address straying through improved imprinting and release strategies. Ocean interaction questions are addressed through food-web research, juvenile survival tracking, cohort comparisons, and coordinated North Pacific science. None of these challenges are solved through speculative, uniform egg-take cuts applied without localized analysis.

Public process matters. Alaska’s fisheries system is built on transparency and meaningful opportunity for engagement. The existing hatchery permitting structure allows for region-specific review, commissioner oversight, and public input on individual programs. Statewide mandates bypass this structure and reduce the opportunity for fishermen, Tribes, municipalities, processors, and subsistence users to evaluate real-world impacts before decisions are made. That shift weakens trust in a management system that has long depended on collaboration and accountability.

Hatcheries are also critical coastal infrastructure. They support food security, working waterfronts, processing capacity, and year-round employment in communities already navigating climate impacts, rising costs, and market volatility. Sudden statewide production cuts ripple outward through harbor activity, municipal revenues, and family incomes. Coastal communities need stability to invest, diversify, and plan. Removing foundational infrastructure without a clear, region-specific path forward increases vulnerability rather than resilience.

Alaska’s hatchery programs have operated for decades alongside thriving wild stocks. They serve as conservation partners by stabilizing fisheries, shifting pressure from sensitive runs, and generating the monitoring data necessary for adaptive management. Where wild stocks are struggling, the solution is stronger science and sharper tools, not blunt statewide constraints. We respectfully urge the Board to reject Proposals 170, 171, and 172. If the Board determines that adjustments are warranted in any region, those changes should occur in partnership with the established, science-based permitting process with full regional input and clear, localized findings. Precision management strengthens Alaska’s fisheries. Sweeping mandates weaken them.

Thank you for your consideration.

Sincerely,