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B&J Sporting Goods Response to Chinook Salmon ESA Listing Petition
B&J Sporting Goods' Opposition to 2024 Chinook Salmon ESA Listing Proposal
A Call to Protect Alaska’s Fishing Industry Through In-State Management
B&J Sporting Goods
113 W Northern Lights Blvd. Anchorage AK 99503 | (907) 274.6113 | bnjsg.com
Proposed Rule: NOAA-NMFS-2024-0042
Anne Marie Eich, Assistant Regional Administrator
Protected Resources Division, Alaska Region NMFS
Attn: Susan Meyer
P.O. Box 21668
Juneau, AK 99802
September 6, 2024
Dear Ms. Eich,
As Alaska’s largest fishing tackle and bait shop, B&J Sporting Goods has been serving the Alaskan fishing community for decades. We are deeply connected to Alaska’s fishing culture, supplying equipment to private individuals, businesses, and organizations who rely on Alaska’s fisheries for sustenance, economic livelihood, and recreational enjoyment. Our customer base spans commercial fishermen, subsistence harvesters, guides, charters, scientific researchers, as well as out-of-state and international visitors. We are uniquely positioned to provide a perspective on the impact that any listing of Chinook (King Salmon) under the Endangered Species Act (ESA) would have.
While we recognize the need for responsible management of our salmon fisheries, we strongly oppose the proposal to list Chinook salmon under the ESA. The implications of such a decision would be far-reaching, negatively affecting the livelihoods of thousands of Alaskans, from those who fish for a living to businesses like ours that support the industry. The economic consequences of this proposal are severe, and the regulatory burden it would place on our already struggling industry would be devastating.
It’s important to note that the Alaska State Constitution, Article VIII, specifically mandates the management of Alaska's natural resources, including its fisheries, for the maximum benefit of its people. Alaskans have a long-standing tradition of sustainably managing their fisheries, ensuring that these resources remain viable for future generations. We believe that the state of Alaska, through the Alaska Department of Fish and Game (ADFG), is best suited to continue managing Chinook salmon populations without federal intervention.
We would like to align our position with comments and concerns voiced by numerous Alaskan organizations and industry leaders. Specifically:
- Opposition to Listing Chinook Salmon Under ESA: We stand in full opposition to any attempts to list Chinook salmon in Alaska under the ESA. Like Cordova District Fishermen United, we agree with their assertion that “the ESA is not an appropriate tool to address a downturn in Chinook productivity.” We believe that existing conservation efforts through ADF&G are more effective in addressing the current situation.
- Petition Misses the Mark: As pointed out by Salmon State in their public statement on their website, this petition is an extreme measure that fails to address the actual threats to Chinook salmon populations. We agree that focusing on habitat degradation, climate change, and bycatch by industrialized bottom dragging trawl nets would be more productive than an ESA listing.
- Economic Impact on Alaska’s Fishing Families: As noted by the Alaska State Legislature’s response to this petition, listing Chinook salmon as endangered will exacerbate the challenges faced by Alaska’s fishing industry. Many of our customers, who are small business owners, guides, and independent commercial fishermen, would face significant economic hardships that could cripple their ability to continue working in this field.
- Factual Errors in the Petition: The Southeast Alaska Fishermen’s Alliance letter highlighted significant factual errors and unsupported assertions in the petition. We share their concern that the petition was accepted despite these flaws, and we question whether the petition meets ESA criteria in its current form.
- Importance of Scientific Expertise: The Alaska Department of Fish and Game’s response letter emphasized the importance of including ADF&G salmon experts in the process. We echo their request that these recognized experts be included in the Biological Review Team to ensure that the best available scientific and commercial data is used and that Alaskan voices with Alaska’s perspective are truly heard in this review process.
- Existing Conservation Efforts: The Alaska Marine Conservation Council has acknowledged in their response statement the need for conservation measures, which the ADF&G already has in place. The ADF&G has a long history of successfully managing Alaska’s fisheries and ensuring sustainable salmon populations, even in times of low abundance.
In alignment with our position, we stand alongside and support the following organizations that have expressed opposition to or have advocated for in-state management of Chinook salmon populations by submitting response letters or public statements on their websites to this petition in question:
- Alaska Charter Association
- Alaska Longline Fishermen's Association
- Alaska Marine Conservation Council
- Alaska Sportfishing Expedition
- Alaska State Legislature House Coalition
- Alaska Trollers Association
- Aleutians East Borough Assembly
- Bristol Bay Regional Seafood Development Association (BBRSDA)
- Central Council of the Tlingit & Haida Indian Tribes of Alaska
- City of Kenai
- City of Ketchikan
- City of Pelican
- City of Soldotna
- Cordova District Fishermen United
- Copper River Seafoods
- Homer Charter Association
- Ketchikan Gateway Borough
- Matanuska-Susitna Borough Fish and Wildlife Commission
- Metlakatla Indian Community Council Annette Islands Reserve
- Pacific Seafood Processors Association
- Petersburg Borough Assembly
- Petersburg Economic Development Council
- Petersburg Vessel Owners Association (PVOA)
- Purse Seine Vessel Owners Association (PSVOA)
- Representative Rebecca Himschoot
- Salmon State
- Seward Charter Association
- Southeast Alaska Fishermen's Alliance (SEAFA)
- Southeast Alaska Guides Organization
In conclusion, we believe that Alaskans are best equipped to manage our fisheries responsibly. An ESA listing of Chinook salmon is unnecessary, overly burdensome, and would harm Alaska’s economy. Instead, we urge the National Marine Fisheries Service (NMFS) to focus on addressing the actual threats to salmon populations, including bycatch in trawl fisheries, habitat degradation, and climate change.
We stand in support of the numerous organizations and businesses across Alaska who have already voiced their concerns and opposition to this petition.
Thank you for considering our perspective. We hope that NMFS will take into account the severe economic impact this decision could have on Alaskans who rely on fishing for their livelihoods, and that you will reject this misguided petition.
Sincerely,
Troy Arnold
Owner
B&J Sporting Goods, Anchorage, AK
B&J’s Tackle Repair Center, Anchorage, AK
B&J’s Tackle Box, Whittier, AK
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