December 8, 2008
Ms. Kaja Brix
Assistant Regional Administrator
Protected Resources Division, Alaska Region, NMFS
PO Box 21668
Juneau, AK 99802
Attn: Ellen Sebastian
Re: Initiation of Status Review for the Southeast Alaska population of Pacific Herring
Dear Ms. Brix:
Thank you for the opportunity to submit comments on the Status Review of the Southeast Population of Pacific herring under the Endangered Species Act (ESA).
The Resource Development Council (RDC) is a statewide private economic development organization with the mission to grow Alaska’s economy through responsible resource development. RDC’s membership encompasses all of Alaska’s basic industries — oil and gas, tourism, fisheries, mining and timber. Our membership also includes construction companies, labor organizations, Native corporations, local communities and a wide variety of industry support firms.
In accordance with an ESA listing petition, the National Marine Fisheries Service (NMFS) previously conducted a status review of the Lynn Canal stock of Pacific herring, upon which NMFS concluded that population is not a distinct population segment (DPS) under the Act. The review did, however, find the Southeast Alaska herring population, under which the Lynn Canal stock belongs to, to be a DPS and is therefore conducting a status review for that population.
Upon conclusion of this status review, NMFS will determine whether to list the Southeast Alaska population of Pacific herring on the ESA. RDC opposes that listing, and strongly questions the notion of the Southeast Alaska stock being a Distinct Population Segment (DPS) separate from herring in the Gulf of Alaska and the northern Pacific Ocean. As indicated in the Lynn Canal Federal Register notice dated December 10, 2007, Pacific herring stocks in Southeast Alaska have not been examined in detail for population discreteness. However, studies conducted on herring stocks in the North Pacific, e.g. Puget Sound, have concluded the stocks do not constitute a DPS as defined under
the ESA. Similar studies must be conducted in all of Southeast Alaska prior to a listing decision. When making DPS determinations, the discreteness of the population in question and the significance of the population to the remainder of the species should be considered.
The Commercial Fisheries Division of the Alaska Department of Fish and Game (ADF&G) manages the Southeast Pacific herring population exceedingly well. The populations are reviewed annually and harvesting decisions are based on these population assessments. In the past, the herring fishery has been closed when it is discovered populations are depressed and remain closed until it is proven the population can support commercial fisheries. In 2007 the ADF&G stated that overall herring stocks in Southeast Alaska are stable and healthy.
RDC is concerned about the impact an ESA listing and subsequent critical habitat designation could have on development projects in and around Southeast Alaska. The Kensington Mine, poised to provide millions of tax dollars to the City and Borough of Juneau, as well as the State of Alaska, would be directly impacted. Given its location, shipping and transportation to and from the mine would be hampered, and even the most basic mining operations would prove to be incredibly difficult. Also affected in the area would be the Kensington Mine dock facility owned by Goldbelt Inc., and the existing Greens Creek Mine on Admiralty Island. All of these projects have been planned and permitted while working with local, state, and federal government agencies to ensure the region is protected and preserved for the future. RDC surmises the petitioners may be attempting to list the Southeast Alaska Pacific herring stock under the ESA to control land use decisions, rather than because the stock is threatened. The ESA is not meant to control development activities, but rather to preserve species that are truly threatened or endangered.
Anytime a species is listed under the ESA, that decision must be based on sound science and recognize existing conservation efforts, management mechanisms, and actual population assessments. An ESA listing should be a last resort, and not a foregone conclusion. Given the Southeast herring population as a whole is healthy and able to support a commercial fishery, a listing under the ESA is not warranted at this time.
Thank you for the opportunity to comment on this important issue.
Sincerely,
Resource Development Council for Alaska, Inc.
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