February 12, 2013
Tuesday PM

Dear Editor,

At its Statewide Finfish meeting in March, the Board of Fish (BoF) will consider the Board generated Proposal 243, which would add Pacific herring (Clupea pallasii) to the State’s Forage Fish Management Plan (FFMP).  Pacific herring are currently the only forage fish species that is commercially harvested in the State of Alaska.  The State fails to acknowledge herring as a forage fish by not specifically listing them in its FFMP, however, the FFMP does list exemptions for all existing herring fisheries.

Biologists, fishery managers and governments around the world acknowledge herring as a forage fish.  The federal government acknowledges their importance by listing them as a prohibited species in the Gulf of Alaska and Bering Sea trawl fisheries.  Herring also meet the role of a forage fish as defined by the BoF in the FFMP (5 AAC 39.212 (d)):

“The board finds that forage fish perform a critical role in the complex marine ecosystem by providing the transfer of energy from the primary and secondary producers to higher trophic levels. The higher trophic levels include many commercially important fish and shellfish species. Forage fish also serve as important prey species for marine mammals and seabirds.”

There are some who have the misconception that this listing will shut down the various herring fisheries within the State.  This is not the case.  As stated above, the current FFMP lists exemptions for all the herring fisheries in Alaska (5 AAC 03 - 5 AAC 39).  Proposal 243 does not remove these exemptions it merely lists Pacific herring as a forage fish.  At the October 10, 2012 Board of Fish meeting in Anchorage, ADF&G Regional Supervisor Scott Kelly testified that adding herring to the State’s FFMP would not change the way the State manages the herring fisheries.

Listing Pacific herring on the FFMP will require fisheries managers to acknowledge herring as a forage fish and is the first step towards a more conservative management approach that prioritizes the needs of the marine ecosystem.  Commercial (longline, troll, seine, etc.), sport, personal use, and subsistence fishers along with non-consumptive users would all benefit from more conservative management of this keystone species.

I encourage you to write a letter to the BoF in support of Proposal 243, which can be mailed or faxed to the address or number below.  You also have the option to completing an on line petition at http://www.thepetitionsite.com/492/125/552/add-pacific-herring-to-alaskas-forage-fish-management-plan/ , which will be submitted to the BoF.  Written comments should be submitted to the BoF by March 5, 2013.

Sincerely,

Jeff Feldpausch
Resource Protection Director
Sitka Tribe of Alaska
Sitka, AK

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