April 30, Mr. Steve Devitt Moody Marine, Ltd. 28 Fleming Drive Halifax, Nova Scotia B3P1A9, Canada

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1 April 30, 2011 Mr. Steve Devitt Moody Marine, Ltd. 28 Fleming Drive Halifax, Nova Scotia B3P1A9, Canada Re: Alaska Salmon Fisheries Fourth Annual Surveillance Audit Dear Mr. Devitt: Thank you for the opportunity to contribute to the Alaska salmon fisheries annual surveillance audit. Below we present input on several general and region-specific issues that we believe Moody should carefully consider in its review. Status of Conditions A total of 70 conditions were placed on the Alaska salmon fisheries when they were re-certified by MSC in 2007 (SCS 2007). After completion of the third annual surveillance audit (MML 2011), 49 of the 70 conditions had been closed out. Of the remaining 21 conditions, 8 are scheduled to be closed during the fourth annual surveillance audit and 13 will likely remain and possibly not be closed out during the period of this certification. We note that since the last surveillance audit, MSC has provided specific directions to certification bodies regarding treatment of conditions that are behind target or will be unmet during annual surveillance audits and re-certification (see TAB D-033 v1). We are interested in understanding your intent in dealing with conditions in these categories in the context of this TAB directive, including its revisions to specific sections of MSC s Fisheries Certification Methodology. Enhanced Stocks State of the Salmon (SoS) is concerned about the potential negative impacts of Alaska s hatchery programs on the sustainable production of wild salmon in several certification units. Alaska is the second largest hatchery producer of salmon in the North Pacific (Irvine et al 2009), second only to Japan. Pink salmon accounted for 55%, and chum salmon 38% of the 1.49 billion juvenile hatchery salmon released in Alaska during In 2010, Prince William Sound hatcheries released 76% of the pink salmon in Alaska. In contrast, 75% of the hatchery chum salmon released in the state originated from Southeast (MTA 2011). Kodiak hatcheries accounted for 17% of the pink salmon and 4% of the chum salmon released in Alaska in Southeast and Prince William Sound ADF&G has been conducting studies to estimate the magnitude of hatchery straying into natural spawning areas in an effort to address conditions for continued certification. As noted in the most recent audit report Preliminary results indicate that hatchery produced fish are straying into

2 some wild spawning areas in Southeast Alaska and Prince William Sound (MML 2011). Studies conducted in Southeast Alaska in 2009 indicated that spawning streams within 50 km (water distance) of hatchery release sites had high proportions of hatchery chum salmon. Because of the number and location of hatchery release sites, this information suggests that hatchery chum salmon comprise a high proportion of the summer chum salmon spawning in many streams in Southeast, including many of those used to monitor wild spawning escapements (Figure 1). Figure 1. Location of wild summer chum salmon spawning index streams relative to hatchery release sites in Southeast Alaska. The orange shaded area represents streams within a 50 km distance of release sites. A 2009 ADF&G study found high proportions of hatchery-origin chum salmon in spawning streams within 50 km of release sites. Figure taken from Kelley and Frenette Similarly, results of ADF&G monitoring of pink salmon in Prince William Sound have documented high proportions of hatchery-origin pink salmon spawning in natural spawning streams near hatcheries and along migration corridors (Sharp et al. 1994, Joyce and Evans 2000, Brenner et al. 2010). Besides the significant spatial extent of straying in this region and proportions of hatchery fish in natural spawning areas, Prince William Sound otolith analysis has further highlighted the extremely low contribution of natural origin fish to the hatchery brood stock (Regnart and Hasbrouck 2010). This circumstance magnifies the likely adverse impacts of hatchery fish straying with respect to the diversity, local adaptation and productivity of the system s wild pink spawners given the likelihood that several decades of Prince William Sound hatchery broodstock have been isolated from any natural selection pressures for a major portion State of the Salmon Alaska Salmon Fourth Annual Surveillance Audit Page 2

3 of the reproduction process (e.g., nest building, mate selection, spawning and incubation in the natural environment). While questions of adverse impacts of large hatchery programs in these two certification units were raised at reassessment by the certifier, there was some uncertainty regarding the magnitude and spatial extent of straying for Southeast hatchery chum and Prince William Sound hatchery pink salmon. Conditions were raised presumably to verify whether the 60 and 80 scoring guideposts for key performance indicators (e.g., , and ) for these certification units had in fact been met. While the related conditions are still open, there seems to be sufficient new evidence for the surveillance team to reconsider the original scores for these indicators with respect to meeting specific elements of the 60 and 80 scoring guideposts. In addition, there has been mounting pressure to increase hatchery production in these regions despite increasing evidence of hatchery straying into Southeast and Prince William Sound spawning streams and the likely adverse impacts on wild stocks. In response to Permit Alteration Requests (PARs) to increase hatchery production, ADF&G permitted additional hatchery chum salmon production by 39 million in Southeast and 17.4 million in Prince William Sound in PARs to increase hatchery pink salmon production in Prince William Sound by 103 million were denied by the ADF&G Commissioner in However, these PARs were resubmitted again this year, along with those to increase chum salmon production in Southeast. We recommend that the surveillance team acquire all available information, technical review and decisions regarding the PARs from ADF&G. We strongly concur with the two issues identified by Moody in the third annual audit report that the client needs to address: The first issue is to ensure that the spawning escapement goal is based on escapement levels of wild salmon that lead to sustained, potentially abundant returns of wild salmon in a manner that preserves fitness of the wild salmon stock. Development of wild salmon escapement goals in a fishery that includes numerous hatchery salmon in a mixed stock fishery and strays in the spawning escapement can confound quantitative development of escapement goals for wild salmon. The second issue is to minimize straying of hatchery fish. Methods or approaches that might accomplish this include: 1) high harvest rates on hatchery stocks in terminal areas where few wild salmon occur, 2) improved imprinting of juveniles to the terminal harvest area, 3) reduced remote releases that might enhance straying, and 4) restricting hatchery production to levels that ensure adequate escapement of wild salmon to streams with minimal hatchery fish. We also agree with Moody s recommendation in its last audit report that an expert review of the issues associated with hatchery production, straying, genetics and fitness of wild salmon stocks in Alaska, similar to that carried out in the Pacific Northwest under the Hatchery Science Reform Group (HSRG) would be useful for defining and implementing actions needed to meet performance requirements and conditions for certification. The review would additionally benefit from the participation of experts from both within and outside of Alaska. These issues are correctly directed toward minimizing negative impacts of hatchery production on wild salmon populations. There were two bullet points that had to be met to achieve the 80 State of the Salmon Alaska Salmon Fourth Annual Surveillance Audit Page 3

4 Scoring Guidepost under Indicator when Alaska salmon fisheries were re-certified (SCS 2007): In fisheries where both enhanced and wild (un-enhanced) stocks are harvested at the same time, the harvest guidelines are based on the goals and objectives established for the wild (un-enhanced) stocks, and there is sufficient information on stock composition (i.e. hatchery and natural fish) to determine whether those goals are met. There are adequate data and analyses to determine that the presence of enhanced fish in the management units does not adversely impact the wild (un-enhanced) fish stocks. The certifier clearly established a burden of proof for the client fishery to demonstrate that enhanced fish are not impacting wild stocks. It appears timely for Moody to reassess new information and evidence regarding the scoring of relevant indicators. This review also should consider that ADF&G recently established escapement goals for three aggregate stocks wild chum salmon in Southeast Alaska (Eggers and Heinl 2008). The level of hatchery straying likely results in an over-estimate of the wild spawning escapement to some areas. This is disturbing considering that two of the three stocks were below the escapement goal in 2008, and all three were below in 2009 (Kelley and Frenette 2010). Kodiak Region During the reassessment Kodiak commercial fisheries received a score of 90 for performance indicator : Enhanced Stocks. The reassessment report stated Most hatchery salmon are released into areas where few wild salmon exist, e.g., Kitoi Bay. This allows the large majority of hatchery salmon to be harvested separately from wild stocks. Hatchery salmon are typically not marked, but marks are not needed for fish taken in the terminal harvest areas. However, performance indicator : Reliable estimates of escapement received a score of 75 and the report stated Although stray studies have not been conducted on pink and chum salmon in Kitoi Bay, ADFG believes its approach to hatchery management has greatly limited straying to streams. While this seems logical given the isolated harvest area and high harvest rate, it would be worthwhile to confirm this belief. Straying studies conducted in Southeast and Prince William Sound shed new light regarding management of hatchery pink and chum salmon in the Kodiak Area. The Kitoi Hatchery released 20.8 million chum and 144 million pink salmon fry in 2010 (MTA lab 2011). These releases were not marked (which conflicts with information used to close condition 66 suggesting that all hatchery production are marked). Because these fish were not marked, there have not been any studies to evaluate hatchery stray rates in the Kodiak Region. However, if we assume that hatchery straying may in fact be high within 50 km of the hatchery release site (as documented for chum in Southeast), it logically challenges the reassessment assumption that the special harvest area designated to harvest hatchery fish in Kitoi Bay is sufficient to limit straying to spawning streams in the area (Figure 2). This new information not only raises questions about the original scoring of performance indicator and rescoring of (condition 66) but it has relevance to closing remaining conditions 54 and 55 (to evaluate status of Kodiak chum salmon). The Kodiak Archipelago chum salmon aggregate stock includes a number of streams on Afognak Island (Nemeth et al. 2010) State of the Salmon Alaska Salmon Fourth Annual Surveillance Audit Page 4

5 Figure 2. The Kodiak Management Area showing hatchery locations (red circles) and the Kitoi Bay special harvest area (SHA). A 50 km circle is drawn around the Kitoi hatchery for reference. that are within 50 km of Kitoi Hatchery. If significant straying is occurring into streams used to monitor escapement, this could mask declines in wild salmon productivity. State of the Salmon Alaska Salmon Fourth Annual Surveillance Audit Page 5

6 As in Southeast and Prince William Sound, there is mounting pressure to increase hatchery production in the Kodiak Region. The public review draft of the Kodiak comprehensive salmon plan released in December 2010 called for dramatic increases in hatchery production for all salmon species in the Kodiak Management Area over the next 30 years requiring the construction of at least one new hatchery. Despite a lack of clear local support for increasing production for pink and chum salmon, the plan proposes to increase adult harvests by approximately 10.9 million even-year and 6.2 million odd-year pink salmon, and 1.3 million chum salmon by 2030 (KRPT 2010). Conclusion We highlight the following points: Moody should carefully consider management of behind target and unmet conditions with respect to TAB Directive D-033 and related provisions of MSC s Fishery Certification methodology. New information and evidence collected since reassessment, as well as new plans or actions by the management system to significantly increase hatchery production in the Southeast, Prince William Sound and Kodiak certification units, would seem to represent significant changes in the fishery since reassessment and warrant Moody to review relevant performance indicators with respect to meeting specific elements of the 60 and 80 scoring guideposts. The available information suggests that hatchery fish are straying into natural spawning streams at unacceptable levels in the certification units discussed above. It seems clear that new management actions, as recommended by Moody in the last audit report (and referenced above), rather than additional studies, are needed to meet performance requirements and conditions of certification with respect to: (1) ensuring that spawning escapement goals are based on and met with wild salmon; and (2) significantly reducing the spatial distribution and proportions of hatchery fish spawning naturally to minimize their adverse impacts on wild salmon stocks. Thanks again for the opportunity to provide information to the surveillance team. We look forward to reviewing the results of your surveillance audit and supporting documents. Sincerely, Randy Ericksen, Salmon Management Specialist State of the Salmon rericksen@wildsalmoncenter.org State of the Salmon Alaska Salmon Fourth Annual Surveillance Audit Page 6

7 References Brenner, R.E., A. Piston, S. Moffitt and S. Heinl Hatchery salmon straying studies: Prince William Sound & Southeast, Alaska. Presentation at the Ecological Interactions between Wild & Hatchery Salmon Conference, Portland Oregon. Eggers, D. M., and S. C. Heinl Chum salmon stock status and escapement goals in Southeast Alaska. Alaska Department of Fish and Game, Special Publication No , Anchorage. Available at Irvine, J.R., M. Fukuwaka, T. Kaga, J.H. Park, K.B. Seong, S. Kang, V. Karpenko, N. Klovach, H. Bartlett, and E. Volk Pacific salmon status and abundance trends. NPAFC Doc. 1199, Rev pp. Available at Joyce, T.L., and D.G. Evans Otolith marking of pink salmon in Prince William Sound salmon hatcheries. Exxon Valdez Oil Spill Restoration Project Final Report (Restoration Project 99 1 SS). Alaska Department of Fish and Game, Division of Commercial Fisheries, Cordova and Anchorage, Alaska. Kelley, S. and B. Frenette Southeast Alaska chum salmon permit alteration requests. Memo from Region I ADF&G Regional Supervisors to Division Directors dated April 2, pp. Kodiak Regional Planning Team (KRPT) Kodiak comprehensive salmon plan: Phase III Public Review Draft. Available at Mark, Tag, and Aging Laboratory (MTA lab) Alaska Department of Fish and Game online hatchery release report. Available at Accessed March 2, Moody Marine Ltd (MML) Third Marine Stewardship Council annual surveillance report Alaska salmon. Annual Surveillance Report. Available at Nemeth, M. J., M. J. Witteveen, M. B. Foster, H. Finkle, J. W. Erickson, J. S. Schmidt, S. J. Fleischman, and D. Tracy Review of escapement goals in 2010 for salmon stocks in the Kodiak Management Area, Alaska. Alaska Department of Fish and Game, Fishery Manuscript Series No , Anchorage. Regnart, J. and J. Hasbrouck Prince William Sound permit alteration requests. Memo from Region II ADF&G Regional Supervisors to Division Directors dated April 19, pp. Scientific Certification Systems, Inc. (SCS) The commercial Alaska salmon fisheries managed by the Alaska Department of Fish and Game: A 5-year re-assessment based on the Marine Stewardship Council program. Public Certification Report. Available at Sharp, D., S. Sharr, and C. Peckham Homing and straying patterns of coded wire tagged pink salmon in Prince William Sound. Proceedings of the 16th Northeast Pacific pink & chum salmon workshop, Juneau, Alaska, February 24-26, P State of the Salmon Alaska Salmon Fourth Annual Surveillance Audit Page 7