Dear Congressional Delegates,
Territorial Sportsmen Inc is a Juneau based sportsmen organization. We are writing to urge you to support the “Steps to Reform”
regarding the Marine Mammal Protection Act, as listed here:
https://www.adfg.alaska.gov/…/092325_marine_mammal_prot…
We are aware that sea otters are decimating crab and shellfish populations south of Juneau and are concerned that if no action is taken the same fate will befall the Juneau area as well. For dungeness crab, the Juneau area, including Stephens Passage has experienced a massive increase in commercial crabbing as commercial fishermen relocate away from their traditional areas to the Juneau area in an attempt to find grounds not barren of dungeness crab due to sea otter predation. We do not begrudge commercial fishermen in their attempt to make a living, but it is frustrating for locals to not be able to access the resource as nearly every possible dungeness crab habitat is being intensely fished by commercial fishermen.
If sea otters were to become established in the Juneau area, based on experiences in other areas of southeast, both personal use and commercial dungeness crab fisheries would likely cease to exist. For king crab, the Juneau area is the most productive ground in Southeast Alaska. The area hosts an extremely popular personal use king crab fishery, as it is one of the only areas that personal use fishermen are reliably able to catch king crab (when open). Furthermore, because ADFG uses a survey method to determine king crab stocks, the Juneau area is very important to the commercial king crab fishery. If sea otters were to become established in the Juneau area without proper management — and they have been sighted increasingly close to town — the results would likely be disastrous for both the local personal use fishery as well as the region wide king crab fishery.
For reference, please see below the “Steps to Reform” from the ADFG document:
https://www.adfg.alaska.gov/…/092325_marine_mammal_prot…
1. Re-define “optimum sustainable population” (OSP). The OSP calculation should reflect modern human use and cohabitation, including the need to sustain harvestable surpluses for subsistence use. ADF&G recommends revising the definition of OSP1 to be “the number of animals necessary to support the continued survival and sustainable uses of the population or the species, while maintaining ecological balance within the current environment.”
2. Remove inappropriate constraints on who can participate in subsistence harvests.
3. Establish statutory standards for data adequacy and assumptions in MMPA implementation. Require objective, robust data collection and analysis before imposing restrictions on nature resource use.
4. Align calculation of “potential biological removal” (PBR) with the sustained yield principle. Marine mammal conservation should be balanced with the responsible use of other natural resources.
5. Exempt re-introduced species. Re-introduced species, such as sea otters in Southeast Alaska, should be exempted from the MMPA.
6. Promote management under the sustained yield principle. The MMPA’s “minimum population size” metric unnecessarily constrains activities. Instead, management should be based on the “best population size,” to support marine mammal productivity, preserve subsistence use, and benefit ecosystem health.
7. Authorize intentional take of marine mammals. States should be able to authorize the intentional take of marine mammals within a sustained yield framework, especially when marine mammals are affecting fisheries, ESA-listed species, or ecosystem health.
8. Remove statutory cross-references between the ESA and MMPA. Overlapping regulatory program create confusion, redundancy, reduce regulatory certainty, and complicate permitting.
Regards
Territorial Sportsmen & Alaska Outdoor Council