To: Mr. Eugenio Piñeiro Soler, Administrator, NOAA Fisheries
Mr. Phil Anderson, Pacific Salmon Commission Chair
Mr. Ron Allen, Pacific Salmon Commissioner
Mr. Douglas S. Vincent-Lang, Pacific Salmon Commissioner
Cc: Ms. Jennifer Quan, West Coast Regional Administrator, NOAA Fisheries
Mr. Jon Kurland, Alaska Regional Administrator, NOAA Fisheries
Re: Requiring Counting and Reporting of Steelhead Incidentally Caught in Fisheries Subject to the Pacific Salmon Treaty
Dear Administrators and Commissioners:
We, the undersigned businesses, organizations, and individuals, write to urge the United States Section of the Pacific Salmon Commission to obtain, in the current round of Pacific Salmon Treaty (PST or Treaty) negotiations scheduled to conclude in late 2027, a requirement that all steelhead incidentally caught in PST-governed fisheries be counted and reported.
Steelhead are defined as “salmon” under the PST. 16 U.S.C § 3631. Article IX of the PST states: “In fulfilling their functions, the Panels and Commission shall take into account the conservation of steelhead.” This is a laudable statement of principle, but it is practically meaningless because there is no requirement that participants in PST-regulated fisheries count and report steelhead that they incidentally catch. To state the obvious, we can’t conserve steelhead if we are not accounting for their catch; we can’t manage what we don’t understand.
The fact that steelhead are not targeted in commercial marine salmon fisheries does not mean they are not impacted by those fisheries. Recent sampling in the North Pacific using eDNA confirms that steelhead are often present in significant numbers in the same waters as coho, sockeye, and pink salmon https://doi.org/10.1093/icesjms/fsaf104, which are targeted in PST-regulated commercial net fisheries. Climate-driven shifts in ocean conditions may be making steelhead more susceptible to incidental catch in PST fisheries. Summer-run steelhead populations, which aggregate near the mouths of their natal rivers before beginning their upstream spawning migrations in the spring and summer, may be particularly susceptible to being caught in PST-regulated fisheries. In Puget Sound river systems, summer-run steelhead are in dire straits and once-popular sport fisheries no longer exist.
The bottom line is this: we don’t know the frequency and magnitude of incidental steelhead catch in PST fisheries because it is not being recorded and reported.
Sadly, despite large public investments to restore steelhead and salmon freshwater habitat in Washington, Oregon, and Idaho over the past 30 years, many U.S. steelhead populations continue to struggle, resulting in fishing season closures and shortened seasons. Eleven “distinct population segments” of steelhead—including those in the Columbia and Snake river basins, the upper Willamette River and Puget Sound—are protected under the Endangered Species Act (e.g., Puget Sound, interior Columbia, and Snake River). Even steelhead populations in rivers on the remote western Olympic Peninsula of Washington, which were previously considered relatively abundant, were recently found to be in long-term decline. 91 FR 1449 (2026). This does not bode well for the fish or the people and businesses who depend on and value them for both their intrinsic and economic value, including the signatories of this letter.
Steelhead support recreational fisheries of significant and distinct economic value in coastal and river communities across Alaska, Washington, Oregon, and Idaho, fisheries that depend on abundant, healthy steelhead populations. In Alaska, fishing for steelhead draws anglers to rivers throughout Southeast Alaska, Southcentral Alaska, Kodiak Island, and even the Aleutians. In Washington and Oregon, steelhead draw anglers to coastal, Puget Sound, and interior rivers in the Columbia River Basin. In Idaho, steelhead anglers eagerly await the fall when they can fish rivers in the Snake River system, including the Salmon River.
These steelhead sport fisheries support myriad small businesses in rural communities that are struggling economically, including guides and outfitters, tackle shops, hotels and lodges, grocery and convenience stores, gas stations, convenience stores, restaurants, and shuttle services. There is a surprising lack of detailed quantitative analysis of the economic impacts of steelhead sportfishing to local and regional economies in the U.S.—a data gap that needs to be filled—but the quantitative analyses that have been done substantiate the high value of steelhead fisheries to local and regional economies. (e.g., Economic Survey of Recreational Steelhead Fishers in Washington: Methodology and Survey Results. U.S. Department of Commerce, NOAA Technical Memorandum NMFS-NWFSC-167. https://doi.org/10.25923/gn14-f110). A robust economic analysis that was just released reveals the major positive economic impact of steelhead sportfishing in British Columbia’s Skeena River basin, and there is no reason that similar benefits, scaled to the size and duration of the fishery, would not materialize in the U.S. if there were consistent sportfishing seasons. The take-home point is that when steelhead populations are well managed and healthy enough to support fisheries, many Alaska and the Pacific Northwest communities, businesses, and anglers benefit.
It bears emphasis that requiring the counting and reporting of incidental steelhead catch in PST fisheries will help you meet your obligations under the General Standard set forth in the Pacific Salmon Treaty Act. 16 U.S.C. §3638. The General Standard requires application of the best available science, and the fact that science can’t be effectively applied in the absence of data needs no further explanation. The General Standard also requires that you align your decisions with other relevant federal law, including the Magnuson-Stevens Fishery Management Act (MSA). National Standard 8 of the MSA requires that federal fishery managers, while giving primacy to conservation, seek to sustain fishing-dependent businesses and communities—including Tribal communities—and minimize adverse impacts. In addition, National Standard 9 requires minimizing bycatch of and harm to non-target species. 16 U.S.C. §1851(a)(8),(9).
Thank you for considering our interests and concerns, and for your service in advancing fisheries policy, which is a challenging role. Steelhead-dependent communities, businesses, and anglers that benefit from and value steelhead are counting on your leadership. We will be watching intently for a revised Pacific Salmon Treaty that includes a steelhead counting and reporting requirement, which is essential to enabling Pacific Salmon Commissioners in both countries to meaningfully consider steelhead conservation, as Article IX of the Treaty requires, and take appropriate conservation actions.
Respectfully,