Battle Roy Al: March 3, 2008

The head of my fishing partner, along with my own
melon, hurt from pounding it against the brick wall
that is the State of Alaska DEC.

We’ve sent letters to the DEC, the governor’s office,
and our legislators asking for development of
appropriate regulations for what we’d like to do –
which dress (gut and gill) salmon at sea. Current law
is an amazing mess of regulations that differ not
based on what is being done (e.g., dressing salmon),
but by what business is doing it. A fishermen who is
going to deliver his catch to a processor can dress
fish all day, as much as he wants, with no permit
whatsoever. A fishermen who wants to sell his catch
directly from his boat has another set of rules to
follow for dressing fish. If you don’t catch the
fish, but buy them from a fishermen and dress the
salmon right next to his boat, yet a third set of
regulations apply!

We’ve attempted, to no avail, to get our DEC to
address what we want to do with appropriate
regulations that will provide for sanitary cleaning
surfaces and knives, a chlorinated rinse of the fish
after dressing, and protection necessary to keep rain
or birds from the processing area.

If we were catching the fish ourselves, we could clean
the fish with sea water, put them in a chlorinated
batch rinse as a final sanitizer, then ice them. Some
sort of cover overhead would keep rain out and stop
any birds, etc. from dropping any presents. This is a
great system that I’ve used, without a permit, and our
track record of quality speaks for itself – as it does
for our partner, who does have what’s called a “direct
marketers” license. Obviously, these systems fit the
smaller sized fishing boats that process relatively
small volumes of fish (a few thousand pounds) per day.

However, for us to do EXACTLY the same thing on a
small boat, with the ONLY difference being we did not
catch the fish, our DEC maintains we must have the
equipment required for a full-blown catcher processor.
We’d need a chlorine injection system, rather than a
chlorine bath, and be required to send water samples
in monthly for testing. This, in and of itself, is
not an insurmountable requirement – but still, why
make this different for what we want to do versus what
a fishing boats does? Isn’t the point to have the
fish rinsed in clean water? We’d love to see a test
of our fish versus that from a shore-based processor
on city water to see which fish had higher bacteria
counts. DEC said the regulations for fishing boats
were different because the volume of fish processed
was lower- to which we have and continue to offer
we’ll accept a volume limit on what we can do. One or
two people on a boat can only process a few thousand
pounds of fish a day – regardless of whether they also
catch the fish or not. Particularly if you’re doing
the careful cleaning that we are.

Back to the requirements – the real stickler – and
most innapropriate requirement is we must have a fully
enlclosed, lighted room on the boat to dress the fish.
DEC indicated it’s to protect against “Dust and
Pests”. When we asked where all this dust and pests
were going to come from out on the fishing grounds
(we’re in the middle of a friggin’ rainforest – dust
and pests ain’t a big problem), DEC told us floating
processors COULD tie up to a dock, so that could be
where all this dust and these pests might get on the
fish. To which we replied – we’re fully willing to be
restricted to dressing fish out on the fishing grounds
and have no intention of tying up to any dock to

After these offerings, we were told DEC believes that
“fishermen fish and processors process”, which really
is nonsensical with regard to food safety. Again, how
can 2 vessels doing exactly the same thing in the same
place at the same time need different requirements for
cleaning fish???

Finally, after the DEC official had disconnected the
conference call and we were getting ready to leave,
she remarked “what would the other processors say if
we did this?”

Finally – a reason that makes sense. They shy away
from working with us to come up with an appropriate
way to make the best fish that will be available
anywhere because of what the larger processors would
say. These are the processors who get their fish
delivered to their plants in the round – and in some
places, not even fully chilled – after the fish first
have been transferred at least once from a tender
vessel (which collects fish from several boats), and
then dress these fish (many times days after they were
caught), freeze them as whole dressed fish, and ship
them to China for “reprocessing”, i.e, filleting,
vacuum packing, etc. These fish are then shipped back
to them as processed fish and then enter the US

Our fish are dressed right after they are caught,
taken to town, and then further processed (filleted
and vacuum packed) by local workers, then held here
until shipment. We essentially squeeze every dollar
out to the local economy before it goes anywhere. Why
DEC would want to restrict that for no justifiable
reason is beyond all of us.

Likely the biggest help we’re going to get is by our
own customers writing their legislators and/or our
governor, asking them to get after it and help us.
Legislation is our last hope now, since we’ve
exhausted everything we know of through the current
statues and through the governor’s office (who chose
not to help us), that this is our last effort. We’ll
see what happens. This could really lead to help alot
of areas in the state – DEC said we were not the first
one’s to come to them with this request (so
apparently, they’re used to just saying no because
they can, and not for any reason).

Sometimes, the way government works, people who you
can’t remove or can’t otherwise change have power that
seems to come from nowhere, but which you can’t
address. If they had real reasons for denying us,
that would be okay. But to deny us with no real
scientific or public health reason, is what’s must
infuriating. Their plan is public health through
restriction of who can conduct trade, rather than
working as public servants who should work with their
constituents to find appropriate solutions to make
this work.

Mark Stopha and Sara Hannan
Alaska Wild Salmon Company
Wild Salmon and Salmon Pet Treats
4455 N. Douglas Hwy
Juneau, AK 99801

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