Request for Support

Dear Stakeholders of Oregon’s Commercial Dungeness Crab Industry,

I am writing to you on behalf of the Oregon Dungeness Crab Commission to seek your urgent support and
assistance in addressing a critical threat to our industry. On December 11, 2025, the Oregon Fish and
Wildlife Commission received a formal petition from the Center for Biological Diversity, Oceana, Natural
Resources Defense Council, and American Cetacean Society requesting substantial modifications to
Oregon’s commercial Dungeness crab fishery regulations.

We respectfully request that stakeholders provide letters documenting the economic losses that
would result if this petition were approved rather than denied.

Background on Petition

The petition seeks to implement the following measures:

• Prohibit the use of conventional pot gear starting on April 1 each year, effective in 2028
• Mandate a 40% reduction in pot numbers and implement a 180-foot depth restriction after April 1 until 2028
• Require authorization and adoption of pop-up fishing gear technology
• Establish emergency closures for conventional gear in the event of unauthorized endangered species takes
• Require public reporting of all marine mammal or sea turtle entanglements within 48 hours

The Oregon Fish and Wildlife Commission is required by state law to respond to this petition within 90 days
by either denying it or beginning rulemaking proceedings. Public comment is currently being accepted
through February 16, 2026.

Economic Significance of Oregon’s Dungeness Crab Fishery

Oregon’s commercial Dungeness crab fishery is the state’s most valuable single-species fishery and a
cornerstone of our coastal economy. The economic data speaks for itself:

• The 2024-2025 season achieved a record-breaking $97.1 million in ex-vessel value paid to fishermen, despite catch volume challenges
• This surpassed the previous record of $91.5 million set during the 2021-2022 season
• Average ex-vessel prices reached $6.19 per pound in 2024-2025, compared to $3.79 per pound the previous season
• Oregon’s commercial fisheries collectively generated an estimated $642 million in income to the statewide economy in 2021, supporting approximately 9,200 jobs
• The Dungeness crab fishery represents a substantial portion of this economic contribution, with revenue and employment rippling throughout coastal communities

Projected Economic Losses if Petition is Approved

If the petition’s proposed measures are implemented, the economic consequences for Oregon’s
Dungeness crab fleet would be severe and far-reaching:

Direct Impacts to Fishermen

• Shortened Season: Prohibiting conventional gear after April 1 would eliminate approximately
  40% of the traditional fishing season (April through August 15). Based on recent seasons averaging
  $95+ million annually, this could result in direct revenue losses of $35-40 million per year to fishermen
• Gear Replacement Costs: Mandatory conversion to pop-up gear would require purchasing
  entirely new gear systems. With permit holders operating fleets of crab pots, the capital investment
  required per vessel could range from $50,000 to $150,000 or more – costs that many small-boat
  operators cannot afford
• Reduced Catch Efficiency: The 40% pot reduction and 180-foot depth restriction during peak
  late-season months would significantly limit catch capacity during periods when crab prices are
  typically highest
• Fleet Consolidation: Smaller vessels lack the hydraulic systems, deck space, and crew safety
  capabilities to operate pop-up gear configured in long-line pot strings. This would force many
  smaller operators out of the fishery entirely

Impacts on Processors and Shore-Side Businesses

• Processing facilities, cold storage operations, and seafood distributors rely on consistent supply throughout the season
• Shortened seasons would result in reduced processing volumes, decreased employment hours, and potential facility closures
• Shore-side businesses including fuel suppliers, gear manufacturers, vessel maintenance providers, and marine supply companies would see substantial revenue declines

Impacts on Coastal Communities

• Port communities including Newport, Charleston, Coos Bay, Brookings, Astoria, Garibaldi, Port Orford and others depend on crab fishing as primary economic drivers.
• Lost income would affect restaurants, retail establishments, lodging, and service providers throughout the coastal economy
• Tax revenues to local governments and port districts would decline significantly
• Multi-generational fishing families and businesses face potential displacement from an industry they have sustained for decades

Market and Competitive Impacts

• Reduced Oregon production would cede market share to Alaska, Canada, and other West Coast competitors
• Established buyer relationships and market access cultivated over generations could be permanently lost
• Oregon’s reputation as a reliable, high-quality Dungeness crab supplier would be compromised

Industry Response and Conservation Commitment

The Oregon Dungeness crab industry has demonstrated a longstanding commitment to conservation and
has implemented significant measures to reduce whale entanglement risks:

• Late-season buoy tagging requirements (implemented 2021)
• Twenty percent pot reduction for fishing beyond May 1
• Two hundred forty-foot depth restriction for late-season fishing
• Color-coded line identification systems to trace gear origins
• Both post-season and in-season derelict pot recovery programs
• Active participation in developing long-term solutions, including federal “take permits” that would provide regulatory certainty while protecting marine mammals

Our fishermen understand the importance of whale protection and have invested substantial time and
resources into entanglement risk reduction. However, the petition’s proposed measures go far beyond
reasonable conservation objectives and threaten the economic viability of the entire fleet.

Request for Your Support

We urgently need stakeholders to document the specific economic losses your business,
organization, or community would experience if this petition were approved.

Your letters should detail:

1. Your connection to Oregon’s commercial Dungeness crab fishery
2. Specific economic impacts your business or community would face under the proposed restrictions
3. Quantified revenue losses, job impacts, or other measurable economic consequences
4. Broader effects on supply chains, communities, or related industries
5. Any additional considerations regarding the feasibility and impact of the proposed measures

Please submit your letters to the Oregon Fish and Wildlife Commission before February 16th, 2026, public
comment deadline. You may also provide copies to the Oregon Dungeness Crab Commission to help us
compile a comprehensive economic impact assessment.

Conclusion

Oregon’s commercial Dungeness crab fishery represents more than just an industry – it is a way of life for
coastal communities and a vital economic engine for our state. While we share the conservation
community’s commitment to protecting marine mammals, the petition’s proposed measures would
devastate our fleet without providing adequate time for development of economically viable alternatives.

The substantial economic losses outlined in this letter – potentially exceeding $40-50 million annually in
direct impacts, with cascading effects throughout the coastal economy – demand fact-based information,
sound science, and comprehensive analysis while using the tools we already have on hand, including our
established rulemaking process and the expertise of our current regulatory agencies.

We respectfully urge stakeholders to document these impacts and submit comments opposing approval of
this petition. Together, we can advocate balanced solutions that protect both marine mammals and the
livelihoods of the families and communities that depend on this fishery.

Thank you for your consideration and support during this critical time for Oregon’s commercial Dungeness
crab industry. Please feel free to contact me with any questions or comments.