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Alaska Department of Fish and Game

Public Comments Submitted to the UCI Task Force
Board of Fisheries

This page contains comments from the public regarding the Board of Fisheries Upper Cook Inlet Task Force.

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Comment #33
Date Submitted: 03/04/2013 at 4:32:45 PM AKST by Dennis Randa

Kenai River Chinook salmon have been under siege since the 1980s. It appears to me this wonderful Chinook salmon nursery is being managed as a playground not a healthy fishery. In the 1990s water quality study data suggested that sensitive macro-invertebrate populations (below Soldotna bridge) were in decline while non-sensitive populations were increasing; a suggestion of urban discharge contamination. Nothing has since been done to determine the contribution to juvenile Chinook salmon well-being, even their ability to survive, that the changing macro-invertebrate populations might effect.

More and more development of the private property all along the Kenai below Skilak Lake has increased to the extent that there are few lots remaining to be developed; these properties undeniably contribute to the non-point source contaminants entering the water.

All our riparian area protection efforts will do little to protect the Kenai River water from water quality degradation; the green banks do little to preserve the natural macro-invertebrate diversity these salmon evolved to take advantage of. Water only reaches the green banks a couple of months of the year.

Since the 1990s anecdotal and df&g sonar reports indicate mostly diminishing run returns. Also, it is undeniable that the overall harvest effort has increased over the length of the Kenai below Skilak Lake. Those populations of large Chinook salmon so desired by anglers has arguably diminished over this time as well.

While fish board direction has, with df&g encouragement, undertaken to manage the river for 2 distinct returns, it remains arguable that the early main stem component of Kenai River Chinook salmon has been so over harvested (by management intention focused on protecting tributary fish) as to be virtually eliminated. When was the last time anyone saw Chinook salmon spawning behavior in late June/early July below the bridge like I used to see in the 1980s?

I would also add, that even the late run management has been mostly focused on the main stem below the Soldotna bridge, where arguably the most valuable and highest contribution of Chinook salmon reproduction takes place. This area, where most all angling effort takes place too, is being managed for human activities to the detriment of the salmon, even to the point of ignoring the needs of salmon to have areas to procreate without a constant barrage of human generated predatory behavior. There is not any main-stem sanctuary for late run fish only sanctuary for early entry tributary salmon.

I have analogized being a Chinook salmon wanting to spawn in the Kenai River a bit like arriving home after a long absence intent upon making love to one's wife while a flock of Pterodactyls attempts to rip the roof off.

While hydrocarbon introduction from boat motor exhausts has all but been eliminated (removal of 2 stroke motors) the continued sound barrage of those motors continues throughout the lower river. The impact of this pollution (sound), which in every study of stresses induced (by sound) upon those species studied has shown to have a deleterious effect upon those species exposed (to that sound); this barrage has an unknown and unstudied effect upon Kenai Chinook salmon. Is it unreasonable to assume a deleterious effect upon salmon too?

From my chair it is arguable that even if the high seas and saltwater interceptions of Chinook salmon are eliminated from the management challenges, can we be at all certain that there will be a return to those Chinook salmon numbers we experienced in the last century?

And, what are the management policy makers going to do when the Chinook salmon fail to sustain those populations, considering present management numbers, populations even capable of sustaining any harvest at all? It is historically documented that wherever we go we do not seem to be able to sustain indigenous wild populations of Chinook salmon. All that remains to those who have gone before us are hatchery generated fish.

Can we continue to manage the Kenai River as a playground and not a Chinook salmon nursery? Can we not alter our behavior, to at least give benefit of doubt, to provide a chance for this run of fish, arguably the last Giant Chinook run?

Finally, it truly confounds me that our managing agencies, parks and f&g, seem inured to these issues. How is it they can ignore anything that arguably contributes to the detriment of their charge: protect and preserve the fishery resources of the Kenai River?

Comment #31
Date Submitted: 02/22/2013 at 6:26:30 AM AKST by Don Johnson

I believe that we have a king salmon food chain failure in the ocean regarding herring. If you wish to read my full explanation you may read it at

Comment #27
Date Submitted: 02/13/2013 at 9:43:53 AM AKST by Dave Lyon

To the task force, On behalf of the Homer Fish and Game advisory council I would like to express support for the "Step down recommendations for the recreational. Marine fishery late run king salmon during periods of low abundance" submitted by Luther Anderson. We feel these are very well thought out steps to be taken by the sport user group. Should these steps be accepted as a response to low escapement, it is our position that other user groups be subject to proportionate reduction in harvest efficiency. In other words, should the sport troll fishery be expected to reduce catch by, for instance, 30%, then both set netters AND in-river sport fishers should accept similar catch reductions. That is only fair.


Dave Lyon Chair, Homer F&G Advisory committee

Comment #25
Date Submitted: 02/11/2013 at 7:08:33 PM AKST by Dwight Kramer

This week the Department came out with their 2013 LR Kenai River Chinook forecast of 29,000. While this may sound low compared to historical levels of the of the 90’s through the mid 2000’s, it is fairly consistent with recent returns and if it holds true will offer plenty of Kings for all fisheries to operate in fairly normal fashion.

With historical harvest levels, by all user groups, of 39% of the total run it would generate a harvest of around 11,000 and an escapement of around 18,000, which would be well into the escapement goal range. While this isn’t ideally around the MSY of 20,000 it is close and should be about what we would expect during a medium to low total return. Remember, salmon by nature are resilient in that they come back over a period of brood years as is illustrated in the peaks and valleys of return cycles.

With this level of available harvest everyone should be able to fish without much restriction. The sport fishery should operate fairly normal unless a bait restriction might be in place at the beginning of the season if the ER comes in weak. The ESSN fishery should operate fairly normal with ample opportunity to harvest across the red run without disrupting the King return beyond historically appropriate levels and the PU King harvest and Marine harvest should be normal as well.

This is how the numbers break out at historical levels;

In-river sport 6,300 ESSN 3,700 Marine Sport 600 Drift Gillnet 435 PU 232

Word of caution…. With this return level fishing just won’t be great but, it should grant all us enough opportunity to be able to participate fully and still meet our escapement goals.

Comment #24
Date Submitted: 02/11/2013 at 8:18:17 AM AKST by Todd Smith

I am encouraged by the new escapement goal report provided by ADFG and the data within. It has provided a framework to focus the discussion within the mission statement of the task force. That is, how to find the best mix of fishing opportunity for all users during times of low abundance of Kenai River late run king salmon, which, while in a period of low productivity, are NOT a conservation concern. Given this, it is important to remember that the discussions we are having and the risks involved are largely that of yield and tradeoffs between stocks.

While there are many theories and much speculation of exactly what elements of the marine environment are affecting King productivity, one area were no longer have to speculate is in our river where the data provided by ADFG paints a clear picture. I think that if we stick to what we know it enables us to come to the most sensible conclusions.

We know that we have never missed the lower end of the newly recommended LRK escapement goal. We know that we have exceeded that goal 15 of the last 27 years, and that the only 4 brood stocks that have not successfully replaced themselves are recent years of record high escapements. We have exceeded the MSY escapement level of 20,000 fish for 26 of the last 27 years. While low ocean productivity is likely a large factor, we know that past seasons of large escapements are also contributing to recent low returns. We know that ADFG has made an unofficial policy statement that they put more emphasis on achieving the bottom end of one escapement goal over the top end of another, and that the overwhelming trend in the Kenai river for all stocks has been near the top end of escapement goals.

Given that all user groups have suffered severe restrictions recently, and that the mission of this task force is to find solutions that provide fishing opportunity for all user groups while still attaining the escapement goals, why have some task force members provided plans that seek to restrict all fisheries further when escapements are expected to be inside the goal and even above MSY? In a time when we have flirted with the upper escapement goals of many local stocks of salmon due to Kenai King related restrictions, why would anyone seek to further exacerbate this issue by stockpiling fish in the river at the expense of all user groups? Given that Mr. Delaney's plan still seeks to minimize ESSN King harvest even at escapement levels above 30,000, and in fact only liberalizes the inriver fishery, this plan seeks to further the trend of large escapements in the face of data that clearly shows a decrease in productivity at high escapement levels. Is it the purpose of this task force to deliberate on allocative measures related to Kings? Shouldn't that argument be reserved for regular Board process?

As Mr. Kramer stated, all user groups have endured heavy restrictions during the last two seasons, only to learn afterwards that there were enough KRLR Kings to achieve escapement goals and provide a harvestable surplus. ADFG states that the new king goal has a built-in buffer at the lower end of the escapement range. When a river system has year after year of high levels of escapement, it also has a built in buffer for occasional years of lower escapement. ADFG data shows that yields at escapement levels of 11-13,000 kings are similar to and even greater than yields at escapement levels of 30,000.

Management options for times of high abundance can be deliberated during regular board process. In the interim, providing a small, scientifically defensible means for harvest for all user groups in times of low abundance is the most reasonable action to take, and is in keeping with the mission of this task force.

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