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.
Displaying Posts 6 - 10 of 13 Posts Total
After reviewing content from the meetings and reading through the comments on this task force discussion board, there are a few things that seem very clear. Foremost we must be sure to remember that the mission of the task force is to recommend adjustments to Management Plan 5AAC 21.359 that would be put in place during times of low abundance during the late run Kenai king run. It is with this in mind that I offer my comments.
It is important to remember that a major contributor (if not the biggest) to the low abundance of king salmon state wide are ocean conditions. Man made ocean conditions in the form of trawler by catch of kings in the Bering Sea and Gulf of Alaska would seem to be the “smoking gun” when discussing the ocean conditions and their effect on the king numbers throughout Alaska. Although this issue is not the focus of this task force it is very critical that all parties involved begin to pay close attention to it and join together to force faster and stronger regulations that will result in meaningful reform of by catch in the trawl fisheries. What we are discussing within the confines of this task force is how to manage the left overs the trawl fleet and any negative natural ocean conditions leaves for us.
Specific to the task force there are a couple things that stand out to me as major issues. 1. The ESSN commercial participants have aggressively questioned the validity (along with the vast majority of task force members and public) of the escapement numbers which seems to have some merit based on the results we saw in the 2012 season where closures had major impacts on our local communities on the peninsula. This is the paramount issue that ADFG must deal with going forward. Since commitment was made to the Didson sonar equipment/system, the department must do whatever it takes to get this system in place and functioning to the best of its abilities so they can couple technology with data to the end of accurate, timely and valid counts. The amount of comments and opinions on how to make this work is not in short supply so my comment will just be to point out that this is a huge issue and simply needs to be resolved.
2. The ESSN commercial participants have put forth a recommendation that, among other things, drops the Kenai King lower end escapement goals (a big concern) to help keep them in the water for sockeye. At the same time there has been mention of the ESSN participants coming up with measures that they would impose on themselves that would reduce the harvest of kings in their fishery. However, none of those measures have been documented, to my knowledge, so far. If the ESSN participants are putting together these measures to reduce king harvest, they should make them public and the measures should be enforceable and be enforced by ADFG. The methods of enforcement should be made public and the results of how the measures performed at king harvest reduction should be public and used as data as we move forward. The only way the self-imposed measures have any merit or validity is if they lay them out in the open for all to see so there is no credibility issue.
3. The late run king harvest numbers provided by the ADFG in their analysis of the late run Kenai king salmon make it crystal clear where the majority of harvest occurs. The ESSN commercial and in-river fishery take 70-80% of the total of the combined harvest for all fisheries/users annually. With that type of number, it is imperative that in time of low abundance that these two fisheries reduce their impact on the harvest at the highest levels. Other fisheries/users must reduce their harvest as well in time of low abundance but, in order for the entirety of the groups to share equally, it must be proportional to their impact. As a whole, we should all hold the attitude that even in times of abundance we should do all we can to keep harvest at sustainable levels. In order to incentivize all the fisheries/groups to make king harvest reduction/conservation a priority, the idea of hard caps for each of the fisheries based on history should be discussed and seriously considered. In essence a hard cap would mean if you go over your high end cap you are shut down or curtailed by way of the step down measures. This type of cap system, along with encouraging king conservation would also go a long way towards reducing or eliminating spikes in participation in the recreational sport, guided sport, personal use and subsistence fisheries in times of abundance. Over escapement of late run Kenai king salmon should never be a catalyst for liberalizing the harvest level of these fish and capping the top end of harvest in times of abundance will enable us to put some fish “in the bank” and hopefully ensure runs big enough in the future so times of low abundance are a rarity rather than commonplace.
We Need To Remove the OOPS Factor
What is the oops factor you say? The oops factor is what has occurred the last two seasons when the department levied severe restrictions on our LR King fisheries only to make post season escapement revisions that indicated there were actually enough fish to have been able to get by with only marginal in-season adjustments. I think we all recognize how difficult it is to manage in-season run strengths in low abundance situations but we simply can’t afford for this to happen again. Our escapements have ended up better than thought, but our community has suffered a great deal, both socially and economically.
The 2013 season will certainly be a challenge. We have a lot of uncertainty in our ability to count Kings accurately and a data gap on late season entry levels. Are we experiencing a run timing shift? What problems might we encounter at the new Didson site and how well will the two Didson locations correlate counts?
For these reasons I think it is important to adopt some interim regulation changes that provide the department with some flexibility should the run appear weak mid-season, and that is why I have suggested establishing an OEG of 13,000 – 30,000. In the rare instances when the in-season counts are questionable, it allows the department more time to evaluate the situation without a great deal of risk when looking at the recruitment tables. This 13,000 OEG is also close to the 10% factor, with regards to the lower end of the escapement goal, that the department has mentioned as an acceptable margin in consideration of run timing variables that may be occurring.
Perhaps none of this will be necessary in the long run if we can just do a better job of evaluating the run as it progresses. During our last Task Force meeting the department indicated that if the 2013 run was like the 2012 run there would still be closures because it could not withstand an average harvest of 20,000. The department erred when they made that statement and should have realized that average harvest rates would not apply appropriately to low abundance runs.
The last marginal run that we fished fairly normal would have been in 2009 where there was an estimated total return of 38,000 with a harvest of 16,000 and an escapement of 22,000. The total harvest included participation by all user groups including the marine and PU fisheries. If the 2013 pre-season forecast comes in at 30,000 that would be a 21% decrease from the 2009 season. If you decrease the 2013 harvest correspondingly the estimated harvest would be 12,640 and thus allow for an escapement of around 17,360. All user groups could participate relatively restriction free and we would still be well within our escapement goal range of 15,000 – 30,000.
Sonar counts and run timing evaluations are going to be crucial to avoid the oops factor. In the Escapement Goal Report the department states, “The recommended goal is based on the actual escapement needed to sustain yields, so that it must be evaluated by accounting for undetected Chinook salmon passing the Rm9 sonar site. This is accomplished by multiplying Didson sonar estimates at Rm9 by 1.31, and subtracting the estimated harvest and release mortality above RM9.” Thus, the department has to commit to adding real time adjustments to the RM9 counter for undetected passage on a daily basis for in-season management purposes. Major end of the season adjustments should no longer be deemed acceptable as they cause too much distrust towards the department’s perceived management strategies.
I hope this adds some perspective to some of these important elements in our ongoing discussions.
I was disappointed that during the January 14, 2013 Kenai King Salmon Task Force Meeting it was announced that the public was not going to be permitted to comment or ask questions directly to the Task Force during any of the discussion. The Dept of Fisheries just released their NEW king salmon study information since the last Task Force meeting, and within the last week of this meeting, so lots of new information was presented to the Task Force by the Department at the onset of this meeting and public was not offered time to comment. I was also surprised that being the public was not able to comment or ask questions publically during to this “Grass Roots” meeting….. the East Side Set Netters were permitted to show a 14 minute video of their concerns and “their math” of how the king fishery should be managed? Again, no member of the public or Advisory Committees could comment on this video to the Task Force? The Anchorage AC had 2 members drive down to this meeting from Anchorage to ask specific questions to the entire Task Force body, as generated by members of the Anchorage Advisory Committee. Considering our AC represents the largest sport fishing community in the state, we were very disappointed in not being able to state our Kenai King Salmon concerns to the Task Force. In closing, It was very disappointing that the ESSN community came to this meeting with no new innovative way to allow them to try to fish for sockeye and not by-catch as many kings. I was expecting after them being on the beach not fishing all last summer that they would have had time to develop some new means of fishing to minimize this problem. Different nets…different timing….something?? I do not support the current plan as presented by the ESSN community in their video to lower the Kenai King lower end escapement goals AGAIN, to NEW RECORD LOWS just to allow for sockeye fishing. The management plan offered by the Department of lowering of the lower end escapement goal for king salmon in the Kenai River below the goals of 2012 is also not supported. AGAIN the Department is lowing this goal lower than any time in history….during troubled times! By the information given by the Department in their latest reports; The only thing we can be “certain of” is the lack of returning king salmon is going to continue in 2013…..and beyond. Bruce Morgan and Kevin Sparrowgrove
Regarding Dwight Kramer's Task Force Mission Statement of resolving Alaska's king salmon problems by only closing down sportfishing or counting fish more accurately. It is extremely short-sighted to believe that a statewide king salmon problem may be addressed by suggesting solutions for a single river within Alaska. We have a problem which involves millions of missing king salmon in Alaska. This magnitude of a problem points only to large scale ocean problems which most likely involve commercial fisheries or food chain disruption factors. To ignore those ocean factors and point to only sportfish closures and better fishing counting, is actually worse than doing nothing. If this Task Force did nothing at least someone else would attempt to pickup the ball and actually take a closer look at the issue. These proposed sportfish only closures and counting solutions will do absolutely nothing to resolve our statewide king salmon problems. If this Task Force is not able to address oceans issues or solutions, then it should have generated a solution statement which cited its inability to address the issue. The Task Force should have just said that our king salmon problems begin within our oceans and are therefore outside this Task Forces ability to address. Shutting down sportfishing on a single river and trying to count fish better are completely meaningless suggestions and totally miss fulfilling the Task Force Mission Statement.
The format of this website is just as illogical as killing salmon on our oceans and dumping them. Why create a website, request comments and when those commments are submitted they must go through some kind of screen for acceptable content in order to be posted? Here we have a monster king salmon problem with lots of persons interested in the subject but look how many comments are posted? I have personally posted many comments to this website regarding this king salmon issue but those comments were not posted as were nodoubt many others. What kind of information gathering is this? If you don't like what the comment information is you just act like it is meaningless. What a great way to not have to listen to the public. The Alaska Board of Fish should try this, they would not have to listen to the hundreds of comments at the meeting! What a very very poor comment page...