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Thread: Proposal 103

  1. #1
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    Default Proposal 103

    Proposal 103 submitted by Kenai River Sport Fish Association would change the Upper Cook Inlet (UCI) management plan to include the sentence…”Achieving the lower end of all escapement goals shall take a priority over not exceeding the upper end of any escapement goal.”


    The Alaska Department of Fish and Game (ADF&G) stated “It should be noted that the management plans and policies do not indicate a priority of meeting the lower end of escapement goals over exceeding the upper end of an escapement goal. However, even though it is not stated in the plans and policies, the department puts a priority of meeting the lower end of escapement goals over exceeding the upper end of escapement goals.”


    The presumption in these statements is that the fish stock is at some biological risk and/or that going over a goal is less risk than going under the goal relative to sustainability of yields. What is not stated is how far one is under a goal for one stock (Stock A) and how far one is willing to go over a goal for another stock (Stock B). As implied by ADF&G and KRSA, - being slightly under Stock A goal is greater risk than going over Stock B goal by a wide margin. Historically the Board of Fish (BOF) and ADF&G have not had this attitude for all stocks and situations.


    Biological and Sustainable Escapement Goals (BEG and SEG, respectively) provide for high average yields. They are not goals that if not met threaten the long-term health of the stock. Spawner levels that would do that are well below the BEG and SEG goals. In addition, well under a goal and well over the goal can produce the same return and therefore the similar risk of loss yield and altered ecological consequences

    ADF&G until recently has never stated that there was a priority of meeting the lower end of an escapement goal than going over the upper end of a goal. This response was relative to a question about trade-offs between the Kenai River Chinook salmon SEG goal and the Kenai River sockeye salmon SEG goal. This answer is not consistent with past practices of the BOF or ADF&G.


    Within UCI there have been as many as 35 streams with escapement goals. In a mixed stock fishery ADF&G staff have always realized that in some years a goal may not be achieved so that other goals are not significantly exceeded. Every year at least one of these goals will be under the SEG or BEG goal.


    Does ADF&G plan to close all fisheries downstream to achieve this goal or will they manage the other systems so that they reach their goal or do not exceed the Maximum Recruitment Point. Does a 100 fish under Stock A goal mean hundreds of thousands of fish in Stock B goes over the goal? This is the fundamental question and why ADF&G and KRSA positions are not defendable in a mixed stock fishery for all systems that may be under a goal.


    Management flexibility has been a hallmark of ADF&G management and was in effect in 2013 – ADF&G recent priority statement is not consistent with regulations or practice.


    For example, when Russian River late run sockeye salmon goals are not being met the BOF and ADF&G close the Russian River and the Kenai River 1800 yards downstream of the confluence. The ADF&G does not close the whole Kenai River even through Russian River fish will be harvested in the 50 miles below the Russian River. The reason for this is that Kenai River sockeye in-river harvest would be lost and the trade-off of protecting every Russian River fish is not worth the cost. According to the recent policy statement ADF&G would or should close the whole river as meeting the Russian River goal minimum would take priority over harvest and meeting the Kenai River mainstem spawning goals.


    In addition, the Department under-escaped the Susitna River to keep Kenai River sockeye salmon from significantly exceeding its goal when the Kenai River late run sockeye salmon return was above 4 million fish.. The BOF codified this into regulation that reduced the Susitna SEG goal to an OEG goal that had a lower minimum when Kenai River sockeye salmon return was strong. The trade-off was to go over the goal in the Kenai and under in the Susitna. The main point was not to do it every year or on a consistent schedule.


    There are numerous other examples to demonstrate that ADF&G does not make a priority of meeting the lower end of a goal over going over or meeting another stock escapement goal


    For example, ADF&G has allowed a Kenai River late run chinook salmon fishery to start July 1 even when the Kenai River early run chinook stock has not met it’s goal. In 2012 and 2013 the Kenai River chinook early run did not meet its goal, yet the in-river sport fishery was allowed to harvest early run fish. If a priority to meeting the early run goal was in place then the in-river fishery should have been closed for the whole month of July according to this rationale. In 2013 ADF&G claim is that the early run goal was not made and therefore there was no harvest-able surplus, but fish were harvested while targeting late run Chinook salmon.


    The reason for these types of decisions is obvious. All systems are not created equal and in a mixed stock fishery, whether in-river or out, trade-off must be made in-season. All systems cannot meet their goals. With numerous systems with goals this would be impossible.


    Instead, ADF&G has historically used their professional judgement to make these trade offs. How far one is going over on one goal and under on another is the issue. Meeting the minimum goal vs. going over other goals, regardless of magnitude, would be poor best management practice


    In summary, putting language in regulation that puts a priority on meeting the lower end of a goal in all cases is both biologically and socially a bad idea.

    I would hope people will write the Board of Fish and say no to this proposal. I guess I have more trust in ADF&G than the KRSA.

  2. #2
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    This could and would close the river to all fishing when ER kings do not meet their lower goal. So any time ER kings are below their goal no gill net in cook Inlet till July 1st, then gill nets could fish and the river stays closed to protect all ER kings in the river. That sounds good to me, but if they try to open the river before all the ER kings have spawned it will not work. I am sure all the guides will go for the river being closed till the end of Aug.

  3. #3

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    Had this proposal been in effect in 2013, the entire inlet should have been closed to fishing because Fish Creek was failing to make its 20,000 fish Sockeye escapement goal. While it ended up only 1,100 fish short, millions of Sockeye would not have been harvested and would have instead overescaped into the Kenai, Kasilof, and other rivers. Given that in UCI there will pretty much always be systems that, for whatever reason, fail to meet escapement, this would be disastrous for our fisheries.

    While some people might think that's great that all the nets could be pretty much shut down most of the time, they may not be so happy when the entire Kenai is closed to sport and PU sockeye fishing because ER Russian River Sockeye fail to meet their goal, and any Sockeye harvest in the Kenai could result in harvest of that stock. Or when ADFG picks a bad day to do their single areal surveys of the Susitna Drainage systems, and fishing in that system grinds to a halt due to low counts in one or two tribs.

    I'll be interested to listen to KRSA's hired guns from the lower 48 tell us all why we'd all be better off by putting this into our management plans. Maybe they'll tell us it'll give us all nice suits and pretty tans...

  4. #4
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    Whenever someone proposes a regulation that includes the words all, any, never, always, must, shall, or similar absolutes, be aware. Be very aware. Those words, when codified in the regs, can handcuff the managers to the extent that they cannot do their job with any confidence or credibility.

    If the UCI has as many escapement goals as Nerka points out (35), the regulation would virtually eliminate fishing on the KP. It might not be because of the lack of escapement, but rather the uncertainty in the enumeration of the escapement. If ADF&G has to hit the lower end of each escapement goal before they can conduct a fishery, fishing of any sort (commercial, recreational, subsistence) will be both uncertain and quite limited.

    I can understand that achieving the lower end of the escapement goals should be an ADF&G priority, as it appears to be, but mandating that in the regs is overkill. And likely to result in poor management, rather than improved fisheries.

  5. #5

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    Quote Originally Posted by Cohoangler View Post
    Whenever someone proposes a regulation that includes the words all, any, never, always, must, shall, or similar absolutes, be aware. Be very aware. Those words, when codified in the regs, can handcuff the managers to the extent that they cannot do their job with any confidence or credibility.

    If the UCI has as many escapement goals as Nerka points out (35), the regulation would virtually eliminate fishing on the KP. It might not be because of the lack of escapement, but rather the uncertainty in the enumeration of the escapement. If ADF&G has to hit the lower end of each escapement goal before they can conduct a fishery, fishing of any sort (commercial, recreational, subsistence) will be both uncertain and quite limited.

    I can understand that achieving the lower end of the escapement goals should be an ADF&G priority, as it appears to be, but mandating that in the regs is overkill. And likely to result in poor management, rather than improved fisheries.
    Great post Coho, but I believe that the priority for ADFG should be in achieving escapement goals distributed throughout their goal range, as is consistent with Alaska's Sustainable Salmon Fisheries Policy. It seems that achieving this would be effectively impossible with a department policy or management plan that states one end of all goals is more important than the other.

    That said, I especially like your first paragraph. In reading through the proposals and our existing management plans, "shall" is used in current language sometimes when referring to restrictive actions in the interest of conservation, but not when liberalizing fisheries. Perhaps this is appropriate, as at a certain point restrictive action should be taken no matter what.

    But.... There are quite a few proposals that seek to rewrite language that says the department "SHALL" liberalize fisheries when projections or forecasts reach a certain level. Seems like an awful poor plan to me. At the risk of sounding like a broken record, many of these proposals are from the same "sportfishing" association that wrote proposal 103, and would like to see the "ineffective" slot limit eliminated rather than broadened (Proposal 190).

  6. #6
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    I wounder if proposal 103 is why some river guides now have drift net permits? This I know for a fact! I think they may want to cash in on some off the hook gillnetting this next year if 103 goes into play.

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