What is wrong with this picture
I just heard from a KRAC representative that the Board of Fish will not get public comments or reports in written format until the Board of Fish meeting or maybe a day before. The comment period ended on the 17th and staff reports are not done. So Board support is getting everything to the printer but with the holiday that is probably delayed. Anyway the printer has to make up 27 binders for the meeting and of course that includes 2-3 thousand pages of information.
My concern and I would hope everyone else regardless of where one stands on allocation is how in the heck can a lay board, some of which do not know UCI fisheries, read all of the material and understand it in one to two days. Also, the advisory committees are making decisions without materials and the public cannot interact with the staff because written comments come out after the advisory committee meetings. Staff at some of the meetings had to say they did not know the Department position on some proposals.
The system is broken. We are talking about millions of dollars and of course resource conservation issues. There is no way the Board can digest all this information. I have been reading the staff comments and they are inconsistent, open to questions about data and selective use of data, incomplete relative to some conservation issues, and the list goes on and I know the fisheries. Add in biased user group comments and no wonder the Board is confused, makes some bad decisions, and creates a mess with regulations in conflict with each other. To be fair there are really some good points made and data in the staff comments. Separating the two out is the trick.
I would hope user groups would write to their local representatives and tell them the system is in need of repair.
So here are some suggestions.
1, The Board meeting takes place 45 days after they get all the comments and the proposal books need to be out at least 45 days before the comment deadline. Depending on the situation the Board sets a meeting date to allow law to review and get regulations signed before the season but that is really not necessary as the old regulations could be in place for the Board meeting year. So lets have the meeting start on Feb 15th. That means all public comments have to be to the Board by January 2nd and to the printer by December 15th. The proposal books would have to be out by October 1st to the public and call for proposals could be the same as today.
2. Wrinkle number 2 - the AC would act like the Board so after all the comments are out they would have 45 days to make their comments known to the Board. This means after January 1 they would have up to the Board meeting to make comments and they would not be treated the same as the general public. They are an arm of the Board and therefore get special consideration. They would have all the written comments on January 1 and therefore would be meeting, as necessary, in January and early Feb to form positions. The Board will accept the comments up to the day of the Board meeting. This means less paperwork to read just before the meeting.
3. All regulations passed at the Board meeting are in regulation format at the conclusion of the meeting. No more intent language. ADF&G staff use to do this with a regulation specialist. When the Board passed something they wrote the regulatory language that night and the Board reviewed it the next day for final action. One could add a couple of days to the Board meeting just for the Board to review and act on all regulations. This is not to debate the issue but to clarify inconsistent regulations and errors of omission. In the present situation the Board ask if there are errors and the Department usually says no but we know that is not true. The Department does not have the regulatory language in front of them. This also cuts down the law review time as the regulations could go directly to law.
4. ADF&G does not have to make staff divert time and energy to comment on every proposal or get the most recent years data to the Board. The idea one season should drive a regulatory decision is a bad one. So ADF&G staff needs to just concentrate on the major issues and not deal with every proposal on an individual bases. The Board does not do this so it is a waste of time. They pick one proposal and the process starts and the other proposals on that subject are tabled. So choose the main topic and comment in general on the data available and go from there.
So given the present Board makeup this would make the process cleaner in my opinion. However, I also believe that a lay Board of Fisheries can no longer deal with the complex issues of Alaska fisheries management. A full time Board of Fish is needed with their own staff to help them. I prefer a Board that is a mix of professionals and the public. I also think the Board of Fisheries should not meet except every 5 years. Petitions can deal with really serious issues.
Anyway, thought people should know the timeline and think about making changes to the way the Department and Board does business.
On the topic of streamlining....
I noticed the ADFG position paper on the various proposals is extremely redundant... using the same boiler-plate background explanations, tables, and graphs OVER AND OVER again for each proposal on a similar topic/issue. They would save volumes of disk space and paper by grouping similar proposals and providing the explanations/tables/graphs once instead of multiple times. The document would also be a lot thinner and less intimidating to the would-be reader.
"Let every angler who loves to fish think what it would mean to him to find the fish were gone."
The KeenEye MD
Obfuscation by design, unrealistic work schedules or just shoddy work?
I sure can't say why its so in this case, but sometimes when an organization puts in place a plan that cannot possibly work it is because its not intended to actually work.
Instead it can just be a sort of a checkbox to try to show that the organizers are doing their job when in fact they're not.
i.e., Asking if the materials were distributed prior to the meeting: Yes.
Instead of asking if the materials were distributed in time to be read completely before the meeting: No