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Thread: Data request to Commissioner of ADFG on no bait regulation

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    Default Data request to Commissioner of ADFG on no bait regulation

    I sent the following today to the Commissioner so we can understand the rationale for the no bait restriction relative to the management plan. I cannot get the numbers to go below 22500 without some serious adjustments to the way the forecast and management practice has been in the past. It may be ADF&G is using a new technique and I would like to see it or they have gone outside the plans which is fine with justification. This has nothing to do with no bait or bait discussion. It has to do with how the decisions are made and whether they are defensible given the data and management plans.

    Personally the plans should not couple the two fisheries. Giving up Kasilof sockeye management when chinook are not abundant on the beach and Kasilof sockeye are available is good management practice. The plans keep that from happening with the hour limitation tied to bait or no bait. But that is what we have and the e.o does not explain how ADFG came up with the numbers.

    I am making a formal request for a justification for the recent Sport Fish Emergency Order which limits the Kenai River Chinook Salmon Fishery to no bait. I would like to see the mathematical calculation used to meet the requirements of the Kenai River Late Run Chinook Salmon Management Plan.
    My calculations would indicate that the Alaska Department of Fish and Game has gone outside the management plans with this emergency order. My rationale is as follows:
    1. Prior to the season the forecast for late run Chinook salmon was 30,000 total return. This was stated in the Outlook documents and at Advisory Committee meetings. Commercial fisherman were told the season would start normally and be adjusted based on in-season information.
    2. The forecast has not been changed and based on Kenai River early run chinook to late run regression analysis the forecast would be much higher than 30,000 (near 40,000). The fact other systems in UCI are also doing well would indicate a stronger than forecast return.
    3. The late run management plan states that no bait restrictions may be used if the Department projects an in river return of less than 22,500 fish. This is return not spawning fish.
    4. The historical commercial harvest rate of late run chinook has ranged up to 20% but averaged much lower (13%). This is actual fishing hours. Assuming a full out fishery wilth all hours as stated in the emergency order is not rational or historically defensible. Thus the total commercial harvest is likely to be around 6,000 to 7,000 fish.
    5. The genetic data on the eastside set net chinook fishery would suggest that not all commercially harvested chinook are Kenai River bound and the historical exploitation rate used above was calculated on the assumption all were Kenai River chinook.
    6. Therefore, even subtracting 7000 fish from 30,000 one arrives at 23,000 in river return.
    7. Probability of having a higher return is much greater than the probability of having a lower return.
    Therefore the Department must be using different numbers or have used calculations that include some probability analysis not in evidence. Therefore please provide me with those numbers and rationale for the decision. At this point it appears that the Department is outside the management plans and has caused an impact on the commercial fishing hours that is not justified.

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    Quote Originally Posted by Nerka View Post
    I sent the following today to the Commissioner so we can understand the rationale for the no bait restriction relative to the management plan. I cannot get the numbers to go below 22500 without some serious adjustments to the way the forecast and management practice has been in the past. It may be ADF&G is using a new technique and I would like to see it or they have gone outside the plans which is fine with justification. This has nothing to do with no bait or bait discussion. It has to do with how the decisions are made and whether they are defensible given the data and management plans.

    Personally the plans should not couple the two fisheries. Giving up Kasilof sockeye management when chinook are not abundant on the beach and Kasilof sockeye are available is good management practice. The plans keep that from happening with the hour limitation tied to bait or no bait. But that is what we have and the e.o does not explain how ADFG came up with the numbers.

    I am making a formal request for a justification for the recent Sport Fish Emergency Order which limits the Kenai River Chinook Salmon Fishery to no bait. I would like to see the mathematical calculation used to meet the requirements of the Kenai River Late Run Chinook Salmon Management Plan.
    My calculations would indicate that the Alaska Department of Fish and Game has gone outside the management plans with this emergency order. My rationale is as follows:
    1. Prior to the season the forecast for late run Chinook salmon was 30,000 total return. This was stated in the Outlook documents and at Advisory Committee meetings. Commercial fisherman were told the season would start normally and be adjusted based on in-season information.
    2. The forecast has not been changed and based on Kenai River early run chinook to late run regression analysis the forecast would be much higher than 30,000 (near 40,000). The fact other systems in UCI are also doing well would indicate a stronger than forecast return.
    3. The late run management plan states that no bait restrictions may be used if the Department projects an in river return of less than 22,500 fish. This is return not spawning fish.
    4. The historical commercial harvest rate of late run chinook has ranged up to 20% but averaged much lower (13%). This is actual fishing hours. Assuming a full out fishery wilth all hours as stated in the emergency order is not rational or historically defensible. Thus the total commercial harvest is likely to be around 6,000 to 7,000 fish.
    5. The genetic data on the eastside set net chinook fishery would suggest that not all commercially harvested chinook are Kenai River bound and the historical exploitation rate used above was calculated on the assumption all were Kenai River chinook.
    6. Therefore, even subtracting 7000 fish from 30,000 one arrives at 23,000 in river return.
    7. Probability of having a higher return is much greater than the probability of having a lower return.
    Therefore the Department must be using different numbers or have used calculations that include some probability analysis not in evidence. Therefore please provide me with those numbers and rationale for the decision. At this point it appears that the Department is outside the management plans and has caused an impact on the commercial fishing hours that is not justified.
    Did you also write a letter about why we don't have bait in the early run yet? Or don't you care if all the plans are followed just certain ones?

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    Quote Originally Posted by kidfromgarcia View Post
    Did you also write a letter about why we don't have bait in the early run yet? Or don't you care if all the plans are followed just certain ones?
    My understanding is the run is forecast around 10 tob12 thousand and harvest will be such final escaement wii be at upper end of oeg. There is no management to question. I know the numbers on early run and can understand rationale. Just trying to understand late run as my calculations do not jive with ADFG. Simple as that but I get your venom in the sacrastic tone of your question. Maybe you could have left that part out if you really wanted an answer.

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    By regulation, bait only allowed on ER if projecting above escapement goal. That is to say that bait is a liberalization rather than the norm. What a concept.


    Sent from my iPhone using Tapatalk

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    Shouldn't we be erring on the side of caution and be trying to get as many fish in river as we possibly can? I don't understand F&G. Finally, after years of horrible returns we get some good numbers back and they immediately want to bring harvest levels up? It cant be a bad thing to let these fish spawn, unmolested on their up river spawning beds and without bait until we at least meet the upper end of the escapement before we open it up to bait? The more fish we can get to spawn, the more offspring we should have which should result in better fishing for the future, right? We aren't going to over escape so many kings into the Kenai that it is detrimental to their spawning.

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    Quote Originally Posted by live4chrome View Post
    Shouldn't we be erring on the side of caution and be trying to get as many fish in river as we possibly can? I don't understand F&G. Finally, after years of horrible returns we get some good numbers back and they immediately want to bring harvest levels up? It cant be a bad thing to let these fish spawn, unmolested on their up river spawning beds and without bait until we at least meet the upper end of the escapement before we open it up to bait? The more fish we can get to spawn, the more offspring we should have which should result in better fishing for the future, right? We aren't going to over escape so many kings into the Kenai that it is detrimental to their spawning.
    Actually no, we should be trying to manage within the escapement goal range - for ALL of our stocks. Why do you assume that we won't over escape on kings? According to the data, we've almost done that in recent years with lower projections than this year's. Also, we've consistently over escaped on Sockeye as a result of King restrictions.

    I do agree that bait should be a liberalization, not the norm, on both ER and LR. From what I've seen, most inriver fishermen agree, but some prefer to keep things as is since going no bait on the LR severely restricts setnets. It is very unfortunate that we are trying to manage a commercial fishery via the sport fishery.

    This has been a debate within ADFG for months, with sportfish leaders arguing that any time they go no bait, setnets should get restricted. Unfortunately, the regulation only applies if they are projecting less than 22,500. Nerka is correct to question the validity of this projection and of this management call. It is not consistent with recent years when the correlation was used to make management calls and it has special interests written all over it. Interesting that upriver fishing was liberalized and everyone downstream was restricted. Have we become the Matsu?

    FYI, no creel survey above Soldotna bridge, so all harvest up there will be estimated. Our King run is strong enough for that, but not for two regular setnet periods per week with additional time based in abundance?

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    Quote Originally Posted by live4chrome View Post
    Shouldn't we be erring on the side of caution and be trying to get as many fish in river as we possibly can? I don't understand F&G. Finally, after years of horrible returns we get some good numbers back and they immediately want to bring harvest levels up? It cant be a bad thing to let these fish spawn, unmolested on their up river spawning beds and without bait until we at least meet the upper end of the escapement before we open it up to bait? The more fish we can get to spawn, the more offspring we should have which should result in better fishing for the future, right? We aren't going to over escape so many kings into the Kenai that it is detrimental to their spawning.
    It is a valid question and one I tend to support in concept for a stock that has had escapement issues. As a general rule more fish is not better and management to the escapement goals is to produce high sustained yields. Where the problem comes in with a number of years of low escapement or harvest policies that do not take in distribution is that you can lose sub populations within the system. I keep using Beaver and Slikok Creek as examples but they are good ones. So going back to status quo is not dealing with some of the issues. Therefore a higher escapement and maybe a slight loss of yield for some years to repopulation depressed stocks may be fine (depends on the trade offs and habitat of the streams impacted). Same goes for age composition. When a stock has these issues the concept of a single escapement goal really does not apply and in my opinion ADF&G should be taking that into consideration. One thing they should do is close the area at the mouth of Beaver Creek and try to get fish spawning in that system again. I know it is a great fishing spot but why is Beaver Creek fish not protected when other tributary systems have closed waters at their mouth? Plain and simple opportunity and user pressure over conservation.

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    Hmmmm.....

    Did you ask under a specific legal authority, such as the Freedom of Information Act (Federal law), or perhaps under a State statute such as Open Records law or something similar? If so, you will likely a response. If not, I'm not optimistic. The request seems a bit provocative. Sorta like asking ADF&G to provide ammunition that might be promptly fired back at them.

    I realize public agencies are required to justify their actions. And presumably they've done that in the E.O. Past that, are you sure they have an obligation to provide the information being requested? If you ask per a specific legal authority, you'll get their attention. But otherwise, don't be too surprised if you don't get a response.

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    Quote Originally Posted by Cohoangler View Post
    The request seems a bit provocative. Sorta like asking ADF&G to provide ammunition that might be promptly fired back at them.
    .......... don't be too surprised if you don't get a response.
    Agreed, especially with the last comment.

    Quote Originally Posted by Nerka View Post
    it appears that the Department is outside the management plans and has caused an impact on the commercial fishing hours that is not justified.

    Quote Originally Posted by Nerka View Post
    I get your venom in the sacrastic tone of your question. Maybe you could have left that part out if you really wanted an answer.
    Ha Ha Ha...Pot this is Kettle....

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    Alaska is different Cohoangler. The Department for an Emergency Order must justify it with data. Therefore this request is for that data and in the pass ADFG has usually provided it in the emergency order justification. However, this is a request to the Commissioner and again in Alaska if they do not respond the local representatives can request it or the Governor. The Board of Fish members can also request the data and ADF&G will have to provide an answer. However, in my letter I am just asking for the rational and data. I said it appears that the Department .... Not that they did anything wrong but my calculations would indicate that the probability of having a larger return than forecast is much greater than a lower return. Next even with 30,000 the commercial harvest estimate would have to be 7500 fish to not meet the 22500. Even at the higher end of know exploitation rates in the commercial fishery it is unlikely that 7500 fish would be caught. My point in all of this is that if ADF&G wants to go outside the plans for other reasons they should state it or if they want to be super conservative then provide the data and let others see if being super conservative is justified (board of fish members may like to know since this is an allocation plan). The justification used in the e.o meets none of the historical e.o descriptions and I want to know why.

    Pot vs Kettle - yes we all have sarcastic nature sometime. Usually prompted by someone else's comment or actiion but should try to control it.

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    Why is it unlikely they will harvest less than 7,500 fish? They took just under that many last year with stricter com fishing times.

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    Quote Originally Posted by Nerka View Post
    Alaska is different Cohoangler. The Department for an Emergency Order must justify it with data. Therefore this request is for that data and in the pass ADFG has usually provided it in the emergency order justification. However, this is a request to the Commissioner and again in Alaska if they do not respond the local representatives can request it or the Governor. The Board of Fish members can also request the data and ADF&G will have to provide an answer. However, in my letter I am just asking for the rational and data. I said it appears that the Department .... Not that they did anything wrong but my calculations would indicate that the probability of having a larger return than forecast is much greater than a lower return. Next even with 30,000 the commercial harvest estimate would have to be 7500 fish to not meet the 22500. Even at the higher end of know exploitation rates in the commercial fishery it is unlikely that 7500 fish would be caught. My point in all of this is that if ADF&G wants to go outside the plans for other reasons they should state it or if they want to be super conservative then provide the data and let others see if being super conservative is justified (board of fish members may like to know since this is an allocation plan). The justification used in the e.o meets none of the historical e.o descriptions and I want to know why.
    Alaska is certainly different but I'm not sure it's different on this issue. Clearly ADF&G has to justify their actions, and they have to provide additional technical information when someone with management authority over ADF&G asks for it. Perhaps at one time you were. My sense is you're not anymore.

    So before ADF&G answers your questions, they have to ask whether they have an obligation to respond to every individual that asks them technical questions in the middle of the season. My sense is that it's their discretion whether they respond to these requests. Or not.

    If they stopped what they are doing to respond to every such request, they might not get anything else done. Recall they are in the midst of their in-season management process. They're currently up to their neck in issues related to managing "one of the most complex fisheries in the world". Your words, not mine (but I agree!)

    So if you get a response, great! Lettuce know what they say. But I'm not holding my breath.....

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    Quote Originally Posted by live4chrome View Post
    Why is it unlikely they will harvest less than 7,500 fish? They took just under that many last year with stricter com fishing times.
    Fair question. So here are the data from ADFG - the run last year was a total return of around 31 thousand (however rumor has it that Sport Fish will up this before the Board meeting to around 37-39 thousand because of netting adjustments for size. So the run was stronger but lets use 30,000 last year to be super conservative. The total ESSN harvest was 7781 chinook but not all of them are kenai. Genetic data indicated that the kenai portion was around 73% or 5700 fish. Therefore last year the goal of 22500 would have been met. It also means that the Department had 1800 additional fish to harvest in the commercial fishery relative to the plans. So that is a lot of fishing time at the peak of the return if used correctly.

    So I hope this helps frame why I am asking the Department for their data. Relative to that cohoangler is only partially correct. The Department has an obligation by law to justify an emergency order. They cannot just issue them and say trust me. The courts and AG office have spoken to this already. So as a citizen they do have an obligation to provide a defensible justification. Now that could be verbal but the AG office has in the past said it must be written. So you are not correct to say they have no obligation to me and only a person of authority. Now if they say no then I have a number of options. First, the Freedom of Information Act which could ask for emails and data. In the past the Department has refused this request if the data are part of deliberations. That has not been challenged in court relative to an actual e.o justification. Next one could sue to get it. But the most effective way if they refuse to answer is to ask a representative or Board of Fish member. All of this would just point out the weakness of their position or at least cast questions on their rational. There is really only a single number they have to provide. The commercial harvest estimate and how they got it. No one has questioned using the forecast except to see if they used it and not some other number which they have used in the past based on the regression.

    Now a lesson in Alaska management. When ever an e.o is issued because it is outside the regulations the Department must justify it. So making a request on an e.o is not the same as asking for inseason data or burdening the Department. Justifications are part of the e.o process in Alaska. Have written and justified many of them without questioning why. They could delay answering until after the season when the formal e.o is written. Done that also in the past.

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    Quote Originally Posted by Nerka View Post
    My understanding is the run is forecast around 10 tob12 thousand and harvest will be such final escaement wii be at upper end of oeg. There is no management to question. I know the numbers on early run and can understand rationale. Just trying to understand late run as my calculations do not jive with ADFG. Simple as that but I get your venom in the sacrastic tone of your question. Maybe you could have left that part out if you really wanted an answer.
    I called the fish and game office for answers I don't need a bunch from bloggers. For understanding the thinking what I can see here is that for the June chinooks it is ok to look at size and smaller runs as in less fish# so ok to not fish hard on them and then the July chinooks come and is a different story, all of a sudden the stuff disappears, actually the small fish and smaller runs as in # fish is also happened to July everyone on the river knows it. i don't see all the anti-against logic of going easy to be sure, so when sure with no bait all you did was load the river with chinook and can put out all the nets your allowed as many times as you can for reds, when you actually have a good idea can see that the chinook run is so much bigger than forecasted. It happened last year great I say and hope it does again this year, so you have some good fishing to look forward to, if your a guide and dont like it or a commercial netter and don't like it, your free to find other lines of work. Braid or mono?

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    Quote Originally Posted by live4chrome View Post
    The more fish we can get to spawn, the more offspring we should have which should result in better fishing for the future, right? We aren't going to over escape so many kings into the Kenai that it is detrimental to their spawning.
    I was actually told that this is the same for chinooks as like reds when to many get into the escapements it can also be detrimental to future numbers runs of chinooks. My problem with this is that since everyone came here and allowed the cities to grow and houses to become an urban kenai river city of people, stores, schools and roads more fish are needed since the land all around it is now worn down like a plowed up prairie.

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    Quote Originally Posted by kidfromgarcia View Post
    I called the fish and game office for answers I don't need a bunch from bloggers. For understanding the thinking what I can see here is that for the June chinooks it is ok to look at size and smaller runs as in less fish# so ok to not fish hard on them and then the July chinooks come and is a different story, all of a sudden the stuff disappears, actually the small fish and smaller runs as in # fish is also happened to July everyone on the river knows it. i don't see all the anti-against logic of going easy to be sure, so when sure with no bait all you did was load the river with chinook and can put out all the nets your allowed as many times as you can for reds, when you actually have a good idea can see that the chinook run is so much bigger than forecasted. It happened last year great I say and hope it does again this year, so you have some good fishing to look forward to, if your a guide and dont like it or a commercial netter and don't like it, your free to find other lines of work. Braid or mono?
    you need more help from bloggers than you know.

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    Quote Originally Posted by kidfromgarcia View Post
    I called the fish and game office for answers I don't need a bunch from bloggers. For understanding the thinking what I can see here is that for the June chinooks it is ok to look at size and smaller runs as in less fish# so ok to not fish hard on them and then the July chinooks come and is a different story, all of a sudden the stuff disappears, actually the small fish and smaller runs as in # fish is also happened to July everyone on the river knows it. i don't see all the anti-against logic of going easy to be sure, so when sure with no bait all you did was load the river with chinook and can put out all the nets your allowed as many times as you can for reds, when you actually have a good idea can see that the chinook run is so much bigger than forecasted. It happened last year great I say and hope it does again this year, so you have some good fishing to look forward to, if your a guide and dont like it or a commercial netter and don't like it, your free to find other lines of work. Braid or mono?
    I thought kids these days have spell/grammar check on there smart phones?
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    I think you meant: "I thought kids these days have spell/grammar check on their smart phones?"

    Quote Originally Posted by FishGod View Post
    I thought kids these days have spell/grammar check on there smart phones?

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    Quote Originally Posted by Nerka View Post
    It is a valid question and one I tend to support in concept for a stock that has had escapement issues. As a general rule more fish is not better and management to the escapement goals is to produce high sustained yields. Where the problem comes in with a number of years of low escapement or harvest policies that do not take in distribution is that you can lose sub populations within the system. I keep using Beaver and Slikok Creek as examples but they are good ones. So going back to status quo is not dealing with some of the issues. Therefore a higher escapement and maybe a slight loss of yield for some years to repopulation depressed stocks may be fine (depends on the trade offs and habitat of the streams impacted). Same goes for age composition. When a stock has these issues the concept of a single escapement goal really does not apply and in my opinion ADF&G should be taking that into consideration. One thing they should do is close the area at the mouth of Beaver Creek and try to get fish spawning in that system again. I know it is a great fishing spot but why is Beaver Creek fish not protected when other tributary systems have closed waters at their mouth? Plain and simple opportunity and user pressure over conservation.
    Unless you're talking about Northern District management and issues; this discussion applies solely to the Kenai.

    Seriously, though, I do hope you get your answer to your letter.

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    Quote Originally Posted by NorcalBob View Post
    I think you meant: "I thought kids these days have spell/grammar check on their smart phones?"
    Ah, you got me. I was writing that while taking a dump
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