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.