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Thread: Kenai River Sport Fishing Association Proposal

  1. #1
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    Default Kenai River Sport Fishing Association Proposal

    The KRSA has submitted proposal 132 to the Board of Fish meeting to take place in February. In this proposal KRSA has a section which states

    " Limitations on emergency order authority and fishery closure windows designated to distribute escapement throughout the run and to the balance allocation and opportunity among fisheries shall take priority over not exceeding the upper end of any optimum, biological, sustainable, or in river escapement goal."

    This proposal has significant implications for fishery management in Alaska. It essentially say that escapement goal management is to not be conducted by ADF&G via emergency order authority relative to the upper end of goals.

    For the record most escapement goals in the State are a range where the goal will provide high sustained yields of salmon. The above section would remove the management of the fishery by ADF&G to provide for high sustained yields. The fact that the proposal says that sustained goals are not to be managed for.

    This limitation on emergency order authority is probably illegal based on the Brown ruling but KRSA appears to show no regard for fishery management practices that have made Alaska a model for salmon management.

    I would hope every fisherman in the State, regardless of the allocation issues, would oppose this proposal and write to the Board of Fish stating such.

    It is an embrassment for a group that is supposely a conservation group to propose this limitation on ADF&G.. It is an insult to those biologist in ADF&G who manage our fisheries to meet escapement objectives. If KRSA wants management to change they should provide a rationale for new goals and why the present allocations are not working rather than dismantle a proven management system.

    KRSA has sunk to new lows in the effort to dismantle fishery management in Alaska. This is a statewide issue even though the meeting is for Upper Cook Inlet.

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    Thumbs down KRSA should be ashamed

    Thanks for the head's up Nerka.

    Do you have any background on why KRSA is doing this? Exactly what are they using to justify this change in management, and what is their true objective? Is this just something they are throwing out there to benefit their own allocations, or is it actually backed up with some science? I take it this has Bob Penny's and Ted Stevens' fingerprints somewhere.

    If there is a best contact at the BOF for opposing this, please let us know what/who it is. I plan on sending my opposition of KRSA's proposal 132 asap.

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    Default address

    You can send comments to

    ATTN: BOF Comments
    Alaska Department of Fish and Game
    Boards Support Section
    P.O. Box 115526
    Juneau, Alaska 99811-5526
    Fax 907-465-6094

    Sorry I did not include this with the first post

    I believe this is really about single species management for the Kenai River. The goal of KRSA from day one is to restrict the management of the sockeye fishery to put more chinook salmon into the river.

    However, when there are goals then KRSA is blocked by ADF&G because they manage for both sockeye and chinook goals. Since the Brown ruling the ADF&G Commissioner can use his emergency order authority to override management plans that have fixed closures in them.

    This was because the legislature knew that to tie the hands of the on ground managers was a failed approach from watching how the federal government managed. So the Commissioner of ADF&G has the authority to adjust in-season to the changing conditions on the grounds and to be held to the standand of meeting escapement objectives. The State of Alaska put escapement first to make sure high sustained yields could be realized for everyone. Not managing to the sockeye goals is bascially saying that production does not matter for sockeye salmon. For all the sockeye salmon fisherman - personal use and sport this proposal is a threat to your fisheries in the long term. But more important it is a threat to foundational structure of Alaska fishery management.

  4. #4

    Default A few questions

    Guys, I'm still unsure how to read the proposal and what it means. It is a very awkward sentence.

    What is KRSA proposing exactly?

    My guess so far, is that KRSA is asking for no EO's when the escapement numbers get to the high end? Is that what they are asking for?

    So basically if the sockeye run were near it's upper end, then they would prefer no EO to open commercial fishing and essentially net more kings while cleaning up on the sockeye?

    Do I have this right?

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    Default

    I think you're on the right track Sockey Charlie.

    I've asked the KRSA to clearify, and state exactly what their goal is with their proposal, and why they think current methods of management aren't working. They haven't responded. I don't see any biology or science backing up their proposal, so I have to question their true motives.

    I could be wrong, but given the history of KRSA, it appears the proposal is aimed at single species management (sport caught chinooks) at the expense of another species (commercial caught sockeye). At least that is what will happen if the proposal goes through. We know we must manage both. Not an easy thing to do, and not always perfect, but ADF&G's EO's give us the flexibility to do the best we can. It works for the most part, and I really see no reason to change it. Everyone always gets their fish, adequate escapements seem to happen, adequate harvests seem to happen, and the current yields are proving sustainable. We need ADF&G's EO's. I doubt KRSA's proposal, which seems to ignore over-escapements, would result in better management...in fact quite the contrary. That is scarey.

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    Default KRSA comments posted on BOF board support section

    The Board of Fisheries committee on Upper Cook Inlet Management Plans has its white paper posted on line and also posted are nine public comments.

    The link is http://www.boards.adfg.state.ak.us/f...citeleconf.php

    In regards to the KRSA proposal prioritizing prescribed windows over the upper end of the escapement goals, read through their comments, posted here as a courtesy, in two sections.

    Section One:


    KRSA Comments on 12/21/2006 Upper Cook Inlet Working Group Issues

    Thank you for the opportunity to provide input on the 12/21/02 white paper entitled Management Plans and Issues prepared by the Upper Cook Inlet Working Group.
    We offer the following comments and suggestions in the interest of continuing efforts by the working group to develop a comprehensive summary of issues that warrant consideration at the next Cook Inlet Board of Fisheries Meeting. We believe there are a number of significant issues that have been over looked by the working group. To ensure Board members are presented a balanced and complete review of the issues we offer issue statements for inclusion in the subsequent and final draft of this document.
    Management Plan Principles
    The current suite of UCI management plans is complex because the needs and values inherent in Upper Cook Inlet fishery management are complex. These plans have been designed to ensure sustainable escapement levels for a wide variety of salmon species and stocks while balancing fishery needs and values among a broad spectrum of fishery uses. Rather than seeking to maximize the harvest of any single species or stock in any one fishery, the plans seek to optimize net fishery benefits among all users This balancing necessarily involves tradeoffs among competing objectives.
    UCI fishery management plans represent a comprehensive approach to providing conservation and allocative direction to Department management staff. There are several important principles that bear mentioning concerning the plans:
    • Although structured to address specific fisheries the individual plans are not stand alone regulations. Rather they are interrelated with respect to fishery resource conservation. To adjust one is to likely affect another.
    • Plans were developed with stakeholder involvement and collectively represent delicate and agreed upon balances among user groups with respect to allocation of fishery resources. To address “issues” in a plan by plan manner is to ignore and disregard the agreements between users that lead to the current allocation structure present among all the plans.
    • Department desire for flexibility in management is understandable when addressing only conservation oriented issues; however, allocative decisions, inexorably entwined into the plans, require specific direction be given to managers to protect them from claims of favoritism or bias. Department managers are charged with managing fishery stocks in a sustainable manner and in accordance with Board adopted allocation plans. Management plans by their nature tend to reduce flexibility, often because fishery managers are removed from making decisions that are allocative in nature. Explicit and detailed plan guidance to the fishery managers protects them from undue allocative pressures and focuses these allocation issues on the Board of Fisheries where they belong.
    General Comments Regarding Draft Issue Statements
    We are particularly concerned with suggestions that UCI management plans are unnecessarily complex, inflexible, and difficult to implement. We note several issues with current plans that warrant consideration, including clarification of potentially competing priorities. However, suggestions that these plans are somehow “broken’ and in need of wholesale changes are unfounded. In the past, “flexibility” for commercial fishery management and in-season proposals to manage outside of the plans has effectively translated into shifts in fishery allocation in favor of the commercial sector at the expense of escapement and in-river opportunities.
    We are troubled by the apparent failure of the issue paper to consider the full spectrum of issues, particularly as they relate to the sustained opportunity for in-river sport and personal use fisheries. Current issues are framed solely in terms of increasing commercial fishery “flexibility” which will inevitably exacerbate current in-river fishery and chinook escapement problems. This raises substantive questions regarding the depth and breadth of information that has been provided to the Working Group to date. To cover more fully the balanced spectrum of issues we offer additional issue statements for inclusion in the final draft.
    Current UCI Management Plans have proven to be very effective in providing for the conservation and sustainable harvest of UCI salmon. To read the presentation of issues within the white paper the reader would miss the important facts:
    • Plans have protected minimum escapements for virtually all UCI stocks in every year (with the Yentna exception).
    • Commercial fisheries have sustained consistently high harvests, ranging from 2.2 million to 5.2 million over the recent 5-year period.
    • The 2002-2006 average commercial harvest of 3.7 million sockeye per year is 70% greater than the preceding 5-year average.
    • The 2004 and 2005 commercial sockeye harvests of 4.9 million and 5.2 million were the largest in the last 15 years.
    • Continuing moderate to large sockeye returns have proven fears of stock collapse due to large escapements to be overblown. In fact, larger escapements in the Kasilof have resulted in record returns to that system.
    Windows are not new and have been used in fishery management systems since statehood (1959). In early regulatory language weekly fishing schedules provided for on and off (windows) commercial fishing. These periods of closures (windows) were intended to allow fish to escape into river systems and were essential in the rebuilding and sustaining of Alaskan salmon resources.
    The institution of fishery windows has for the first time addressed the need for consistent and predictable in-river opportunities for in-river users. In addition to their conservation value, windows now serve to facilitate the delivery of fish to sport and personal use fishermen over the course of the run/season.
    These management plans provide necessary and appropriate guidance for in-season management consistent with conservation and allocation priorities identified by the Board of Fisheries. Past experience has repeatedly demonstrated that without this guidance, commercial fishery interests will aggressively pressure the management system to maximize their harvests at the expense of sport and personal use fisheries and with significant risk to minimum escapement needs.
    The allocation implications of any proposed changes in the management plans need to be carefully considered. Even seemingly minor changes can have significant allocation effects. Many changes can have unintended allocation implications under different run size and timing combination that may occur from year to year. Any proposed changes in these plans warrant a comprehensive and systematic evaluation for a variety of fishery situations to ensure changes to address one management issue won’t cause other problems somewhere down the line. Effective evaluations will require clear descriptions of assumptions and cause-and-effect relationships.
    These plans reflect the collective wisdom of a series of Fishery Boards including current Board members as well as a generation of commercial and sport fishery managers. Plans have evolved over time to incorporate new information and adapt to different fish run and fishery situations. During each board cycle, additional refinements are considered to address new developments and unforeseen situations. Effects of changes are evaluated in light of both recent and past fishery situations.
    Recent forecast problems for Kenai sockeye highlight the need for precautionary management to ensure that forecast and fishery errors do not cause low escapements which result in future yield, management, or conservation problems. While the future effects of escapements in excess of goals are a subject of continuing uncertainty for some stocks, no one disputes that underescapement can drastically reduce future yields. Many of the early season fishery limitations contained in existing management plans were expressly designed to ensure that fisheries would not erroneously overharvest a run in years when the forecast was an overestimate or run timing was early. Plans are designed to ensure that management errors do not come at the expense of the fish and future yields. Recent years have seen returns consistently greater than forecast which can make it difficult for the commercial fishery to access the additional fish while also balancing other management needs throughout the system. However, the situation could abruptly reverse where consistent over-forecasts result in excessive early harvests which would shift the balance of the conservation burden onto inriver fisheries.
    Results of ongoing research programs and updates of old analyses with recent data have the potential to drastically change the context for considerations of UCI management plan issues between now and the UCI Board meeting. Attempts to narrow or resolve current management issues without this new technical information are premature. For instance, updated escapement goal analyses of Kasilof sockeye appear likely to support larger escapement goals which would mean that the current management plan provides ample opportunity to access the harvestable surplus. Ongoing Kenai sockeye sonar validation research will clarify uncertainty and potential error in escapement estimates that could help explain and correct the high rate of forecast error. Improved methods for stock apportionment of the commercial fishery harvest could help explain chronic low returns of Yentna sockeye, particularly if this stock is more heavily impacted in setnet fisheries than previously believed.
    Central District Drift Gillnet Fishery Management Plan

    General Comments
    The issue paper highlights the effects of Central district drift gillnet fishery constraints to protect Northern District sockeye and coho stocks. During the 2005 UCI Board of Fisheries meeting, the management plan was revised, with the agreement of the Commercial Fishery stakeholders, to provide for additional early drift net fishery time to address problems of large escapements into the Kenai and Kasilof Rivers while attempting to afford conservation measures for sockeye stocks in Northern Cook Inlet.. However, this option was not effectively utilized by commercial fishery managers and it is unclear why not. The issue paper incorrectly characterizes the problem as a product of restricted commercial fishing time. Rather, the issue is one of not effectively utilizing the allowable fishing time granted within the plan.

    Additional Issues
    We also note an apparent oversight in section 5 AAC 21.353 (a)(2)(B) regarding season dates. The current text in (B) provides direction “from July 16 through July 31.” Part (C) provides direction “from August 11 until closed by emergency order.” The plan currently provides no direction from August 1 through August 10. To address this oversight we recommend the addition of a third issue statement.
    Issue 3:
    The plan currently provides no direction regarding commercial fishing time from August 1 through August 10. Section B should apparently read “from July 16 through July 31 August 10”. Alternatively, the plan could clarify that no drift net fisheries are currently authorized from August 1 through August 10.
    Northern District Salmon Management Plan

    General Comments
    The issue paper highlights the need for clarification of which Kenai goals take precedence in years where every goal cannot be met. This is primarily a Kenai sockeye management plan issue rather than a northern district issue. The northern district plan directs that achievement of the lower end of the Yentna River OEG shall take priority over not exceeding the upper end of the Kenai escapement goal. Consistent with the yield and conservation risks of falling below the lower end of the Yentna, it has always been clear that the Yentna goal takes precedence over any upper Kenai escapement goal, be it the OEG or the run-strength-based in-river goal. The source of confusion regarding the precedence of the Yentna goal is not apparent.
    The broader question concerning poor returns of Northern District sockeye is why this run is performing poorly while returns of Kenai and Kasilof remain strong. More typically, different stocks within a region co-vary, increasing and decreasing in tandem due to common environmental effects in freshwater and the ocean. Potential explanations for this disconnect might include differences in local freshwater effects in the Susitna, differences in ocean survival, random chance, inaccuracies in the Yentna sonar counts, or underestimates of Susitna sockeye harvest in UCI driftnet and setnet fisheries. ADFG has implemented extensive research to address this question and results will have significant implications to management of Northern district stocks. Given the pending research results it is premature to make changes in this plan until the cause of the poor performance within the Yentna is better understood and more clearly articulated into a management objective.

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    Default KRSA comments continued

    Section Two of KRSA's comments

    Kenai River Late-Run Sockeye Salmon Management Plan

    General Comments:
    The working group identified several significant issues with interpretation of this plan. In addition, we highlight the need to clarify sockeye priorities relative to 5 AAC 21.359 (a) directs that the department shall manage the late-run Kenai River chinook salmon stocks primarily for sport and guided sport uses. Despite this direction, management of commercial sockeye fisheries typically results in a de facto 50% or greater allocation of late-run Kenai River chinook salmon to the commercial fishery. The commercial harvest share exceeds 50% in years of large sockeye returns. In contrast, sockeye which are designated for commercial fishery priority are typically harvested at about 80% by the commercial fishery. We can well imagine the objections of the commercial fishery if the sport and PU fishery harvest of sockeye rose to or exceeded the same 50% or fewer shares the sport fishery receives of the kings. Commercial fishery management has failed to consider alternatives for correcting this situation including different net configurations and area restrictions. Some BOF have previously expressed a desire to tell the managers what goals to manage rather than how to manage to meet the goals. However, specific allocations of sockeye and chinook among the various fisheries have never been directly identified by the Board.
    A second over-looked issue concerns the need to recalibrate the OEG range and in-river goal range based new data on in-river sockeye fisheries at recent harvest levels. Kenai goals are based on biological spawning escapement goals backed down to the sonar based on assumptions for inriver harvest in sport and PU fisheries. However, in-river harvest has been significantly greater than previously assumed, particularly when large numbers of sockeye are available in the river. As a result, even when the sonar goals have been exceeded, escapement targets have often been met. Much of the hand ringing over the purported evils of “over-escapement” has been groundless because spawner escapement goals may not be exceeded even when enumeration goals are. Reconciliation of the relationships among spawning escapement goals (500,000-800,000), the OEG (500,000-1,000,000), and in-river goal ranges (graduating over 650,000 to 1,100,000 million depending on run size) with current data on in-river harvest expectations at different run sizes, will clarify the real significance of the issue of conflicts among the tiered system of Kenai goals and will likely resolve some recent concerns. Management plans for affecting Kenai late run sockeye should also recognize the utility and power of the in-river fisheries for management of escapement. As with king salmon allocation issues, the Board might also wish to consider more explicit direction on the appropriate allocation of sockeye among commercial, sport, and personal use fisheries.
    Additional Issues:
    There appear to have been two important issues over looked in the initial draft. We recommend the following issues and explanatory language is added to the document:
    Issue 4:
    Clarify sockeye priorities relative to 5 AAC 21.359 (a) which directs that the department shall manage the late-run Kenai River chinook salmon stocks primarily for sport and guided sport uses. Despite this direction, management of commercial sockeye fisheries typically results in a de facto 50% or greater allocation to the commercial fishery. How should adjustments to existing plans that diminish this directive be addressed?
    Issue 5:
    The current OEG range and in-river goal range need to be recalibrated and reflect updated in-river sockeye fisheries harvest levels. Kenai goals are based on sustainable spawning escapement goals backed down to the sonar based on assumptions for inriver harvest in sport and PU fisheries. However, in-river harvest has been significantly greater than previously assumed, particularly when large numbers of sockeye are available in the river. As a result, even when the sonar goals have been exceeded, escapement targets have often been met. Much of the hand ringing over the purported evils of “over-escapement” has been groundless because spawner escapement goals may not be exceeded even when enumeration goals are.

    Kasilof River Salmon Management Plan

    General Comments:
    The current draft issue paper entirely overlooks issues of poor in-river fishery opportunities and excessive Kasilof chinook impacts caused by intensive Kasilof area setnet fisheries implemented to avoid exceeding the OEG in the face of continuing large Kasilof sockeye returns. Nearly continuous (by stepping outside the Board approved management plan) commercial fisheries at or near the Kasilof mouth from late June through much of July have drastically reduced what historically was a productive and popular Chinook sport fishery. The intensive commercial fishery has been prosecuted in spite of a lack of data on Kasilof Chinook harvest rates or escapements which appears inconsistent with the Sustainable Salmon Fisheries and Escapement Goal policies.
    A second overlooked issue concerns the continuing harvest of significant numbers of Kenai Chinook in Kasilof sockeye setnet fisheries and the contribution of that harvest to the disproportionate harvest share of Kenai Chinook in the commercial setnet fishery relative their sport fishery priority identified in the Kenai River late-run King Salmon Management Plan (5 AAC 21.359). Kasilof commercial sockeye fisheries are being managed to avoid exceeding the upper OEG without regard for their effects on the realized allocation of Kenai king salmon to commercial fisheries often in excess of 50% of the total harvest.
    The problem in the Kasilof is not that the current management plan does not provide adequate flexibility to avoid exceeding the upper end of the OEG, but rather that the upper end of the OEG appears to be too low. We note that the current OEG is 50,000 greater than the recommended BEG to provide management flexibility in meeting Kenai escapement needs. The Kasilof has continued to produce very large returns despite consistently exceeding BEG and OEG numbers. These large escapements, rather than reducing run size as the OEG assumes, have instead produced more even larger runs. It now appears that results of past escapement goal analyses have been biased low by a lack of data points at larger escapements. Management for these biased escapement goals would have had the effect of sacrificing significant fishery yield over the years. If confirmed by the updated escapement goal analysis, all or most of the Kasilof management issues identified by the Working Group are moot.
    Additional Issues:
    There appear to have been four important issues over looked in the initial draft. We recommend the following issues and explanatory language is added to the document:
    Issue 5:
    Nearly continuous (by stepping outside the Board approved management plan) commercial fisheries at or near the Kasilof mouth from late June through much of July have drastically reduced what historically was a productive and popular in-river chinook salmon sport fishery.

    Issue 6:
    The intensive commercial fishery has been prosecuted in spite of a lack of data on Kasilof chinook harvest rates or escapements which appears inconsistent with the Sustainable Salmon Fisheries and Escapement Goal policies.
    Issue 7:
    Harvest of significant numbers of Kenai chinook in Kasilof sockeye setnet fisheries contribute to the disproportionate harvest share of Kenai chinook in the commercial setnet fishery relative their sport fishery priority identified in the Kenai River late-run King Salmon Management Plan (5 AAC 21.359). Kasilof commercial sockeye fisheries are being managed to avoid exceeding the upper OEG without regard for their effects on the realized allocation of Kenai king salmon to commercial fisheries often in excess of 50% of the total harvest.

    Issue 8:
    The current Kasilof River sockeye salmon escapement goal, and the attendant OEG, may be too low. Large escapements into the Kasilof, rather than reducing run size have instead produced above replacement resulting in even larger returns. Concern about over escapement and lost commercial harvest opportunity may be misplaced.

    Upper Cook Inlet Personal Use Salmon Fishery Management Plan

    General Comments:
    The issue presented within the document addresses the inability to use the existing Personal Use fishery to assist in attaining management goals. Oddly, the notion of extending Department authority to adjust PU bag limits, and time and area restrictions in season, in an effort to harness the harvesting power of the PU fishery as an asset in management was rejected in 2005. Expanding the department’s management authority to extend the Kenai PU fishery after July 31, providing for incremental increases in the PU bag limit from 25 to 40 fish, and opening of additional dipnet areas based on abundance will all help management cope with large returns. Growth of interest and participation in the PU fishery provides the opportunity to more fully utilize this fishery to regulate spawning escapements in years of large inriver returns. This would be an added management tool to control large escapements which might exceed goals. It has the added benefit of meeting consumptive needs of Alaska households.
    Additional Issues:
    There appears to have been one important issue over looked in the initial draft. We recommend the following issue and explanatory language is added to the document:
    Issue 2:
    The Department lacks the necessary authority to make inseason adjustments to bag and possession limits as well as time and area to make full use of the harvest potential of this fishery to assist with the attainment of management goals.

    Kenai King Salmon Management

    General Comments:
    The working group did not identify management issues regarding king salmon but significant issues warrant consideration. It is unclear if this is beyond the scope of the working group’s charge and whether other issues besides those identified in the white paper are expected to receive significant BOF attention.
    For early run King salmon for instance, there are significant questions regarding the value and need for the slot limit, particularly given the reduction in the escapement goal range. The combination of the slot limit and bait restrictions in the early run fishery significantly increase the chances of exceeding the upper end of the escapement goal range. It also appears that the slot limit may be concentrating harvest on fish just under the slot size, thus exacerbating rather than balancing size selective fishery effects as originally intended.
    We are also continuing to observe very low harvest rates of small size classes and disproportionate catch and release mortality of these smaller fish. New data is also available for correcting confusion on Kenai jack sizes observed at the 2005 UCI Board meeting.
    Additional Issues:
    We suggest the following two issue statements be incorporated under a new section entitled Kenai King Salmon Management.


    Issue 1:
    Current slot limit affecting harvest of early run chinook salmon may unnecessarily restrict harvest opportunity in the sport fishery given that the management target (escapement goal range) has been reduced.

    Issue 2:
    Current restrictions on the harvest of jack salmon do not allow for a harvest of this size and age class proportional to abundance and is therefore unnecessarily limiting harvest opportunity.

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    Default not true representation of UCI

    The posts which copy KRSA positions are not really about this thread. Most of their issues are either mistated or flat out wrong but I do not want this thread hijacked with discussions of jacks and slot limits.

    I would like people to focus on the idea of fixed closures in any fishery that ignores escapement goals which is what the KRSA proposal does.. They are giving up escapement goals management to meet some allocation agenda. That approach took the Pacific NW down the path of reduced returns and will do the same for Alaska. Is that what people want?

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    Default Not what I want to see

    Nerka, that proposal and a few others are ones our org will be sending comments in on. (we oppose that one for reasons you mentioned) Thanks for getting the word out. I'd also like at some point to bring up some others that concern me, as well as have a discussion on the KAFC proposals.
    Regards,

  10. #10

    Default Devils Advocate

    So to play devils advocate for a moment. This question comes to mind after reading all this....

    Why even have a management plan in place if your not going to follow it and give one person (or group of persons) ultimate EO control to override the plan at any time?

    It seems to me that KRSA just wants to follow the current management plan without constant EO's to disrupt it.

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    Default try to answer

    Quote Originally Posted by Sockeye Charlie View Post
    So to play devils advocate for a moment. This question comes to mind after reading all this....

    Why even have a management plan in place if your not going to follow it and give one person (or group of persons) ultimate EO control to override the plan at any time?

    It seems to me that KRSA just wants to follow the current management plan without constant EO's to disrupt it.

    The legislature has in statue the emergency order authority of ADF&G. That cannot be diluted by the Board of Fish by directives in the management plan. That was upheld by Judge Brown in a court case a couple of years ago. So management plans should not have restrictions on the emergency order authority of ADF&G written in them - it is illegal to do so.

    Relative to allocation the Board of Fish can allocate fish to various user groups that can be written into management plans. They can define a portion of the harvest for each group, they can create in-river goals like the Kenai River sockeye salmon in-river goals which has an allocation built into them, they can raise the chinook salmon goals as long as they are sustainable, they can make methods and means more liberal for fisherman - PU limits, sport fish limits to achieve an allocation objective.

    What KRSA is asking is the Board to tell the ADF&G not to manage for the upper end of the goals and that ADF&G cannot use its emergency order authority to manage for the upper end of the goals. This is probably illegal, not good fisheries management, and puts allocation ahead of sustainable resource management.

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    Talking The devil is in the details. . .

    Quote Originally Posted by Sockeye Charlie View Post
    So to play devils advocate for a moment. This question comes to mind after reading all this....

    Why even have a management plan in place if your not going to follow it and give one person (or group of persons) ultimate EO control to override the plan at any time?

    It seems to me that KRSA just wants to follow the current management plan without constant EO's to disrupt it.
    SC. . . there is a management-plan-for-escapement-goals in place, which KRSA would like to see playing hind-tit to a fish-in-the-river-management-plan that would ignore escapement goals in order to feed Bob Penny's "economic-engine-running-hard.*"

    KRSA rejects following a "management-for-escapement-goals" plan, of which EO authority is a critical tool; KRSA wants rather a "management-for-money" plan, which totally disregards escapement goals.

    Keep in mind that KRSA is a parasite—owing its foundations and continued existence to the Bob Penny/Ted Stevens connection, and KRSA's self-confessed agenda is the demise of Cook Inlet's gill-net industry**. Check out the newly-formed Kenai Area Fishermen's Coalition, which is, in contrast to KRSA, a grass-roots organization. .

    *“There isn’t a single thing your committee or this legislature can do to have more economic impact and strengthen the state than one single thing, now that is increase the availability for sportfishing in Cook Inlet; it will double in value in two years. You take a pond here and put catfish in it, the people are gonna show up. Take a part of the channel and put king salmon in it, I assure you the people are gonna show up. . . . That the way the fisheries manage [sic] should be turned around one-hundred eighty degrees in Southcentral . . . That’s the way the fishery’s got to be changed . . .
    . . .if you wanna look at something that will really increase the economic impact in our entire state, make more fish available to the public! Believe me, the tourists will come, . . “The economic value of the land along the Kenai River privately held from Skilak to Ames bridge; three years ago the assessed value to the borough of only the privately owned land was three hundred and thirty-five million dollars. As Mr. Busey just said to you, it’s increased since then. Now, I know it’s well over five-hundred, but we haven’t seen what the borough’s assessed it. But gentlemen and ma’m, all that assessment in value came from one reason; cause there’s fish in the river. And you put the fish in the river, and you put the fish in the inlet, and you give the opportunity for the public you’ll see the economic engine run hard.”
    —Bob Penny, testifying with KRSA board members to House Committee on Economic Development and Trade/ The Economics of Sportfishing, April 24, 2007

    **"[KRSA] disagree[s] with present harvest methods (read: the gill-net industry) that allow[s] the by-catch of kings and silvers. . . We want to work with all user groups to find new harvest methods. . ." —Ron Rainey, ADN Compass, 12/16/04 (Note: It has been nearly three years since Mr. Rainey made that statement, and with whom, since then, has KRSA worked with to find those new harvest methods? Actually, the only solution KRSA has offered in the pursuit of their agenda is total reallocation of the entire fishery.)


  13. #13

    Default Calculated misrepresentation of a KRSA proposal

    Quote Originally Posted by Nerka View Post
    They are giving up escapement goals management to meet some allocation agenda.
    This is a not the intent or effect of the KRSA proposal. This proposal recognizes that there are a complex of biological and allocation objectives to Cook Inlet fishery management and seeks to shape an optimum balance among these objectives.

    Virtually every proposal for UCI fishery management has both a biological and allocation element. An argument by Nerka for strict escapement goal management of Kenai and Kasilof sockeye is no different. There is a biological yield element - fish passed to escapement in excess of the habitat capacity can be harvested without long term consequences to future yield. There is also an allocation element. Arguing to implement rigid escapement goal management for Kenai and Kasilof sockeye would essentially be arguing to maximize allocation of sockeye and kings to the central district commercial fisheries.

    Maximizing the commercial sockeye allocation comes at the expense of escapements of the less productive sockeye runs (e.g. Susitna sockeye), runs without established escapement goals (e.g. Kasilof kings), northern district commercial, sport and PU fisheries, Kenai and Kasilof sport and PU fisheries, and the allocation priority for kings to the sport fishery.

    The KRSA proposal is an attempt to optimize long term yields for multiple species, stocks, and fisheries throughout Cook Inlet. It uses fishery windows to ensure adequate passage of all species and runs through mixed stock commercial fisheries in the central district. Windows provide both biological and allocation benefits. Windows will increase the likelihood that escapement is adequate to meet minimum goals for all runs including Yentna sockeye. Windows will ensure significant escapement of runs without escapement goals including Kasilof Kings. Windows will pass significant numbers of sockeye into the northern district to fuel fisheries there. Finally, windows will provide a consistent supply of sockeye and kings for fisheries in Kenai and Kasilof rivers.

    In-river fisheries can be severely affected by long periods of continuous net fisheries along the beaches. In the last plan revision, a mandatory window was established on Fridays to provide fish for the weekend PU and sport fisheries. This is a particularly big deal for folks driving down for a weekend of fishing. When people are provided with a predictable fishing opportunity, we have seen that they can very effectively catch a lot of sockeye. This provides a powerful management tool for regulating escapement to desired levels. In fact, the in-river sockeye fisheries have proven capable in some years of limiting spawning escapements to desired levels even when in-river sonar goals have been exceeded. However, the net effect of the windows is an implicit reallocation of a greater share of the sockeye harvest to PU and sport fisheries.

    This issue largely boils down to a question which management objectives do you prioritize in years where you can’t meet them all. It’s more than just about escapement goals because the current system has by default consistently resulted in some escapement goals being met and others not being met or never established in the first place.

    If your intent is to maximize commercial sockeye harvest and allocation, then you would manage primarily for escapements that provide maximum yields of the strong sockeye stocks in the Kenai and Kasilof. You would fish hard in the commercial fishery once it was clear that the minimum Kenai and Kasilof escapement needs would be met. You would live with underescapement of the less productive Susitna sockeye because the Kenai and Kasilof sockeye yield benefit outweighs of the cost of reduced yield from the Susitna. You would accept reduced opportunity and allocation of kings and sockeye into northern district, and Kenai/Kasilof in-river PU and sport fisheries. This is the historic practice in Cook Inlet fishery management and essentially prioritizes the value of central district commercial fishery over the value of northern district, PU, and sport fisheries.

    If your intent is to avoid biological and yield effects of consistently falling short of minimum escapement goals and to increase sharing of harvest and allocation among all commercial, sport, and PU fisheries, then you would consider a more balanced optimization strategy along the lines of the KRSA proposal.

  14. #14
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    Wink Optimization for whom?

    Quote Originally Posted by Bfish View Post
    If your intent is to avoid biological and yield effects of consistently falling short of minimum escapement goals and to increase sharing of harvest and allocation among all commercial, sport, and PU fisheries, then you would consider a more balanced optimization strategy along the lines of the KRSA proposal.
    Bfish: Why should anyone believe that KRSA wants a "more balanced" optimization strategy when by their own admission KRSA opposes Cook Inlet's gill-net industry because of the so-called "by-catch" of kings and silvers?—their words, not mine.

    Why should anyone believe that KRSA wants a "more balanced" optimization strategy when by their own admission KRSA simply wants more fish in the river to fuel Bob Penny's "economic engine, running hard"?—their words, not mine.

    As I see it—and feel free to enlighten me/us otherwise—KRSA is the voice/tool of Bob Penny and would like to see the demise/destruction of Cook Inlet's gill-net industry for the purpose of putting more fish in the river, resulting in:

    a. Narrowing of area's economic base
    b. Increased dependence on tourism, which is vulnerable to rising energy prices
    c. Foregone harvestable yield of the resource
    d. Users who buy salmon denied access to resource
    e. Destruction of ADF&G's ability to manage for (maximum) sustained yield to benefit of all Alaskans
    f. Wildly fluctuating/undependable sockeye runs
    g. Further degradation of angling experience
    h. Increased pollution, habitat destruction
    i. Further debasement of resident lifestyle
    j. Increased property values.

    Give me some help here. . .

    John Nelson
    Soldotna


  15. #15

    Default John

    I don't speak for KRSA - I was merely trying to represent the biological and allocation effects and implications of the proposal in question as I see them from the perspective of my working relationship. Perhaps balance is too loaded a word - maybe I should have used distributed effects instead. Ray

  16. #16
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    Default Bfish misrepresents intent

    Bfish, the proposal is very clear. The upper end of escapement goals - including sustainable goals are to have a lower priority than fixed closures in the fisheries.

    ADF&G has done a good job of balancing escapements into the various river systems of UCI. Runs have sustained high yields for all species, including the Susitna River ( production drops in that system are not due to harvest issues - rather to pike, beaver dams, and other in lake conditions).

    Your comments about commercial sockeye management comes at the expense of other stocks is not supported by data. If one looks at the in-river goals for Kasilof and Kenai sockeye they have a built in allocation. Second, the PU fishery has no allocation and thus has been allowed to expand from catches of less than 80,000 fish to over 300,000 fish.

    Your assumptions about adverse impacts on Kasilof chinook are not supported by any data. The mark/recapture estimates from ADF&G do not support your conclusion and those runs have maintained themselves in over 40 years of state management. Chum, coho, and pink salmon stocks are healthy and there are no stocks of concern listed for UCI, including the Sustina drainage (see recent Board of Fish paper by ADF&G)

    Your position on fixed windows providing fish to the fisheries is again without foundation. Fixed windows do not mean fish move during those time periods, especially fish moving to the northern district.

    However, what you fail to recognize is that ADF&G uses emergency order authority to reduce exploitation rates by restricting areas and times. They also increase fishing time when necessary - they do not howerver ignore other stocks and species - to imply such is a mischaracterization of ADF&G management. It is truely adapative management which is the standard of good fisheries management today.

    Finally, you have restated exactly what the proposal does - it put allocation of the resources above management of the resources. That is maybe what they do in your state but Alaska has shown that escapement goal management is the foundational strength necessary to maintain runs for all users.

    Here is a question - where are user needs not being met in UCI - the sport fisheries on sockeye, chinook, pink, and coho salmon are being met. There are no widespread closures in these fisheries. Harvest rates are good for Kenai and Kasilof chinook and escapements are being met. Pink and chum salmon are essentially not harvested by the sport fishing public or the commercial fishery (exploitation rates are in the teens). PU fisheries are growing and harvests are increasing. In fact, most PU fisherman do not take the fish available to them - see ADF&G report on the PU fishery.

    So what allocation goal are you trying to meet or is the true goal to reduce the commercial fishery in UCI to a level it cannot survive. Bob Penny has stated that is his goal.

  17. #17
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    Default data?

    I did not study KRSA's proposal, but I did read through all of the above once. I see very clearly some of the reasons for KRSAs proposal. More fish available to sports fishers. And no study is needed to understand the "data" of there's a hell of a lot more sports fishers than there are comm fishers that want these resources. Allocation priority based on the user groups' fair share seems fair enough to me.

    ADF&G has done a great job doing what they've been asked to do. But they aren't being asked to do what would benefit the most people, nor the most resources. The KRSA proposal seems to ask for that sort of change in priority. It's about time. Management for the sole purpose of keeping the "comm fish economic engine" running hard (and harder with the EOs) is outdated based on the demands of today's users.

  18. #18
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    Default

    Quote Originally Posted by Charholio View Post
    And no study is needed to understand the "data" of there's a hell of a lot more sports fishers than there are comm fishers that want these resources. Allocation priority based on the user groups' fair share seems fair enough to me.

    ADF&G has done a great job doing what they've been asked to do. But they aren't being asked to do what would benefit the most people, nor the most resources.
    Nor is any study needed to determine that they are way more people who use the commercially harvested resource than use the sport harvested resource. You're missing that the commercial harvesters are not the end users of the resource. The real user of the resource in these fisheries are the hundreds of thousands of Alaskans and millions of Americans who get their fish from the market and restaurants. They (at least the Alaskans) have a legitimate claim to the resource as well. In that case, I would say that allocation priority based on user groups' "fair share" is already pretty well balanced, if not skewed in favor of sport fishing interests. (Said as someone who sport fishes the Kenai River.)

    Really, charholio, what would "benefit the most people"? Can you honestly, with a straight face, say that reallocating fish away from commercial harvest to a sport harvest would benefit the most people? Or would it just benefit the most sport fishermen? Do you see the difference??

  19. #19

    Default OK, I'll play (but I'll probably regret it in the morning)

    Quote Originally Posted by Nerka View Post
    ADF&G has done a good job of balancing escapements into the various river systems of UCI. Runs have sustained high yields for all species, including the Susitna River ( production drops in that system are not due to harvest issues - rather to pike, beaver dams, and other in lake conditions).
    The Susitna has not met the minimum escapement goal for 5 of the last 7 years. If they're not as productive, then you can't fish them as hard. If you do, then chronic escapements will be the result.

    Quote Originally Posted by Nerka View Post
    Your comments about commercial sockeye management comes at the expense of other stocks is not supported by data. If one looks at the in-river goals for Kasilof and Kenai sockeye they have a built in allocation. Second, the PU fishery has no allocation and thus has been allowed to expand from catches of less than 80,000 fish to over 300,000 fish.
    The current managment plans result in a de facto allocation among all the fisheries which is the net result of the complex of regulations built into the plan. As a result people are always advocating for regulatory changes that shift the numbers in their favor. Obviously, if a change results in more sockeye taken in the commercial fishery, there are fewer available to the other fisheries. I've not seen an explicit assignment of allocation shares by the Board of Fisheries to the various fisheries - might be interesting to ask for one. It is always a difficult question of how to handle changes in fishery demands as the world continues to turn. With the increasing population in southcentral and the popularity of the PU fishery, the demand from that end continues to grow. Cook Inlet has a long history of fishery evolution over time - previously these were among different segments of the commercial fishery (decreases in west side and northern district fisheries, reductions in the drift fishery). When is it appropriate to make a change in actual or implied allocations in response to changing fishery demands? That is a BOF question - glad I don't have to take that one on.

    Quote Originally Posted by Nerka View Post
    Your assumptions about adverse impacts on Kasilof chinook are not supported by any data. The mark/recapture estimates from ADF&G do not support your conclusion and those runs have maintained themselves in over 40 years of state management. Chum, coho, and pink salmon stocks are healthy and there are no stocks of concern listed for UCI, including the Sustina drainage (see recent Board of Fish paper by ADF&G)
    Well, Kasilof kings haven't gone extinct but does anybody know whether their escapements are at or near MSY levels? There are clearly alot of Kasilof kings being taken in the Kasilof setnet fishery in big run years. The mark-recapture studies tell us that's alot larger population than maybe we previously thought but don't tell us whether current escapement provides for maximum or just sustainable yield. In the face of uncertainty, doesn't the burden of proof lie on the side of precautionary management as per the sustainable fishery policy?

    Quote Originally Posted by Nerka View Post
    Your position on fixed windows providing fish to the fisheries is again without foundation. Fixed windows do not mean fish move during those time periods, especially fish moving to the northern district.
    On average, fixed windows clearly pass fish. They have real effects - that's why the commercial folks object to them so strongly. In some years and weeks, windows pass more than others. For instance, this year the run was late, the fish were booking and so plenty of fish made it into the Kenai for the inriver fisheries windows or no windows. However, in more normal run conditions there is a direct relationship between the windows and the escapement. Of course, that's how the fishery is regulated - the Fox man watches the escapements and turns up or down the fisheries depending on what is getting through. The problem with short one day or unfixed windows has been that they can be configured so as not to make much of a difference to either the commercial or inriver fisheries. When the fish are traveling in a more normal pattern, a couple days of setnet fishing will clean the beaches and it usually takes several tides to reload. A short window will then just reload the commercial fishery and not pass much inriver. At the same time a window earlier in the week doesn't do as much for the weekend sockeye fishers in the lower Kenai - the Friday fixed window more times than not makes sure there are some fish in the river if there are any around. With the northern district, the windows obviously don't have the same effect - here the result is just passing more fish past the senet fishery so that the northern fisheries get a share.

    Quote Originally Posted by Nerka View Post
    However, what you fail to recognize is that ADF&G uses emergency order authority to reduce exploitation rates by restricting areas and times. They also increase fishing time when necessary - they do not howerver ignore other stocks and species - to imply such is a mischaracterization of ADF&G management. It is truely adapative management which is the standard of good fisheries management today.
    ADFG is comprised of a whole lot of hardworking, dedicated, underpaid and often underappreciated people. The fishery is managed by time and area openings managed practically to the minute based on real time data - a highly developed and intensive management system. The Board of Fisheries has adopted a series of management plans designed to achieve biological and allocation objectives. In part this is designed to protect the area and regional management staff from being placed in the position of having to make allocative decisions. The commissioner has the authority to go outside the plans as the situation demands. Any such action can have signficant allocation implications - that is why the Department takes them very seriously.

    Quote Originally Posted by Nerka View Post
    Finally, you have restated exactly what the proposal does - it put allocation of the resources above management of the resources. That is maybe what they do in your state but Alaska has shown that escapement goal management is the foundational strength necessary to maintain runs for all users.
    This whole issue is all about yield and allocation - who gets how much of which fish. Going over an escapement goal reduces future yields if the goals are biologically based. Going under an escapement goal reduces future yield in the same fashion and can also cause long term conservation problems if they are way under. Ever notice how the people that argue that something has to be done for the "good of the fish" are also the ones that coincidentally benefit from the same action?

    Quote Originally Posted by Nerka View Post
    Here is a question - where are user needs not being met in UCI - the sport fisheries on sockeye, chinook, pink, and coho salmon are being met. There are no widespread closures in these fisheries. Harvest rates are good for Kenai and Kasilof chinook and escapements are being met. Pink and chum salmon are essentially not harvested by the sport fishing public or the commercial fishery (exploitation rates are in the teens). PU fisheries are growing and harvests are increasing. In fact, most PU fisherman do not take the fish available to them - see ADF&G report on the PU fishery.
    This is not a question for you or I to answer. It is definitely not a question the fishery managers want to be left to sort out. It is a question for the users and the Board of Fish. From all the noise out of Anchorage and the Valley of late, I suspect there is at least one group of folks that would say their needs are not being met. Seems like that group has been getting closed pretty regularly. I'm sure the Kasilof sport fishers might also have something to say about the effects of the continuous net fisheries off the mouth the last couple of years. Come to think of it, the commercial folks are being caught between the rock of lower prices and the hard spot of more limited fisheries so they would say their needs aren't being met either. I guess that pretty much means everybody.

    Quote Originally Posted by Nerka View Post
    So what allocation goal are you trying to meet or is the true goal to reduce the commercial fishery in UCI to a level it cannot survive. Bob Penny has stated that is his goal.
    The commercial fishery is a vital part of the local economy and fabric of the community as well as an honest and hard working way of life. Anybody that likes to fish is OK by me.

    The KRSA proposal in question is to clarify priorities in portions of the management plans current in place. These plans represent a relatively modest shift from historical practice. I don't see any KRSA proposal to do away with the commercial fishery. As for Mr. Penney, I saw him the other day but I didn't notice any horns or a pointy tail.

  20. #20
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    Default

    Charholio, exactly how are all of us sportfisherman getting short-changed allocations under current management? I like being able to catch a couple Kings before/after work, just about any time I want. My relatives and their friends keep coming back because it's so great. The tourists come in larger and larger numbers. The economy is growing. There are more guides than ever. Harvests are up. The River and its facilities are already exploited to the max, over-flowing with people number problems.

    Our sport fishery seems to just keep expanding and growing under current management methods. My god, if a sportsfisherman can't fill his freezer and experience some of the best fishing in the world under current UCI management, he's either lazy or clueless.

    Part of the reason sport fishing is so good and the fish are so abundent is because of the way we manage and prioritize the commercial fishery...EO's give F&G the ability and flexibility to open or close accordingly. If we allow allocations and species specific management priority over managing sustainable yields and other species management, we have disaster.

    As a sportsfisherman, I don't want anything to do with KRSA. It's clear to me that they want it all....at the expense of the resource and other fisheries.

    BTW, where's KRSA's biology that backs up this proposed management plan? Who's providing this science? Are they using data from the exact management method that they critisize? Where's their numbers for these proposed new allocation goals? And why the hell should we let an organization like KRSA, financed by the likes of Bob Penny, Ted Steven's and the boys, who have clear special interests, dictate how our sportfishery is managed?

    Clearly KRSA has gotten so greedy that they have forgone proven, sensible management. They've forgone managing for sustained yields in lue of "more" for them.

    The jig is up on Bob Penny's KRSA. All fisherman, especially sportsfishermen, should see the pattern and problems with the proposal. Make sure you submit your comments to the BOF at the address above.

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