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.
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:
General Comments Regarding Draft Issue Statements
- 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.
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:
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.
- 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.
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
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.
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.
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
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.