Deshka River closure

[willphish4food]

Now that the Sportfish Division of F and G has has closed the Deshka River to the keeping of kings four days of the week, what actions should the commercial department take to share the burden of conservation?

By their own claims before the Board of Fish, Commercial fishing is the most effective means of harvesting large numbers of salmon. If Commercial fishing is the most effective, then it follows that sport fishing is less effective. It seems logical to me that if the less effective means of harvesting salmon has been heavily restricted due to concerns over not making the escapement, then the most efficient means should also be restricted.

I shall wait to see if the Commercial Fishing Division really does care about conservation of the resource, or just ensuring that the commercial fisheries harvest the maximum amount of fish possible before being forced to restrict?

If the affected runs of kings cannot be effectively quantified as they pass through the various commercial fisheries before arriving at streams where there are escapement concerns, then some restrictions to all commercial fisheries intercepting Deshka bound kings can only have a positive effect for escapements. If that is unpalatable, tough- spend some money on more genetic studies to find out what fish are being caught and in what numbers.

The Department is called upon to act upon the best available science, to conserve the resource, and to share the burden of conservation. All excuses aside, about how poor the science is, yada yada, thats the bottom line. The best available science that we have shows varying proportions and numbers of Susitna and Deshka bound kings in each commercial fishery. It also shows that unless more adults are allowed to enter the river, there will be some very lean years ahead, with no surplus for harvest. Therefore, that is the science that must be used in the management of the fishery. Don't like it? Get better science. In the meantime, though, follow your statuatory requirement to "act upon the best available science, and share the burden of conservation."

Since a burden of conservation has been placed on the sport fishery, which will likely cost Valley businesses hundreds of thousands of dollars, if not more, the department must not forget its duty under the SMP to "share the burden."

I await the announcement.

[Mr. Pid]

You forgot that Alexander Creek has already been totally closed to kings. Now the restrictions are spreading.

The constitution mandates the resource shall be managed for the benefit of all Alaskans. If the commercial side doesn't share the burden of protecting the stocks by regulation then they may be forced to share the burden by the courts. ADFG is walking a very thin line.

[gotfish?]

what would your plan be?

I am curious how far "south" you guys are thinking. Should all commercial fisheries south of the valley be closed? Do "your fish" swim north and west too? I am not trying to be smart here. I am just wondering what you would consider an effective point to stop commercial fishing to protect "your fish". I think I would be working pretty hard to try and eliminate pike and beaver dams too. Is their any sort of comprehensive approach being considered? I don't believe that simply ceasing commercial fishing is going to be the magic wand that fixes the problem. It can't hurt I guess. Do you think that it will solve the problem? Convince me!

[Grampyfishes]

Willfish4food, look at the data. Look at the brood years. For 12 out of the last 13 years the Deshka has met and exceeded chinook escapement goals. The top end of the goal was exceeded 9 of those years, and even doubled at times. Sport fishing bag limits were liberalized and restrictions removed. All while the commercial fishermen sat back and watched this lost yield swim under our sportfishing boats. Yes, 2008 was a bust for the Deshka, as it was for most systems. And it looks like predictions for 2009 might be a bust too.

By law, the Northern District commercial fishery is allowed to take 12,500 Chinook. These aren't just Deshka-bound Chinooks. Keep in mind that restrictions have limited the commercial guys to about a quarter of that cap, on average. Clearly, even if every Chinook caught in the Northern District commercial fishery was bound for the Deshka, and that commercial fishery was completely closed, it still wouldn't be enough.

So what you are suggesting is closing southern commercial fisheries...based on a guess that they are catching your fish and that closing them down will solve your problem. And at the same time you hypocritically ignore the resource and economic impacts to the rest of the Cook Inlet's sustained fisheries by doing that. Keep in mind these are fisheries that have already been restricted a great deal on behalf of the Northern District escapements.

It's not a perfectly managed fishery. It is a complex mixed-stock mixed-user-group conundrum. Unfortunately the Northern District is at the end of the line. And it's topped off with several known in-system productivity problems that the Northern District ignores, because it's easier to target the commercial fishery as the problem.

"Sharing the burden" of the Northern District's problem is one thing. The commercial fishery continues to do that. But shutting the southern commercial fisheries down becomes more than "sharing the burden"...it becomes "creating burden".

Willfish4food, besides trying to close the commercial fishery down, what have you done to enhance the known productivity problems of the ND systems (flooding, beaver dams, pike, etc.), and what have you done to secure funding for further studies on what is happening to your fish?

[Nerka]

another misrepresentation by will

I really think willphish4food is trying to mislead people as opposed to providing facts. His posts continue to misrepresent the situation. Here is the facts on this issue.

1. The Deshka is not closed to fishing. It is restricted. That is a big difference. The management plans says the Deshka must be closed to fishing - every day before the commercial fishery closes.

2. The management plan also took into consideration conservation issues when it was written. The commercial fishery is not closed until a complete closure of a system happens. However, conversely the commercial fishery is not expanded when runs are strong. It is a fixed exploitation rate fishery. So the conservation burden is already written into the plan for commercial fisheires via the quota, limited gear, and time.

3. Next comes the issue of the projections. Sport Fish Division made a forecast and that forecast indicated that with an average harvest the goal would be met - by 600 fish. One must remember that the average sport fish harvest is based on some really great years when the runs were 50,000. So the chance of an average harvest in a poor return is not likely.

4. Sport Fish Division was irresponsible in this action prior to the season. It was based on a forecast that has significant error. More importantly, the forecast was not used but the gut feeling of an area biologist and regional staff. The news release even says they do not believe their own forecast. That is interesting - we used science (forecast) when it suits our needs and then give it up when it does not - the Commissioner of ADF&G should look seriously at this issue. Making management decisions prior to having inseason infroamtion is not a responsible way to manage fisheries, especially when a management plan exists.

5. The area biologist testified that between 100,000 and 150,000 chinook will return to the Northern District. The Deska would be 15% of that so with a commercial harvest of 3000 fish or so that would be 450 fish - this is certainly within the error of the forecast margin and management options. The Board of Fish recognized this when they wrote the plan and said a total closure is needed to prompt action in the commercial fishery.

Willphish4food - you need to be honest when you present something and frankly you know this information and refuse to state it or deal with it. Your desire to close commercial fisheries is so intense you have lost all sense of fair play.

[willphish4food]

deflecting the question

Best available science, and share the burden of conservation. Those are mandates. All other is just deflecting the question, Grampy. I will dignify your questions with a dignified response, though.

Funding and pike problems. I worked very hard with the valley legislators to get funding for the genetics study and economic survey. In '05 I submitted a pike predation permit proposal as an RC. In '08 I worked on the pike committee and lobbied for a 5 line limit on Nancy Lake, which has both a red run and pike. In '09 I helped submit an emergency proposal to bring Alexander Lake to the table out of cycle. As a result the slot limit on pike will be dropped to increase angler effort. I recognize there are many problems in our system, and I have taken the actions I can to address them. I'm not a single issue warrior.

Restricting all mixed stock fisheries- this is not necessarily the case. If a mixed stock fishery occurs after the main bulk of Deshka/Susitna kings has passed, then it likely wouldn't be affected, unless there's no fish in the Deshka. The Northern District's May opener that was just added to their season is one that has the a very large effect on Deshka bound kings, and more importantly, Alexander Creek. The other one to look at would be the Upper SubDistrict of the Central District.

It is very dishonest to look at commercial catch vs commercial catch cap, and not take into consideration the other factors besides restrictions that limit the Northern District catch. Look at sport harvest numbers on 4 major systems in 1990. This was a year when ND caught numbers close to the cap. Theodore, Lewis, Deshka and Alexander Creek all had sport harvests in excess of 1,000 fish, and Deshka had a high harvest as well. These are all remote fisheries. Theodore, Lewis and Alexander were all thriving fly in fisheries, and Deshka and Alexander were mixed boat/fly in. I wish I had the exact numbers in front of me! Add to this the fact that the last two seasons, of all surveyed streams in the Valley, less than half were even at the escapement threshold. There are no extra fish to be caught from the Susitna/West side systems. We're not talking about harvesting fish that are not necessary to the system- there is no longer an overabundance of fish in the Deshka, much less the Su.

The reason this is an extremely important point is that when you put this data in the mix with the higher commercial catch, it shows that more kings were available to all fisheries. Now three of the systems that produced so many kings in the early nineties have no sport fishing mortality allowed, and the Deshka, the fourth system, is heavily restricted to MAYBE allow its bottom threshold escapement to be reached. In other words, the total number of fish getting into the Susitna and West Side streams is far lower than it was when ND was able to catch 13,000 kings in a season. To me, it makes no sense to continue to take measures to increase the commercial catch back to the numbers it had in its heyday when all the indicators show that there is not nearly the pool of fish to pull those numbers from. Just as important, the restrictions to sport fishing that were put in place still exist. We still cannot use bait anywhere other than the Deshka River, we have a one fish a day and in possession (half the former possession limit), and a 5 fish a year cap- we formerly had no season limit. If extra fish are there to expand commercial fishing again, then they are there for sport fishing as well. Share in abundance, share in scarcity.

Finally, lost economic opportunity when Deshka river overescaped. First off, that is a very sketchy thing to say when looking at '05 commercial numbers. I'll get to that in a minute. The same argument applies here as the one Grampy uses for mixed stock fisheries. Even though escapements in the Deshka were high, the rest of the monitored streams were not above the high end of escapements. They were well within the range, and some were under the minimum escapement. Alexander was one of these. Increasing commercial effort on the mixed stocks in the Inlet would have caused other major streams in the system to fall below the minimum escapement threshold, possibly prompting closures in the sport fishing on the major Parks Highway streams. Yes, there is an economic qualifier for BOF decisions. It is one of the criteria they must consider when deciding upon allocation shifts.

Lost economic opportunity is so hard to quantify too. In those years of large escapements in the Deshka there were literally hundreds, sometimes several thousand, boats fishing the Deshka every day. Both guided and non guided. So even though the overescaped fish did not end up in a fisherman's hold, the abundant fish caused a big surge in sport fishing effort and expenditures. This gets into economics principals which I am fuzzy on, but my point is that there is a tradeoff. Dollars lost to ND setnetters are not dollars that are lost to the economy, nor to the state. There's a lot more dollars separated from tourist's pockets when the king fishing is good than when it is poor. $282,679. That is the ex vessel value of 8500 kings at '05 prices, from the numbers in the '05 commercial fishing report. The closure of the Deshka River last summer, combined with poor returns elsewhere, cost the business I work at roughly $150,000. And it is just a small tackle shop. Add in Freddy's, Wally world, the hotel industry, guides, Deshka Landing, etc, and the economic impact on the Valley far exceeded the exvessel value of an additional 8500 kings to the Northern District.

Now, one more statement I'd like to set straight. Was there lost economic opportunity? The BOF took action to rectify it, if it happened, in spring '05, and it worked- despite Grampy's claim to the contrary.

Grampy- "Sport fishing bag limits were liberalized and restrictions removed. All while the commercial fishermen sat back and watched this lost yield swim under our sportfishing boats."

Sorry that's just not true. This is also excerpted from the '05 commercial report:
"In 2005 the commercial harvest in the Upper Subdistrict set gillnet fishery of 20,808 Chinook salmon was the third highest harvest since 1966 when harvest records specific to fishery are available." "The 2005 harvest of 28,894 Chinook salmon is well above the long term average harvest by approximately 11,000 fish. The two fisheries where Chinook salmon are harvested in appreciable numbers in UCI are in the Northern District and in the Upper Subdistrict of the Central District."

This doesn't look like a bunch of fishermen sitting by watching lost yield swimming by. There was a great return of kings, and a lot of them were caught in both the commercial and sport fisheries. Yes, the Deshka did overescape. But don't blame that on lack of effort by management to prevent this. Commercial boys were nearly double the long term average. In fact, they had the 3rd largest harvest in 40 years! Sport fishermen tried, but did not catch more fish, despite liberalized bag limits on the Deshka, because the water temp was so high the fish had lockjaw. You can't blame that one on Fish and Game!

http://www.cf.adfg.state.ak.us/regio...i/ucipos05.pdf

And there's the link if you'd like to verify my numbers.

Ya know? Sportfishing on the Deshka wasn't really great in the late 90's, either. It was shut down completely for 5 years!

[willphish4food]

Nerka, before you call me a liar please read my post again. "Now that the Sportfish Division of F and G has has closed the Deshka River to the keeping of kings four days of the week,"

I am sure you can read an entire sentence at one sitting . "closed to the keeping of kings" is not closed... how is this misleading people? You can agree to disagree, but please don't call me a liar. Especially if you then post a rebuttal to my statement that just restates what I wrote!

Nerak wrote- "1. The Deshka is not closed to fishing. It is restricted. That is a big difference. The management plans says the Deshka must be closed to fishing - every day before the commercial fishery closes."

sheesh... I'm not here to schoolyard bicker. I want to see Fish and Game manage the complete fishery, with sport fish and comfish working together to manage for conservation.

[Nerka]

Get it right and I will back off

Nerka, before you call me a liar please read my post again. "Now that the Sportfish Division of F and G has has closed the Deshka River to the keeping of kings four days of the week,"

I am sure you can read an entire sentence at one sitting . "closed to the keeping of kings" is not closed... how is this misleading people? You can agree to disagree, but please don't call me a liar. Especially if you then post a rebuttal to my statement that just restates what I wrote!

Nerak wrote- "1. The Deshka is not closed to fishing. It is restricted. That is a big difference. The management plans says the Deshka must be closed to fishing - every day before the commercial fishery closes."

sheesh... I'm not here to schoolyard bicker. I want to see Fish and Game manage the complete fishery, with sport fish and comfish working together to manage for conservation.

Willphish4food, below is the language of the emergency order. The fishery is not closed to fishing. It is closed to retention. So the sport fishery is operating 7 days a week and catch and release mortality si taking place on four days and harvest on three days. That is not a closure it is a restriction. Maybe you should figure out what your know and do not know before you post.

Anglers fishing on the Deshka River will not be allowed to use bait and will only be allowed to retain king salmon on Saturdays, Sundays, and Mondays, from May 15, 2009, through July 13, 2009. All king salmon caught Tuesday through Friday may not be removed from the water and must be released immediately. These changes go into effect at 12:01 a.m., Friday, May 15 through 11:00 p.m., Monday, July 13, 2009. Contact:Dave Rutz

The management plan states that if the Deska is closed to sport fishing the commissioner shall close by emergency order the commercial king salmon fishery through out the Northern District.

Sport Fish Division is their outlook papers and discussion of the management plan notes that restrictions are what they are doing right now - not a closure. A closure means you cannot target the stock. The above emergency order allows Deska chinook to be targeted and recognizes a harvestable surplus. End of story.

This is about a bunch of valley people who again want to take matters into their own hands and promote their own greed. It has nothing to do with stock conservation. They would have the whole ND fishery closed for the season under their definition of closure as outlined by Willphish4food. I am sorry but that type of action deserves a harsh response.

[willphish4food]

Wow. If this keeps up maybe the moderaters will have to step in! I'm still a liar! Woohoo, I have a title! I'm trying to get this straight: The Deskha is closed to retention of kings 4 days of the week. This is a restriction; I have never claimed that the Deshka river is closed to fishing, just retention! Nerka, give it a rest! You're saying the exact same thing I'm saying, and calling me a liar because I'm wording it differently than you'd like to see! What a crock!

Now moving away from the he said I said argument. I do not see the reason there is such a virulent response to requesting that since one more Susitna river's sport fishery has been restricted by EO, the commercial fishery will also be restricted by EO.

Nerka, do you really believe this? "This is about a bunch of valley people who again want to take matters into their own hands and promote their own greed. It has nothing to do with stock conservation. They would have the whole ND fishery closed for the season under their definition of closure as outlined by Willphish4food. I am sorry but that type of action deserves a harsh response."

If so, I am really sorry for you. That hatred for sport fishermen must be eating you alive. Take a deep breath, a few blood pressure pills, and simmer down!

My entire point is that the escapements to valley streams of chinook salmon are at a down point in their cycle. In their discussion at the 2008 BOF meeting, the BOF explained that peaks and valleys happen, so the Board chose not to restrict the Northern District by regulation, but expand it, and trust the Department to use EO authority to restrict it if the run forecasts were weak. Thats right. The Department does not have to entirely shut the fishery down: only if Deshka is completely closed to sport fishing would it require the collateral closure of Northern District set net. They have been given EO authority by the board to restrict the fishery. What is so wrong with closing the extra opener in May that was granted spring of '08? They would still be left with all the fishing time that they had prior to '08, which is twice the amount of time they had prior to '05! How is that a hardship? And don't tell me that extra time doesn't make a difference- these are their words, not mine- taken from the 2005 UPPER COOK INLET COMMERCIAL SALMON FISHERY SEASON SUMMARY: "

Changes
made by the BOF in the 2005 regulations lengthening the fishing periods to twelve hours instead of six hours
each Monday, likely increased harvests in 2005. The 2005 harvest of 3,452 Chinook salmon is approximately

1,200 fish above the recent 10-year average harvest of 2,200 Chinook salmon."

Its all about sharing the burden. No one within the department has been willing to explain to the public how the burden is being shared between commercial and sport fish. So far, they are keeping sportfishermen, both Alaska residents and non residents, from retaining fish in one of the most popular valley fisheries in 4 out of 7 days of the week. I wonder if anyone really believes that the fishing effort will remain the same as if retention was allowed? This is a VERY burdensome restriction to Valley sportfishermen and the businesses that rely on them. So how is the Comfish department acting to share the burden?

Nerka for some reason would like to believe I'm asking to shut down the whole ND setnet. I have no idea how he arrived at that conclusion- restricting them to 3 openers instead of 4 is not a closure, only a restriction. Right Nerka? And it would only restrict them to catching 64% more fish than the recent 10 year average. Shoot, if a restriction to my paycheck were the same, I'd be begging my boss to restrict me!

[Nerka]

The plan dictates the actions.

The conservation burden is outlined in the management plan. It appears that some want that management plan changed. The ND fishery is limited by a variety of actions of the BOF. Fishing dates, times, gear, and a quota.

The ND fishery does not share the conservation burden and then not get to help harvest large runs? That is the point. The ND limited fishery has its conservation burden built into the fishery - a fixed exploitation fishery. The sport fishery does not have those restrictions. In fact, a few years ago the sport fishery was made more liberal prior to the season based on a forecast. The commercial fishery was not made more liberal per the plan.

That may be hard for some to understand but that is the technical approach the BOF took. In this plan the next action for the commercial fishery is closure when escapement goals will not be met.

I am not anti-sport fisherman. I am against some sport fish groups that refuse to understand or explain the history and development of these plans in an honest way. I am not anti-sport fishing at all. I belong to a sport fishing group and work hard in that capacity. Some commercial groups do not like that but so be it.

My comments about some valley residents and greed is based on my experience with them. They refuse to look at the data, make outlandish comments to their representatives and in some cases get things like Senate resolution 22 introduced.

[willphish4food]

If the plan dictates the actions, then how does EO authority work, Nerka? That's just it- EO authority is also a part of the plan, is it not?

[Grampyfishes]

Geeze Willfish4foood…this is the same old misrepresented arguments and misleading information you continually post here, all of which have been discussed before, and none of which you ever legitimize. The “Deshka River closure” has simply given you new spark to once again find a way to close commercial fishing down so your own interests are better served. As usual, you fail to acknowledge the facts, lay your plan out there (whatever it is), and answer the tough questions with justification.

Nerka has summed things up pretty well, although I doubt you'll acknowledge the truth. But let me get a few straggling things you posted off my chest:

The title of your post, "Deshka River closure", and its ensuing argument about the commercial fishery, misleads folks into thinking the Deshka is closed while the commercial fishery has been liberalized. The fact is the Deshka River is not closed, and the commercial fishery has not been liberalized. You can squirm out of that by trying to flip it back on Nerka if you want, accusing him of calling you a liar and trying to label him as a “hater” of sport fishermen just because he addresses your disinformation. But nobody is biting.

You keep talking about "sharing the burden of conservation" without recognizing that the Northern District commercial fishery has already been reduced and restricted so much from its original state that it's hardly recognizable as the same fishery it once was. You fail to understand that "burdens" were put on this commercial fishery long ago. In fact it has actually lost participation because it is hardly viable anymore. Somewhere along the way you decided to throw all that out. Those burdens were never lifted when returns rebounded, even after 12 years of exceeding, and sometimes doubling, the upper end escapement goals. All while our sport harvests sky-rocketed, our bag limits were liberalized, escapements were exceeded, and commercial harvest yield was lost. See, the commercial fishery has been "sharing the burden" for quite some time.

You totally misrepresent the 2005 period extension (again). I've posted the reasons for this extension per the BOF record many times for you, but you reject them. Again, escapements were exceeding the top end by tens of thousands of Kings, and at times even doubling goals. There was no reason not to extend the period a lousy 6 hours and harvest 1,200 more Kings. Furthermore, the record shows that the decision was based on the fact that 6-hour periods sometimes left the commercial nets fishing out of the water, in the mud and rocks because of the tide timing…When you only have a few fishing periods, and you can’t fish them, what good are they? Also, delayed transportation of the fresh fish to the canary because of tidal issues was jeopardizing quality. And let’s not forget we are talking about a fishery that was harvesting an average of only 2,200 fish when it has an allowable cap, per law, of 12,500. I hate to break it to you willfish4food, but you got problems bigger than those 1,200 Kings you’re popping a vein over.

Speaking of popping a vein, when the sport fishery gets an EO restriction you go ballistic. Yet when the commercial fishery gets them, which they constantly do, you react just the opposite. Why is that? Because you have a special interest, and speaking against the commercial fishery better serves you? Of course.

It is not dishonest to look at the commercial catch vs. commercial catch cap. The cap is established, by law, at 12,500 Chinook. The fact the fishery has been reduced and restricted to a point where, on average, only 2,200 are harvested, goes to show where the "burden" has been placed. Particularly since the Deshka's returns have consistently produced large surpluses for over a decade. Escapements were not only met, but the top end was exceeded many years, and it even doubled! You tend to blame the problems of the Theodore, Lewis, and Alexander on the commercial fishery, ignoring how the same commercial fishery has produced huge surpluses on the Su’s Deshka for more than a decade. You have a serious disconnect there, failing to recognize in-river production problems on those systems. Without evidence, you simply point a finger to commercial fishing. And then after only one bad year on the Deshka (2008), also echoed throughout entire Cook Inlet, you claim “there is no longer an over-abundance on the Deshka”. I wish I had your crystal ball and could make such quick, rash, assumptions. But at least you admit there has been over-abundance, which really contradicts your entire argument.

You keep talking about the 2005 commercial harvest being so high. Of course it was…the return was huge. Even with that increased harvest, the Deshka still over-escaped. I mean what are you suggesting?...that on big return years the commercial harvest should be low? Unbelievable.

Your economic spiel is almost laughable. You want to close commercial fishing and upset the successful and sustained management of the entire Cook Inlet sport and commercial fisheries because of a problem at the end of the line…which has never been proven to be a result of commercial fishing in the first place. Your own economic interest is apparently more important than the rest of the entire affected economy throughout South Central. Right. And then you go and compare only the direct ex-vessel value of commercial fish to the entire direct and indirect economic value of sport fish. I guess recognizing the entire economic effects of closing commercial fishing, and its trickle-down impacts at Fredys, Wally World, etc. would be too much to honestly ask. Willfish4food, there is no guarantee of economic prosperity for a sport fishing industry that built itself, and relies, on a fluxuating natural resource and an economic-driven, recreational-oriented, livelihood. And BTW, economics is just one factor the BOF must consider. Odd you don’t talk about the others relating to commercial fish.

Willfish4food, the fishery laws are clear that the burden of conservation is shared by all user groups, particularly in times of poor returns. If the Deshka closes, so will the commercial fishery.

[Nerka]

easy answer

If the plan dictates the actions, then how does EO authority work, Nerka? That's just it- EO authority is also a part of the plan, is it not?

Yes and no willphish4food. The ememrgecy order authority of the ADF&G is spelled out in the plan for the Deshka... if the Dahka River is closed to sport fishing, the commissioner shall close , by emergency order, the commercial king salmon fishery through out the Northern District for the remainder of the fishing periods...


Just for those who want to follow this when Will states share the conservation burden the Board did this if no management plan was in place. Therefore, it gave direction to ADF&G to share the burden in prpoportion to harvest. However, if a management plan is in place then the management plan takes priority at the first decision phase. In the case of the Northern District chinook plan the above quote from the management plan is the action the Commissioner is directed to take by the Board.

Finally, the Commissioner emergency order authority cannot be inhibited by the Board of Fisheries as it is in statue. The courts have ruled that in the Brown decision. The Board follows this rule of law with a statement in the UCI salmon management plan that states that if significant new information arise that, the commissoner's judgement warrants departure from the provisions in the management plans... the Commissioner may alter the plans.

In the case of the ND chinook fishery there is nothing that has happened to date that would cause the Commissioner to deviate from the plans on biological grounds. However, political decisions are made in UCI and we will see how this Commissioner responds to the pressure from the valley and Anchorage who refuse to read the plans, understand the history, or try to work to the good of all Alaskans. The Board of Fisheries has written a good ND plan for conservation and it should be followed.

[commfish]

Provision added to all the Cook Inlet plans

If you recall all the discussion at the last Cook Inlet meeting regarding managing for escapement goals vs staying within management plans, the board clarified that managing for escapement goals shall take priority.

5 AAC 21.366. Northern District King Salmon Management Plan

(b) The commissioner may depart from the provisions of the management plan under this section as provided in 5 AAC 21.363(e) .



5 AAC 21.363. Upper Cook Inlet Salmon Management Plan

(e) Notwithstanding any other provision of this chapter, it is the intent of the board that, while in most circumstances the department will adhere to the management plans in this chapter, no provision within a specific management plan is intended to limit the commissioner's use of emergency order authority under AS 16.05.060 to achieve established escapement goals for the management plans as the primary management objective. For the purpose of this subsection, "escapement goals" includes inriver goal, biological escapement goal, sustainable escapement goal, and optimal escapement goal as defined in 5 AAC 39.222.

[Nerka]

that is correct

If you recall all the discussion at the last Cook Inlet meeting regarding managing for escapement goals vs staying within management plans, the board clarified that managing for escapement goals shall take priority.

5 AAC 21.366. Northern District King Salmon Management Plan

(b) The commissioner may depart from the provisions of the management plan under this section as provided in 5 AAC 21.363(e) .



5 AAC 21.363. Upper Cook Inlet Salmon Management Plan

(e) Notwithstanding any other provision of this chapter, it is the intent of the board that, while in most circumstances the department will adhere to the management plans in this chapter, no provision within a specific management plan is intended to limit the commissioner's use of emergency order authority under AS 16.05.060 to achieve established escapement goals for the management plans as the primary management objective. For the purpose of this subsection, "escapement goals" includes inriver goal, biological escapement goal, sustainable escapement goal, and optimal escapement goal as defined in 5 AAC 39.222.

Commfish the above is correct. Relative to the ND situation the forecast is to meet the goal even with an average sport fish harvest. If inseason ADF&G determines that it will not meet the goals then both the sport and commercial fisheries will close to all fishing - not just to retention or three day a week harvest. At this point ADF&G is still indicating a harvestable surplus above escapement needs.