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16 MYTHS OF COOK INLET SALMON FISHERY MANAGEMENT

June 4th, 2015

MYTH 1. MAXIMIZING UCI COMMERCIAL HARVEST MAXIMIZES SALMON ECONOMIC VALUE

The essential economic question in Cook Inlet is not which fishery is more valuable but rather how to optimize the combined value of commercial, sport, personal use, and subsistence fisheries.

Successful sport, personal use, subsistence and commercial fisheries are all vital to the economic and social well-being of people throughout Upper Cook Inlet (UCI). The economic value of the commercial salmon fishery has long been recognized but equivalent or greater values of sport and personal fisheries in Cook Inlet have only recently been realized. The needs and values of no single user group are preeminent. An honest discussion of UCI fisheries issues must recognize the perspectives, needs, and values of each of the competing fishery interests.

MYTH 2. THE BOARD OF FISHERIES PROCESS IS BROKEN AND MUST BE REPLACED

Alaska’s world-best salmon fisheries are a testament to the effectiveness of the current Board of Fishery process.

While cumbersome at times, the board process provides an open and transparent means of addressing the ever-evolving challenges of salmon fishery management. To the Board falls the difficult responsibility of allocating fishery resources among competing users. Dramatically changing demographics, economics and culture in Upper Cook Inlet have increased demand for equal access by sport and personal use fisheries to the common property salmon resource. The Board has recognized current economic and cultural realities by beginning to balance management priorities that have long favored UCI commercial fisheries. Many attacks on the Board process are an effort to protect the historical status quo in UCI salmon fisheries when a Board dominated by commercial interests allocated the vast majority share of salmon harvest to commercial fisheries. A balanced Board of Fisheries with fair representation of commercial, sport, personal use and subsistence users is essential for equitable treatment of all user groups where no single interest can dominate the process at the expense of the others.

MYTH 3. UCI SALMON MANAGEMENT IS NOT SCIENCEBASED

Regulatory decisions by the Board of Fisheries are firmly grounded in science but necessarily determined by socially constructed values and expectations of the stakeholders at the policymaking table.

Science informs but does not dictate resource management decisions. It identifies alternatives, tradeoffs, risks, and uncertainties. It does not and cannot provide an objective basis for choosing human goals embedded in decisions. Why have days of public testimony if human goals are not going to be part of the decision criteria? Nor is science an allocative weapon – it is a body of organized information, interpretations and qualifications developed to minimize subjectivity – in our case regarding fishery management decisions.

When people claim that management is not science-based, they usually mean they disagree with the science that is being used for management purposes because it doesn’t support their positions. So know that you are hearing only one side of an argument when you hear statements such as:

  • “pseudo-science” is the basis for decision making,
  • “allocative agendas, disguised as conservation, prevail over science” at the Board of Fisheries,
  • “just let the biologists decide how to best manage the fisheries,” or
  • “research on salmon genetics, acoustic tagging, etc. is allocation disguised as science.”

MYTH 4. UCI SALMON MANAGEMENT PLANS DONT WORK

Sustained and diverse fishery opportunities as well as millions of dollars of economic activity in commercial, sport and personal use fishery sectors provide clear evidence that current management plans are largely working as intended.

UCI salmon management is complicated by the mixed stock, mixed species nature and very large fishing power of the commercial fisheries that operate out in front of sport and personal use fisheries. Current management plans seek to focus commercial set and drift gillnet fisheries on abundant and valuable Kenai and Kasilof sockeye while minimizing harvest of coho and late-run king salmon to provide personal use, sport and guided sport fishermen with a reasonable harvest opportunity for salmon.

The last few years have been particularly challenging for management. Historic low numbers of Chinook salmon and designation of Susitna sockeye as a stock of concern have required significant restrictions to all fisheries to share conservation burdens. However, all fishery sectors continue to produce significant opportunity and economic value. In fact, the last 4 years have been the most profitable of the last 20 for the commercial drift gillnet fishery based on total catch value. Escapement goals are generally being met. Where they are not, it is more often due to balancing inevitable tradeoffs rather than a failure of management plans. Suggestions of management plan failure are often an objection to recent allocation and conservation-based measures enacted by a Board of Fisheries as part of their duties.

MYTH 5. CURRENT MANAGEMENT PLANS PRODUCE DISASTROUS SOCKEYE OVERESCAPEMENTS

“Overescapement” arguments are largely an effort to establish a biological rationale for allocative strategies favoring commercial fisheries.

This argument favors strong stock management to maximize harvest of Kenai and Kasilof sockeye with lower regard for impacts on other species and stocks. Overescapement of Kenai and Kasilof sockeye has proven to be a problem more in theory than in practice. Kenai and Kasilof sockeye are already harvested at some of the highest exploitation rates of any wild stock of salmon in the world (70 – 80 percent). Dire predictions of a decline following successive large Kenai sockeye escapements from 2004-2006 have proven unfounded. High sockeye escapements continue to produce large returns, including the largest in over 20 years.

MYTH 6. COMMERCIAL FISHERY IMPACTS ON COHO ARE INSIGNIFICANT

Commercial harvest patterns affect the success of all other fisheries operating in their shadow.

Commercial drift gillnet fisheries are an extremely effective harvesters of UCI salmon including millions of sockeye per year and many thousands of comingled coho and Chinook. The commercial drift gillnet fishery is the primary harvester of coho destined for northern Cook Inlet streams, in spite of a 35 year-old regulatory directive to minimize the harvest of coho for benefit of the sport fishery. Since 2000, the drift fleet fishery has harvested over 100,000 coho per year on average versus 65,000 in the Susitna/Knik sport fishery. Commercial harvest is concentrated on the front end of the coho run and can effectively delay delivery of significant coho numbers to freshwater sport fisheries by several weeks. If surplus coho exist, why has the ADF&G consistently argued for lower bag and possession limits for sport anglers? Claims of low commercial exploitation rates on coho are based on subjective interpretations of limited data and ignore substantial evidence to the contrary.

MYTH 7. MAT-SU HABITAT QUESTIONS EXCUSE THE NEED FOR COMMERCIAL FISHERY LIMITATIONS

Freshwater production problems are an imperative for limiting harvest, not an excuse for continued overfishing.

The combination of reduced freshwater productivity and significant fishery exploitation is a recipe for salmon stock extinction. Commercial fisheries cannot be held harmless for habitat issues where limits are needed to sustain the salmon resource. Production concerns for northern Cook Inlet salmon including sockeye will require reductions in historical levels of exploitation in order to avoid long-term conservation problems.

The myth here is that participants in UCI commercial fisheries have nothing to do with the challenges facing fish habitat, even though many of these people live in the region and enjoy the roads, utilities and other modern developments. Cook Inlet is the most highly populated and urbanized region of the State. Development provides homes and jobs but inevitably affects fish habitat in areas where people concentrate. While impacts of development can be and are being mediated, does anyone really think that 20 years from now we will have fewer cities, towns, roads, subdivisions, schools and shopping malls or that 50 years of pike invasion can be cost-effectively reversed in hundreds of miles of streams?

The question is not whether factors like culverts, beavers, and pike impact salmon but rather what habitat and fishery strategies are necessary to sustain salmon populations and fisheries in the face of these pressures. Substantial habitat protection and restoration initiatives have been undertaken by the Mat-Su Borough and partners. If the fish truly come first, and maximizing total harvest is secondary, then precautionary fishery management strategies for impaired stocks such as Susitna sockeye must also be part of the equation.

MYTH 8. PERSONAL USE FISHERIES ARE OUT OF CONTROL

Growth in the UCI personal use fisheries over the last two decades attests to the tremendous value placed by Alaskan families on the opportunity to harvest salmon for their tables.

Over 30,000 households now participate in the UCI personal use fishery, harvesting 600,000 or more sockeye salmon per year, primarily from Kenai or Kasilof rivers. The personal use fishery has benefited greatly from sustained strong sockeye returns and commercial fishery closure “windows” that deliver fish to the rivers when the sockeye are running. The popularity of the personal use fishery has led to growing pains, while access and infrastructure to the limited fishing areas have struggled to catch up. However, the economic value and activity generated by the fishery easily justify and support significant investments in the facilities and systems needed for effective regulation and management. The “out-of-control” criticism comes largely from commercial fisheries which see the personal use fishery as a direct competitor for harvestable surpluses of sockeye causing a reduction in the local consumer market.

MYTH 9. THE STATE CONSTITUTION MANDATES MAXIMUM SUSTAINED YIELD

Management of UCI salmon, which shares and optimizes fishery yields and values among diverse fisheries, is very obviously consistent with the constitutional provision that directs fisheries be managed for sustained yield to achieve maximum benefit for Alaskans.

Arguments for constitutional failure confuse the technical fishery term, “maximum sustained yield” or MSY for the actual words found in the State Constitution, “maximum benefit.” MSY maximizes commercial harvest but leaves much to be desired for those who use the fishery resource upstream from the commercial fishery. Sport, personal use, and subsistence fishery success is greatest when fisheries are managed for “maximum production” or MSP which maintains stocks at the highest levels of abundance rather than the highest levels of yield. Simply put, MSP puts more fish in the rivers. A balance between maximum yield and maximum production provides maximum combined value for all fisheries – the technical fishery term for this balance is “optimum sustained yield” or OSY. Optimum sustained yield from multiple fisheries, rather than maximum sustained yield in a single fishery, is the paradigm for modern fishery management.

MYTH 10. THE POLICY FOR MANAGEMENT OF SUSTAINABLE SALMON FISHERIES (SSFP) HAS COMPROMISED COMMERCIAL FISHERY MANAGEMENT

Commercial salmon harvest in UCI has been reduced over the last 20 years by a complex of factors which are largely independent of the SSFP.

Chief among these is a gradual reallocation in response to increasing demand by sport and personal use fisheries. Commercial fishery harvest patterns also vary considerably over time in response to environmental factors and other factors such as processing capacity and market forces. Most recently, fisheries have been reduced by implementation of conservation measures for kings suffering from a downturn in ocean productivity and Susitna sockeye impacted by a combination of freshwater productivity and commercial harvest. The SSFP defines the state of the art in modern scientific management of salmon based on Alaska’s long history of success. This policy has been and will be instrumental in maintaining productive salmon resources in the face of tremendous fishery demand and management challenges associated with a dynamic and changing world.

MYTH 11. UCI MANAGEMENT VIOLATES THE MAGNUSON STEVENS ACT (MSA)

Claims that management of UCI salmon fisheries is inconsistent with MSA requirements are an effort to end run the state BOF process for a federal process that has historically been heavily weighted toward commercial fisheries and is far less accessible to the public.

The Magnuson–Stevens Fishery Conservation and Management Act (MSA) is the primary law governing marine fisheries management in United States federal waters. Management of salmon in Upper Cook Inlet is very obviously consistent with the national standards of the MSA, involving management for optimum yield and use of the best available science. Recent legal challenges to State management, based on resident-only participation in the personal use fishery, have absolutely nothing to do with a desire to allow non-resident participation in this fishery.

MYTH 12. LIMITED ENTRY & TRADITIONAL MANAGEMENT STRATEGIES ARE ALL WE NEED FOR EFFECTIVE UCI FISHERY MANAGEMENT

There is far more commercial fishing gear in the marine waters of UCI each summer than is needed to effectively harvest the available surplus of salmon. In the long-term, commercial fisheries can prosper, but management must evolve toward fishing more selectively.

Limited entry, the state statute that placed a maximum limit on the number of participants by gear type in the commercial fisheries within the regions of the state in 1971, does nothing to limit the harvest potential of the commercial salmon fisheries of UCI. On average, only about 65 percent of the gill net permits are fished during any given season, the others are considered to be “latent”. There is no room for additional set net gear along the shores of the Kenai Peninsula.

Out of the 571 drift gillnet permits authorized for UCI only about 475 have been active during the previous five years, even though those years provided for the highest payout in history. The commercial salmon fishery in UCI is substantially overcapitalized and a reduction in gear could be beneficial, but a rationalization or buyout strategy does not seem to be impending.

The historical tools used to manage the gillnet fisheries of UCI have been shown to have limited utility when used in the traditional manner for one simple reason; they lack effective selectivity between stocks and species. New tools are necessary to meet evolving demands of these complex mixed species, stock and user fisheries for the benefit of all involved. Recent innovations, including closure windows and shallow nets for the set net fisheries, and both terminal harvest strategies and conservation corridors for the drift gill net fishery, are just a few examples of potentially effective management tools that are being employed to optimize harvests.

The market price of fresh, high quality, wild Alaskan salmon and the demand for this outstanding product is high enough that UCI commercial fisheries can prosper while being managed to provide late-run kings, Kenai and northern coho for successful sport fisheries and late-run sockeye for personal use. The magnitude of expected loss resulting from reconfiguration of the gillnet fisheries in the manner selected by the Board of Fisheries in 2014 is no more than 5-10 percent of the year’s total ex-vessel value. Total variation in ex-vessel value has ranged from less than $8 million to more than $53 million annually over the past 25 years.

Clearly, the approximate amount foregone to manage more selectively is dwarfed by annual variations in sockeye harvest and price per pound paid to the fisherman. The forgone ex-vessel value is far less than the economic contribution of a successful sport fishery.

Cook Inlet salmon are a tremendous, renewable, natural resource with the capacity to support vibrant sport, personal use, commercial and subsistence fisheries. However, the days of strong stock, single industry salmon fisheries in UCI are past. It is time to shape the successful fisheries of the future. The ability to innovate and adapt will be key to future fishery success.

MYTH 13. KENAI HABITAT ISSUES DEMAND SUBSTANTIAL CHANGES FOR IN-RIVER FISHERY MANAGEMENT

In-river habitat concerns warrant fair consideration and appropriate remediation. However, none rise to the level of a significant biological impact that can only be addressed by reductions in-river fishery allocation. Biological criticisms of the Kenai sport and personal use fisheries are inevitably colored by social issues associated with these fisheries.

The Kenai is inarguably Alaska’s ground zero for salmon allocation disputes between competing commercial and sport/personal use fisheries. Issues are further complicated by different perspectives between residents and non-residents, guided and unguided sectors, and even set gillnetters operating in different areas. As in the Mat Su, in-river concerns are regularly employed by many critics of development and sport, guided sport and personal use fisheries that stand to benefit from higher commercial fishery allocations of salmon. The argument has been that in-river allocations must be reduced in order to avoid significant habitat damage that results from sport and personal use fishery activities and related development. This argument is not supported by the weight of the available evidence.

Human activities inevitably create environmental concerns in areas where people concentrate. Kenai River concerns include shoreline and watershed development, stream bank erosion, elevated turbidity from boat wakes, hydrocarbon pollution from boat motors and urban runoff.

We can all agree that wise stewardship of our tremendous salmon resources and habitat is an essential Alaskan value. It is also true that where risks are uncertain, precautionary actions are appropriate. Thus each of these in-river concerns warrant fair consideration and appropriate remediation. However, none of these in-river issues rise to the level of a significant biological impact that can only be addressed by reductions in-river fishery allocation. While we can hypothesize mechanisms for biological impact, all available evidence indicates that the net effects on Kenai salmon abundance or productivity of all current in-river concerns are so marginal as to not be measurable. In fact, the net biological impact of all in-river factors incidental to the actual harvest of Kenai kings is very likely much less than the undocumented incidental drop-out mortality of late run Kenai kings in the east set side gillnet fishery.

A period of unfavorable environmental conditions on the high seas has reduced abundance and curtailed fisheries for Chinook stocks across the North Pacific from Yakutat to Kamchatka. Similar declines in UCI have required substantial reductions in Chinook harvest in order to meet escapement goals and ensure continuing sustainability. Kenai king sport fisheries have shouldered a large share of this burden. Kenai king salmon sport fisheries are already one of the most intensively managed salmon fisheries in the world with a complex of season, area, time, bag, size, gear, bait, and participation regulations in place. The Kenai early run king sport fishery has been severely restricted with protected size slot-limit and tributary sanctuary regulations in place since the early 2000s and extended closures over the last few years. The Kenai late run fishery has been similarly been closed to king retention or fishing in each of the last few years.

Biological criticisms of the Kenai sport and personal use fisheries are inevitably colored by social issues associated with these fisheries. Social concerns involve fishery crowding, a large influx of seasonal visitors and competition among competing fishery interests. However, allocation and social issues require policy and social solutions. It is fundamentally dishonest to substitute biological justifications for political or social aims.

MYTH 14. COMMERCIAL FISHERY IMPACTS ON THE KENAI KINGS ARE INSIGNIFICANT

The set net fishery has a much greater impact on Kenai late run kings than they are willing to admit. Paired step down measures adopted by the 2014 Board have been instrumental in meeting escapement goals and avoiding catastrophic closures of the commercial set net fishery like that seen in 2012.

It is impossible to reconcile claims of low exploitation on kings in this fishery with everything else we know. New genetic analyses have been used by the Department to apportion the commercial king harvest into Kenai and other stocks. This data has been used to estimate that the east side net fishery catches only about 13 percent of Kenai kings and many of these are small fish that aren’t even counted in the escapement.

The set gillnet fishery along the east beaches accounts for the majority of the commercial harvest of kings, primarily those destined for the Kenai and Kasilof rivers. This fishery typically harvests close to half of the sockeye run reaching the beach and much more during intensive fishing periods. We also know that sockeye generally move onshore and into the rivers with little delay while kings may linger in the fishery area for days before entering freshwater.

MYTH 15. CATCH AND RELEASE OF KING SALMON IS DAMAGING THE STOCK

Effects of catch and release fishing are very small and at least some of the criticism is related to philosophical disagreements over the catch for harvest and catch for recreation. Size selective harvest concerns are effectively addressed by existing regulations in both the Kenai early run and late run fisheries.

Biological effects of sport fishery selection for different sizes, sexes or subpopulations of Chinook have also been questioned. All fisheries, sport and commercial, selectively harvest fish to some degree. Selectivity can theoretically shift biological attributes if it is very great and occurs over a long-enough period of time. The Kenai sport fishery generally selects against smaller kings but the large majority of big kings escape the fishery to pass their genes into the next generation. Effects of selective sport harvest on Kenai kings is marginal at best. A long term declining trend in numbers of large kings has been documented throughout much of Alaska including areas with and without significant sport fisheries.

 

MYTH 16. KENAI HABITAT ISSUES DEMAND SUBSTANTIAL CHANGES FOR IN-RIVER FISHERY MANAGEMENT

In-river habitat concerns warrant fair consideration and appropriate remediation. However, none rise to the level of a significant biological impact that can only be addressed by reductions in-river fishery allocation. Biological criticisms of the Kenai sport and personal use fisheries are inevitably colored by social issues associated with these fisheries.

The Kenai is inarguably Alaska’s ground zero for salmon allocation disputes between competing commercial and sport/personal use fisheries. Issues are further complicated by different perspectives between residents and non-residents, guided and unguided sectors, and even set gillnetters operating in different areas. As in the Mat Su, in-river concerns are regularly employed by many critics of development and sport, guided sport and personal use fisheries that stand to benefit from higher commercial fishery allocations of salmon. The argument has been that in-river allocations must be reduced in order to avoid significant habitat damage that results from sport and personal use fishery activities and related development. This argument is not supported by the weight of the available evidence.

Human activities inevitably create environmental concerns in areas where people concentrate. Kenai River concerns include shoreline and watershed development, stream bank erosion, elevated turbidity from boat wakes, hydrocarbon pollution from boat motors and urban runoff.

We can all agree that wise stewardship of our tremendous salmon resources and habitat is an essential Alaskan value. It is also true that where risks are uncertain, precautionary actions are appropriate. Thus each of these in-river concerns warrant fair consideration and appropriate remediation. However, none of these in-river issues rise to the level of a significant biological impact that can only be addressed by reductions in-river fishery allocation. While we can hypothesize mechanisms for biological impact, all available evidence indicates that the net effects on Kenai salmon abundance or productivity of all current in-river concerns are so marginal as to not be measurable. In fact, the net biological impact of all in-river factors incidental to the actual harvest of Kenai kings is very likely much less than the undocumented incidental drop-out mortality of late run Kenai kings in the east set side gillnet fishery.

A period of unfavorable environmental conditions on the high seas has reduced abundance and curtailed fisheries for Chinook stocks across the North Pacific from Yakutat to Kamchatka. Similar declines in UCI have required substantial reductions in Chinook harvest in order to meet escapement goals and ensure continuing sustainability. Kenai king sport fisheries have shouldered a large share of this burden. Kenai king salmon sport fisheries are already one of the most intensively managed salmon fisheries in the world with a complex of season, area, time, bag, size, gear, bait, and participation regulations in place. The Kenai early run king sport fishery has been severely restricted with protected size slot-limit and tributary sanctuary regulations in place since the early 2000s and extended closures over the last few years. The Kenai late run fishery has been similarly been closed to king retention or fishing in each of the last few years.

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