The number of early-run king salmon returning to the Kenai River in 2012 was likely the lowest on record and the Alaska Department of Fish and Game (ADFG) can’t say whether the escapement goal was attained. The early-run Kenai River king salmon sport fishery has been a disaster, the late-run Kenai River king salmon sport fishery is restricted, in part, to continue to conserve early-run fish, the first two regular openings of the commercial set net fishery are closed and many tough questions remain unanswered.
A quick examination of the historical data for king salmon of Kenai River origin proves just how poor this season has been. The preliminary harvest estimate in the early-run sport fishery is only 317 fish compared to an average (2002-2011) of 1,834. Sportfishing effort, an economic driver in the region, was estimated to be only 15,000 angler-hours compared to an average (2002-2011) of over 55,000 angler-hours.
Even with the well documented imprecision in ADFG’s ability to assess in-river return of Kenai River king salmon, no one contests that the early-run is historically low. No one questions the need for a conservative management approach.
As a result, KRSA has stated its full support of the actions taken to date (06/27/2012). Along with these public statements of support of management actions, KRSA’s professional fishery staff carries an obligation to our membership to assess the fishery data, the regulations from which the management actions flows and the rationale of the decision process used by ADFG.
When it comes to early-run Kenai River king salmon the KRSA believes that a number of important questions must be asked:
1. Does ADFG’s current inability to accurately estimate in-river return of king salmon on a real time basis make it impossible for them to implement the early and late-run Kenai River king salmon management plans as adopted by the Alaska Board of Fisheries (BOF)?
2. If the Department cannot accurately estimate a “number” for the in-river return of king salmon and the existing plans contain specific numbers that must be used to achieve management goals, is ADFG managing “outside” the plan?
3. Is managing “outside” of these management plans considered an “error” in regulation as it applies to the BOF Agenda Change Request Criteria?
KRSA feels that ADFG is operating “outside” the in-river Kenai River king salmon management plans because these plans include escapement goals stated as specific numerical ranges intended to be achieved in-season utilizing sonar estimates on a real-time basis. ADFG now utilizes an array of assessment tools in an effort to index the abundance of king salmon entering the Kenai River. The Department’s stated goal for management is now not a specific numerical range measured by sonar, but a “sustainable” situation.
“Sustainable” is a far more vague target than a specific numerical range In 2012, the Department is not using sonar to manage for the specific numbers stated in the codified in-river king salmon management plans. This departure between a codified regulation and the actual implementation can certainly be considered an “error” in regulation.