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Essential questions to ADFG regarding Kenai king salmon conservation measures in August

August 6th, 2012

After a month of severe restrictions in the commercial, personal use and sport fisheries to protect late-run Kenai River king salmon, KRSA has several essential questions of the Alaska Department of Fish and Game (ADFG) regarding the opening of the Upper Cook Inlet (UCI) east side set net fishery on Monday, August 6. We ask the following:

1. Is there a demonstrable harvestable surplus of late-run Kenai River king salmon above minimum escapement needs?
2. If a demonstrable harvestable surplus does exist, how did ADFG make the determination that the minimum escapement goal of 17,800 late-run Kenai River king salmon spawners has been achieved? Or, as it appears to be the case with UCI commercial fishing announcement #33, has ADFG changed how a harvestable surplus is defined for late-run Kenai River king salmon?
3. If there is a demonstrable harvestable surplus of late-run Kenai River king salmon, why has ADFG continued with an in-river bait restriction under the justification of king salmon conservation concerns?

Without a demonstrable harvestable surplus of Kenai kings, the opening of the commercial set net fishery is inconsistent with direction in the UCI fishery management plans and contrary to king salmon conservation measures required by this year’s record low return. The Kenai River Late-Run King Salmon Management Plan [5 AAC 21.359] directs that ADFG shall manage for a biological escapement goal of 17,800 – 35,700. ADFG obviously believes the minimum escapement goal of 17,800 as defined in the UCI management plan for late-run Kenai River king salmon has or will be achieved; otherwise Monday’s opener of the set net fishery would contravene a “top priority” of meeting minimum escapement goals, as publically stated by ADFG officials to the Alaska Board of Fisheries (BOF) last week.

KRSA seeks to further clarify how ADFG has determined that there is a harvestable surplus above the minimum escapement goal of 17,800. Per ADFG’s website, as of Friday, August 3 a total of 15,487 king salmon have been counted at the Kenai Didson sonar. This is the lowest king count ever recorded and still more than 2,300 fish below the minimum escapement goal (greater than ten percent.) Typically 95 percent of the king run has returned by this date, which would project to a total sonar count of just 16,300. Although no formal king escapement projection has been published, ADFG has presumably used an observed late pulse of fish at the counter to assume that late run timing will ensure that the minimum escapement goal will be achieved.

UCI commercial fishing announcement #33 does not state that the minimum escapement goal of 17,800 of late-run Kenai River king salmon spawners has been achieved. Instead, it states that the run is later than what is typical (without defining by how many days), that the 2012 run-timing indices have increased by over 50% in the last ten days (there have been no published run-timing indices available for public review, only indices relative to run-abundance) and that when the 2012 run is compared to final spawning escapements when in-river harvests are subtracted from Didson sonar counts, the king salmon escapement for 2012 will be larger than the last two years and may provide adequate spawning escapement. Based on this new interpretation of information that is clearly “outside” the minimum escapement goal of 17,800 as identified in the current king salmon management plan, ADFG determined that commercial fishing would be allowed during the Monday regular period.

If ADFG is 100% confident that the minimum escapement goal has been achieved for late-run Kenai River king salmon, then one last issue remains. Why is the no-bait restriction still in place for the Kenai River silver salmon sport fishery? If there is no longer a late-run Kenai River king salmon conservation concern because minimum escapement has been achieved, does it make sense to continue a no-bait restriction that will save less than 20 king salmon in-river through August 15 when at the same time the commercial set net fishery will be harvesting many hundreds of Kenai kings per opener?

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