On May 9, the Alaska Department of Fish and Game (ADFG) announced that the sport fishery for early-run king salmon in the Kenai River will begin under a restriction to catch and release only. According to regulation, the objectives for the early-run are achieving an Optimal Escapement Goal (OEG) of 5,300 – 9,000 and providing fishing opportunity throughout the run.
The justification for this emergency order (EO) restriction is that the preseason outlook for total run size in 2013 is approximately 5,300 fish which if realized would make the 2013 run the smallest on record over the past 28 years. The preseason forecast matches the minimum threshold of the current escapement goal.
KRSA finds it extremely unfortunate that production of king salmon is historically low throughout Alaska. As a fishery conservation organization that advocates strongly for the health of the resource and the economic values that our fisheries contribute, we understand and express sincere empathy to our members and the many others in the region whose businesses depend heavily on participation in sport fishing for king salmon.
As detailed in the subsequent background section, there are multiple issues that are at the root of great concern, including: the late timing of the EO announcement for the catch and release restriction, questionable science used in both the early-run and late-run run reconstructions of Kenai kings that effectively lower the escapement goals, and the problematic inseason use of an expansion factor for Didson sonar counts.
Yet after careful and thoughtful consideration of the many factors involved in this management action, KRSA finds it compelling to side with a precautionary approach and support the restriction to catch and release. If we are looking at the smallest run on record then we have no choice but to put on the brakes now and start the season with no harvest.
In 2013 the early-run of Kenai kings will start the season with catch and release only. ADFG issued its emergency order on May 9, and the justification stated:
As provided by 5 AAC 57.160 Kenai River and Kasilof River Early-Run King Salmon Management Plan (a), the purpose of this management plan is to ensure adequate escapement of early-run king salmon into the Kenai River. The department’s management strategy for 2013 is to achieve the optimal escapement goal (OEG) while providing sport fishing opportunity throughout the run.
The early-run Kenai River king salmon OEG is 5,300 to 9,000 king salmon. The preseason outlook for early-run Kenai River king salmon is for a total run of approximately 5,300 fish. If realized the 2013 run would rank as the lowest run measured (28th out or 28 years), be similar in abundance to the 2012 run, and be less than one-half the 1986-2012 average run of approximately 14,000 fish. Under this scenario, the early run can sustain little harvest without jeopardizing achievement of the OEG. In 2012 the total run was 5,600 fish for the early run. There is little indication to date of a change in the low Chinook production trend observed statewide. It is therefore prudent to start the early run fishery as catch-and-release until inseason data indicates some harvest can be allowed or alternatively further restriction is necessary to meet the OEG.
In spite of the anticipation of a record small run there are well-meaning stakeholders who have questioned whether this course of action is the right decision and others in the community have voiced opposition to the use of catch and release as a tool to provide fishing opportunity throughout the run.
Opposition to the EO for catch and release focuses on five issues:
- the late timing of the release of this EO;
- this is the first time ever that ADFG has put enough faith in the pre-season outlook to use it as a justification for a restrictive emergency order;
- few fish will be harvested prior to the point in the 2013 run when data will be available upon which to justify a restriction;
- the regulatory management objective for escapement is an OEG of 5,300-9,000 rather than the lower Sustainable Escapement Goal (SEG) of 3,800-8,500; and
- a general dislike of catch and release by a segment of the public.
Good communication between ADFG and the public is essential – the issuance of the EO restriction to catch and release came out unsatisfactorily late. While preseason king salmon restrictions for other major king fisheries across the state came out in mid-April, the announcement for this EO was not released until the second week of May. During that interim guides and businesses were making commitments that cannot be broken without significant economic loss. ADFG should be accountable for the timing of this emergency order. Questions remain why the preseason forecast for the early-run Kenai kings only came out on April 17 instead of earlier in the year as did the preseason forecast for late-run Kenai kings on February 5.
Some argue that ADFG has never used the preseason outlook as a justification for starting the season in a more restricted manner. Preseason outlooks in prior years have been viewed as not accurate enough. ADFG now feels that the new Didson sonar and better modeling improves their confidence in preseason forecasts and assists them to more quickly and accurately identify small runs inseason as they happen. ADFG is using preseason forecasts in their decision making process for both the early and late runs of Kenai kings.
If there is a small run, some assert that not many fish will be harvested prior to the 25 percent point in the run when adequate in-season data becomes available. It is also argued that if the run is small it is unlikely that the fish saved at the start would be enough to allow expansion of harvest later in the run. KRSA understands these arguments.
The OEG of 5,300-9,000 for early-run Kenai kings has been the management objective since 2005 and was strongly supported by KRSA at the time of its passage as a tool to guard against loss of future returning kings resulting from potential overharvest. The Alaska Board of Fisheries (BOF) and ADFG did not address the issue of a new SEG for early-run Kenai kings this winter, and instead will consider the issue during next year’s regular meeting cycle for Upper Cook Inlet. This is in contrast to actions taken by the BOF for late-run Kenai king salmon, when a new SEG was taken up out of cycle and has been implemented for 2013. At a later date KRSA will provide a more in-depth overview of ADFG’s new SEG for early-run Kenai kings, and outline our general concerns about the scientific uncertainties associated with ADFG’s new run reconstruction modeling efforts.
5,300 remains the management target in 2013 for the lower end of the OEG range of early-run Kenai kings. The 2012 season ended with only 3,339 Didson counts (fish counted), close to 2,000 fish below the minimum. However, a significant difference exists between how Didson counts will be used inseason during 2013 than in 2012 due to the introduction of the “expansion factor”.
This year for the first time ADFG will apply an expansion factor of 1.55 inseason during the early run to the Didson count to account for the number of fish passing outside of the Didson beam (this means that the Didson counts are multiplied by 1.55 to come up with the “actual” number of fish making it past the counter). Use of this multiplier is related to the new run reconstruction models for both the early-run and late-run escapement goals. The factor is derived from comparisons to “true abundance” estimates from mark-recapture studies. Confounding the necessity of the multiplier is the transition from the old sonar location in a tidal area to a new location in a non-tidal zone, about five miles further upstream. Once the transition to the new sonar location is complete in a few years there will be no need for the expansion factor.
In its post-season analysis for 2012 early-run Kenai kings, ADFG scaled up its inseason Didson count of 3,339 by an expansion factor to get to a final escapement estimate. But use of the expansion factor inseason this year means that a minimum of 3,420 Didson counts will be the management target instead of 5,300 Didson counts used in 2012. The 35 percent reduction in the minimum escapement number necessary to allow for fishing opportunity is a significant reduction in the minimum escapement goal for 2013. Thus the use of an expansion factor for the first time ever inseason is a deviation from past practice, is a source of significant uncertainty and concern, and use of it increases risk of overharvest.
Another area of controversy is catch and release, an important and well researched management tool. In the Kenai River, research on fishing without bait and with a single hook suggests that the mortality does not exceed two percent of the in-river run over the course of the season. Catch and release is the only tool to achieve the “fishing opportunity throughout the run” objective in regulation.
After careful and thoughtful consideration of the many factors involved in this management action, KRSA finds it convincing to prudently follow the precautionary principles found in the Alaska Sustainable Salmon Policy. In the face of uncertainty, salmon stocks SHALL be managed conservatively and priority is given to conserving the productive capacity of the resource. As such, KRSA supports the preseason restriction to catch and release. We continue to support the OEG, more than ever, and are extremely concerned with the “expansion factor”. If we are looking at the smallest run on record then we have no choice but to put on the brakes now and start the season with no harvest.