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KRSA Agenda Change Request to the Alaska Board of Fisheries – Part One

September 19th, 2012

KRSA has submitted an Agenda Change Request (ACR) to the Alaska Board of Fisheries (BOF), which will be heard at the BOF work session October 9 – 11. The request asks the BOF to consider putting the topic on the agenda of its meeting cycle for the year. Typically, the BOF meets every three years to consider proposals – the ACR process is the only way for topics to be considered out of cycle.

Exerpts of the KRSA ACR:
1) STATE IN DETAIL THE NATURE OF THE PROBLEM. Address only one issue. State the problem clearly and concisely. The board will reject multiple or confusing issues.

Record low abundance of late-run king salmon of Kenai River origin combined with changes in the manner used by the Alaska Department of Fish and Game (ADFG) to estimate abundance of late-run king salmon have rendered 5 AAC 21.359 Kenai River Late-Run King Salmon Management Plan inoperative and obsolete. Late-run Kenai River king salmon are an incredibly important stock of fish. Alaska’s Policy for Management of Sustainable Salmon Fisheries mandates wild salmon stocks be maintained at levels of resource productivity that assure sustained yield. The existing plan does not assure the long term sustainability of the stock nor does the current language of the plan provide for the orderly conduct of traditional fisheries under current conditions.

The current management plan for late-run Kenai River king salmon was developed during an extended period of large king salmon returns and does not include effective provisions for management in low run years. The 2012 return of late-run Kenai River king salmon will likely be the smallest on record, achieving the minimum goal of 17,800 spawning fish only by virtue of almost total closure of the sport, personal use and commercial set net fisheries that traditionally harvest these fish. The low return realized in 2012 falls on the heels of other low returns observed in 2009, 2010 and 2011. The 2013 return is also expected to be low based on this year’s numbers; hence, this issue cannot wait for the next scheduled 2014 Upper Cook Inlet (UCI) Board of Fisheries (BOF) meeting.

NEW INFORMATION since the last UCI BOF meeting indicates that management under the current plan failed to provide for minimum escapements specified in the plan in recent years. At the last UCI meeting in 2011, the Board was advised by ADFG that split beam sonar signal interpretations based on “echo length standard deviation” or ELSD would replace the prior method based on “target strength” or TS, which was providing sonar estimates biased high by an unknown amount due to “sockeye contamination.” ADFG felt that the ELSD method could be used to correct apparent biases in the TS sonar estimates, and therefore provide an accurate accounting of fish numbers. However, since that meeting, the ELSD method was subsequently rejected by ADFG due to continuing concerns of sockeye contamination and replaced with Didson sonar estimates and related abundance assessment indices, starting in 2010.

Application of the current technology used by ADFG to estimate late-run Kenai River king salmon abundance in 2012 leads to the conclusion that minimum escapement levels were likely not achieved during 2009, 2010 and 2011. Thus according to ADFG fishery data, this important stock of fish has barely met or has failed to meet its minimum escapement goal for four straight years, a strong indication that late-run Kenai River king salmon are in a dangerous state of decline and must receive additional protection.

The necessary management decisions taken by ADFG to meet the minimum escapement goal for late-run Kenai River king salmon resulted in extreme changes of fish allocation among fisheries. Because of the complex and interrelated nature of the UCI mixed stock fisheries and the potential allocative nature of any change in management of king salmon under low run conditions, this issue is most appropriately addressed by the BOF.

KRSA seeks the following general outcomes should the BOF accept this agenda change request:
• The sustained yield of this vitally important stock of fish should be maintained at acceptably healthy levels to support the fisheries dependent upon late-run Kenai River king salmon. To accomplish this outcome escapement objectives must be defined in terms of the current assessment tools and must be achieved. However, the problem is that the escapement goals established in the current management plan are based on the obsolete split beam sonar counting method. Therefore the escapement goals need to be reviewed and revised as appropriate by the BOF to accommodate changes to Didson and/or other indices currently employed by ADFG.
• The current management plan only covers the time period July 1-July 31 while in 2012 an estimated one-third of the total run returned after July 31. To provide for sustained yield it is critical that the management plan fully cover the time period encompassing the length of the run and not just July 1-July 31.
• The management plan governing the fisheries for late-run Kenai River king salmon should be amended in such a manner that effectively addresses challenges posed by the unprecedented low abundance of late-run king salmon. Total closure of the sport, personal use and commercial set net fisheries must be the tool of last resort but KRSA questions whether all fishing opportunity for sport or commercial fisheries should be lost when only marginal or deminimis savings of fish will likely be realized.
• The burden of conservation must be more equitably shared between the sport, personal use and commercial set net fisheries particularly when restrictions are implemented, yields are estimated to be low or when achievement of the escapement objective is in doubt. Specifically, ADFG needs tools to step up and step down the fishing power of the commercial set net fishery in an effort to minimize the incidental harvest of late-run kings in that fishery and pair these tools with the ones currently used in the sport fishery. The on/off switch strategy for the commercial set net fishery now practiced is not constructive for fish or users in years of low abundance.
• Clarification is needed to the effect that meeting the minimum late-run Kenai River king salmon escapement goal takes precedence over not exceeding the upper end of the Kenai or Kasilof sockeye in-river or optimum escapement goals, respectively.

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