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KRSA’s Policy Approach for responses to in-season management actions taken by the Alaska Department of Fish and Game in fisheries that harvest early and late-run king salmon of Kenai River origin

June 15th, 2012

KRSA’s Policy Approach for responses to in-season management actions taken by the Alaska Department of Fish and Game in fisheries that harvest early and late-run king salmon of Kenai River origin

Purpose: provide KRSA members with a framework to understand this issue, provide the basis for KRSA public responses to in-season management actions, and provide a framework to implement KRSA’s future efforts on this issue which includes preparation for the 2014 Board of Fisheries Upper Cook Inlet meeting.

Important touchstones to fisheries management when shaping our response to the management of king salmon:

1. Fish come first – sustainability of the resource is the top priority;
2. The Alaska Constitution sets the goal for management of renewable resources as sustainable and with maximum benefit;
3. The “precautionary principle” states that in times of shortage or uncertainty of fisheries data it is best to err on the side of caution;
4. The burden of conservation is a shared responsibility amongst all users of the fishery;
5. Tension exists between achievements of these goals—which are allocative—and that is the purpose for the Alaska Board of Fisheries (BOF) and the Board process. The implementation of fisheries management policy is the responsibility of the Alaska Department of Fish and Game (ADFG).
6. Where clear directive is absent from the BOF regarding conservation action, ADFG is put in the position of having to use their best judgment to share the necessary burden of conservation amongst user groups.

KRSA’s viewpoint regarding management of early and late-run king salmon of Kenai River origin in 2012

A. KRSA contends that ADFG is prosecuting the 2012 seasons for both early and late-run king salmon of Kenai River origin “outside” of the BOF-approved codified management plans that govern the in-river fisheries.
a. In support of this contention we offer the following: ADFG is “outside” the in-river plans because these plans include escapement goals stated as specific numerical ranges intended to be achieved in-season utilizing sonar to establish a credible estimate of in-river return of king salmon. ADFG now utilizes an array of assessment tools in an effort to index the abundance of king salmon entering the Kenai River. Their stated goal for management is now not a specific numerical range but a “sustainable” situation due to unreliable sonar estimates that are not expected to become trusted for at least two years.
b. Sustainability is generally defined in the Policy for Sustainable Salmon Fisheries but on a case by case basis, the definition will be situationally defined as necessary for the specific fishery. “Sustainable” is a far more vague target than a specific numerical range. In the existing in-river king salmon management plans ADFG is charged with the responsibility to manage for escapement goals that are stated as a specific numerical range. Without specific numbers from a reliable sonar count these goals cannot be managed.
c. In the early and late-run Kenai River king salmon management plans, tools were envisioned to be utilized when possible as a “dial” than as an on/off switch, meaning that optimally actions could be taken in a step wise manner to dial up or dial down harvest potential rather than abruptly removing all opportunity.
d. Experience enables us to estimate numbers of fish harvested or saved as the result of implementing the various management tools. In the past, these numbers then could be compared to the specific numerical ranges. When the target is “sustainable” and not based on actual sonar fish counts it is much harder, in fact nearly impossible, to make this same comparison.

For example: Implementing catch and release for early-run king salmon in the Kenai River will kill approximately 50 fish more for the remainder of the 2012 season compared to a total closure. In the past, 50 fish then would be subtracted from a projection of the total in-river return made from sonar data, with the goal being realization of a spawning escapement equal to or greater than the lower bound of the escapement range. Without reliance on sonar ADFG can no longer make this calculation.

This leads us to ask the following: If harvest of king salmon were allowed in the middle river after July 1 one could estimate that an additional 100 or so early run fish would be killed. As a comparison, in the normal prosecution of the Kasilof River Salmon Management plan prior to July 1, commercial fisheries targeting Kasilof River sockeye salmon typically harvest 50 to 150 early-run Kenai River king salmon. If these harvests were/are allowed would we still be managing to sustainability? If the sport angler is being required to practice catch and release and/or not use bait to save 50-150 kings, shouldn’t the commercial fishing industry be required to share this burden of responsibility?

e. In summary, it is KRSA’s contention that ADFG is operating outside of the codified management plans for the in-river early and late-run Kenai River king salmon fisheries. The target of their management actions is vaguer than in the past and the vague nature of their “sustainable” target makes it impossible to evaluate management actions that result in savings or killing of relatively small numbers of fish. What ADFG is effectively doing is using their best judgment to share the necessary burden of conservation amongst all users of the fishery. However those management actions can result in significant differences in economic value realized for diverse beneficiaries. There will be winners and losers and that is what is called “allocation”. Allocation is the responsibility of the Alaska Board of Fisheries, not the Alaska Department of Fish and Game. When ADFG operates outside of management plans, it adopts allocative powers normally reserved to the BOF.

B. As stated above, the fish come first. When striving for the sustainability of early and late-run Kenai River king salmon, KRSA cannot objectively evaluate whether sustainability is assured or jeopardized by the addition or subtraction of small numbers of fish to the spawning population. Therefore, KRSA does not know if we should be comfortable and supportive of catch and release, argue for slightly more opportunity that would surely help the economy of the region or argue for a total closure to the taking of all king salmon in an effort to put every fish possible on the spawning ground.

C. KRSA recommends that the early and late-run Kenai River king salmon management plans be addressed by the BOF. The difference in the technical capability assumed when these management plans were adopted and capability to estimate in-river returns today must be reconciled.

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