At the 11th hour the Bering Sea Fishermen’s Association (BSFA), on behalf of the Kuskokwim Salmon Management Working Group, submitted an Agenda Change Request (ACR) for the upcoming Board of Fisheries meetings that will be held this winter. Fisheries concerns for the various regions of the State (e.g., AYK, Southeast, Bristol Bay, etc.) are considered on a three-year cycle, and the Kuskokwim saw it’s turn last year. During that time a new Fisheries Management Plan – one that was co-written by representatives of ADF&G, USFWS, ONC, AVCP and Napaimute – was approved by the Board.
The plan was predicated on using the preseason forecast and Bethel Test Fish tool – the BTF is used as an index of run abundance, to determine run timing and project what the escapement will likely be.
What follows is the crux of the Kuskokwim Management Plan:
In the king salmon fishery, management will be based on preseason and inseason escapement projections.
When the projected escapement of king salmon is above the drainagewide escapement goal range, the subsistence fishery will be open seven days per week with unrestricted gillnet mesh size. The commercial and sport fisheries will be managed to provide harvest opportunity on surplus king salmon in excess of escapement and subsistence needs.
When the projected escapement is below the drainagewide escapement goal range; the sport, commercial, and subsistence king salmon fisheries will close.
However, after the disastrous king season this year in regards to escapement, it was felt that the new management plan was inadequate to provide for meeting escapement and providing reasonable opportunity for middle and upriver subsistence fishers; in other words a sustained yield. Considering how far off the preseason projection was and the inability to interpret the BTF results in regards to run timing, one must ask in low abundance years how realistic it is to equitably spread the harvest out throughout the entire drainage while attaining the escapement?
A seasoned US Forest Service Forest Supervisor, one embroiled in the salmon controversy of the Pacific Northwest (where the salmon, steelhead and bull trout were being either being federally listed as threatened or endangered), once proclaimed that there are no solutions…only compromises.
One thing is for certain, we don’t want to compromise the king salmon to the point where no one can fish on them; hence the impetus for BSFA submitting the Agenda Change Request.
Below is the ACR submitted by the BSFA and Napaimute’s Letter of Support (other entities like the Village of Chuathbaluk and AVCP also have written letters of support).
Napaimute’s Letter Of Support
To The Alaska Board of Fisheries:
The Native Village of Napaimute – located thirty miles upriver from Aniak and 177 miles upriver of Bethel in the middle Kuskokwim River – supports the Agenda Change Request submitted by the Bering Sea Fishermen’s Association.
During the 2012/2013 Board cycle, the Board approved a new Kuskokwim Management Plan that states: (a) The purpose of this management plan is to provide guidelines for management of the Kuskokwim River salmon fisheries that result in the sustained yield of salmon stocks large enough to meet escapement goals, amounts reasonably necessary for subsistence uses, and for nonsubsistence fisheries. The department shall use the best available data, including preseason and inseason run projections, test fishing indices, age and sex composition, harvest reports passage escapement estimates, and recognized uncertainty, to assess run abundance for the purpose of implementing this plan.
(b) It is the intent of the Board of Fisheries that the Kuskokwim River salmon stocks shall be managed in a conservative manner consistent with the Policy of the Management of Sustainable Salmon Fisheries under 5 AAC 39.222 to meet escapement goals ad the subsistence priority.
(c) In the king salmon fishery,
(1) when the projected escapement of king salmon is below the drainagewide escapement goal range, the commissioner shall, by emergency order, close the commercial, sport, and subsistence king salmon fisheries.
Unfortunately, the escapement of king salmon was not realized and most likely substantially below the lower bound of the drainagewide goal of 65,000…possibly being only half of that. Although lower river subsistence fishers – where the hub city of Bethel with over 7,000 people is located – were happy with their catches, many fishers in the upper river sections did not meet their needs. There are two important caveats to keep in mind here – that there is one ANS determination for the entire river and that up to 85% of the subsistence harvest occurs in the lower river.
In the table below showing the disparity of subsistence harvest throughout the Kuskokwim drainage, the villages of Napaskiak, Bethel and Akiak are in the lower river – all others are middle and upper river villages. Although 2012 and 2013 data are not available, the numbers certainly track with the reduced escapement numbers.
As the 2013 season progressed, the department and some members of the Kuskokwim Salmon Management Working Group took the success of the lower river fishes as an indication of relatively good abundance, but for much of the season upper river fishers expressed concern over how difficult it was to catch kings.
To some people, the Bethel Test Fishery results indicated a concern for run strength and resultant escapement levels relatively early on in the season. You can see from the graph below that the CPUE was much lower than in 2010, a year that up until then was the lowest escapement on record. However, throughout the majority of the 2013 fishing season, the department felt that the escapement goal would be met.
As noted below the graph, the only reason that escapement was made in 2012 was because subsistence restrictions were implemented for 35 days which significantly reduced harvest.
Looking at the graph below, you can see that 2013 was the second year in a row where the preseason forecast was grossly overestimated.
The following News Releases predicted total runs of kings near 200,000 for the years 2012 and 2013.
On the surface this letter of support might seem more like a concern over allocation of the king salmon resource…but that is not the case. As the Agenda Change Request states: (6) Conservation and meeting escapement goals are the main objective of this ACR, to the extent that any in-river harvest may be allowed in the near future, achieving allocative neutrality (in a historical context, throughout the drainage) is a secondary objective.
(7) In-season management by ADFG in 2012 and particularly in 2013 may have resulted in a reallocation of fish from upper river users to lower river users. That will be a matter for the Board to determine.
The reallocation of fish to downstream fishers resulted in very few kings passing through the middle and upper portions of the river…including the tributaries. Consequently, as is also noted in the ACR, not one of the individual monitoring project escapement goals were met, and all but one saw the lowest escapements on record.
The Sustainable Salmon Fisheries Policy states in section (5) in the face of uncertainty, salmon stocks, fisheries, artificial propagation, and essential habitats shall be managed conservatively as follows: (A) a precautionary approach, involving the application of prudent foresight that takes into account the uncertainties in salmon fisheries………
(iv) that where the impact of resource use is uncertain, but likely presents a measurable risk to sustained yield, priority should be given to conserving the productive capacity of the resource;
Given the uncertainties associated with the preseason forecasts and the inability to assess what the escapement will be, it is time to follow the Sustainable Fisheries Policy and take a conservative approach.
Thank you for considering the Agenda Change Request submitted by the Bering Sea Fishermen’s Association.