BOF comments needed

The Alaska Board of Fisheries (BOF) will meet in Cordova, Alaska, from December 3-8 to address proposed changes to the Prince William Sound and Upper Copper/Upper Susitna finfish regulations. The Chitina Dipnetters Association (CDA) has submitted 4 proposed changes to the Chitina Personal Use Dip net Fishery (CPUDF) regulations. Two CDA board members, Chuck Derrick and Paul Harrell, will be attending the meeting in Cordova to defend CDA's proposals and oppose several regulation changes submitted by Ahtna, commercial fishermen and Klutina salmon sport fishing guides.

Written public comment on proposed regulation changes, sent online, mail or fax will be accepted by the BOF till November 19. It is of the utmost importance that CDA members and all other dipnetters submit written public comment in support of CDA's proposals numbered 38, 39, 41 and 43. Proposal 18, drafted by the CDA and submitted by the Fairbanks Fish and Game Advisory committee also needs our strong support.

SUPPORT

  • Proposal 18 --- Halt the practice, termed rolling up kings, of hanging drift gill nets so loosely that king salmon are entangled, not gilled

    The practice of rolling up kings by drift gill netters, in the CRD, subverts an early 1990s regulation meant to reduce the king salmon harvest. That regulation limits gill nets used in the Copper River District to a maximum stretch mesh of 6”. Besides the mesh size, only the length and depth of the net is regulated. Nowhere in regulation does it address the amount of mesh hung on the float line, making it legal to entangle kings in loosely hung gill nets. With the low run of king salmon to the Copper River in the last 6 years, the fact that king salmon are an easy target as they mill in the mouth of the Copper River inside of the barrier island and the fact that even in the 1990s the Alaska Board of Fisheries saw fit to protect king salmon entering the Copper River from over harvest, this practice of rolling up kings needs to stopped.

  • Proposal 33 --- Establish a king salmon Optimal Escapement Goal (OEG) in the Copper River of 28,000

    An OEG of 28,000 king salmon would help king salmon stocks in the Copper River rebound from the past 6 years of low returns.

  • Proposal 38 --- Re-set the CPUDF opening date back to “earliest June 1 and the latest June7.

    Prior to 2011the earliest the CPUDF season opened was June 1 and the latest June 7. In 2011 The BOF
    changed the opener to the earliest June 7 and the latest June 15 in response to complaints from up river subsistence fishers that too few early salmon were making it to their fishery, as if the CPUDF was at fault.
    From 2007- 2011 the average harvest in the CPUDF for the first week of June, was 2,572 salmon. As a comparison, in 2014 at the end of the first week in June the commercial drift gill net fleet in Cordova had already harvested 670,000 salmon. Since through radio telemetry and standard salmon tagging the Department of Fish and Game has determined that the majority of the earliest salmon arriving in the Copper River are those salmon which travel to spawning grounds farthest upstream, the early commercial harvest is the determining factor as to how many salmon arrive in the upriver subsistence fisheries, not the small harvest taken in the CPUDF. If sonar counts indicate that there are adequate numbers of salmon moving upstream for the CPUDF to open during the first week in June, then dip netters should be allowed to fish.

  • Proposal 39 --- Increase the CPUDF bag limit to reflect household size

    In the Copper River over the last ten years there has been a 250,000 salmon average annual surplus above the in-river goal. This proposal raises the CPUDF bag limit to match the South Central dip net fishery a much more family size oriented bag limit. The increase would only mean a family of two could take 5 more salmon than the current bag. Where currently a larger family is only allowed, 30 salmon, the same number of salmon as a family of two, the new bag limit would take into account the size of ones family and allow 10 more salmon for each additional household member. If approved the CDA has in its proposal suggested the elimination of the current allowance for supplemental periods where a permit holder, if the sonar counts warrant, was allowed to take 10 additional salmon. This elimination of supplemental periods would help offset any increase in harvest due to the new bag limit.
    The CPUDF is an Alaska resident only fishery supplying salmon for family consumption and with such large surpluses of salmon occurring in the Copper River there is good incentive to pass this proposal.

  • Proposal 41 --- Repeal the regulation reducing the CPUDF allocation to 50,000 salmon if the Cordova commercial fleet is prohibited from fishing for 13 consecutive days or more.

    We remind the BOF that the CPUDF is managed by abundance. Fishing times are established using preseason daily estimates coupled with actual daily sonar counts. If the Cordova commercial drift gill net fleet is not allowed to fish because of poor salmon numbers, then this will also be reflected in low sonar counts and the closing or reduction of fishing times in the CPUDF. For this reason there is no valid justification for reducing the CPUDF salmon allocation for the rest of the season because the commercial fleet is not fishing. Only once, 2008, has the commercial fleet in Cordova not been allowed to fish for 13 consecutive days or more and by the end of the 2008 salmon run, the escapement count showed 140,000 salmon surplus above the 2008 inriver goal. 13 consecutive days does not dictate the number of fish remaining to show up during the rest of the summer. Two bad weeks of poor salmon returns does not dictate the rest of the run.

  • Proposal 43 --- Allocate 3,000 king salmon to the CPUDF

    The CPUDF king salmon bag limit up until 1996 was 5. In 1996 it was reduced to 4 and in 1999 reduced to 1. The 1999 one king limit was based on a BOF determination of the king salmon ANS “amount necessary for subsistence” for the Chitina dip net fishery after the fishery was shown to meet customary and tradition criteria qualifying the fishery for subsistence classification. Two years later after the BOF rescinded that subsistence classification for the dip net fishery, the one king limit was left in place.
    The one king limit may be a major factor in why many Chitina dip netters have left the personal use fishery to rather dip in the Glennallen subsistence fishery where the bag limit is 5 kings. In the last 6 years fishers in the CPUDF were only allowed to retain a king in the first 1-3 weeks of the season.
    In order to let Chitina dip netters harvest unhindered their 1 king salmon the CDA was left with no options other than to ask for a king salmon allocation. The CPUDF has the lowest king bag limit of any in-river fishery.

  • Proposal 44 --- Open the commercial fishing season only after at least one salmon has been counted passing the Miles Lake sonar

CDA is also asking you to submit comments opposing the following proposals which are detrimental to the dipnet fishery.

OPPOSE

  • Proposal 1 -- Change to the Copper River district subsistenc season

    As regulations dealing with the Copper River District (CRD) subsistence season exist now, there is no lack of reasonable subsistence opportunity. Most subsistence fishing around Cordova is done using 50' gill nets. The number of days already open to subsistence fishers is plenty of opportunity to fill their bag limit of 15 salmon for a household of one, 30 for a household of 2 or more plus 10 salmon for each additional household member. This is especially true using a gill net to harvest. Also, many Cordova families are commercial fishers and are allowed, for family consumption, unlimited salmon under homepack regulations.

  • Proposal 35 --- Prohibit the use of mono-filament webbing in dip nets

    A majority of dip netters today use dip nets with mono-filament webbing. The difficulty in removing fish from these nets occurs mainly with smaller sockeye when they become gilled. The larger sockeye and king salmon do not get gilled and thus are removed fairly easily from these nets. There is no evidence that mono-filament over other types of mesh increases released king salmon mortality.

  • Proposal 36 --- Make it illegal to remove a king salmon from the water if intending to release it from a dip net

    This proposal not only would create an enforcement nightmare but shows that the author of this proposal has never dip netted in the turbulent waters of the canyon within the Chitina Personal Use Dip Net Fishery (CPUDF).

  • Proposal 37 --- Create a check station at Chitina to monitor daily harvests in the CPUDF and the Glennallen sub-district.

    The CPUDF is managed using pre-season daily estimates coupled with actual daily sonar counts from the Miles Lake sonar. Fish and Game has never managed the fishery using daily harvest reports. A check station would not only be costly, but of little use in managing our fishery.

  • Proposal 40 --- Require harvest logs of Chitina dip net charter operators

    Harvest data is already supplied on each personal use dip net permit There is no reason to place this extra burden on the one Chitina dip net charter operator.

  • Proposal 42 --- reduce CPUDF salmon allocation to 100,000
  • Proposal 45 --Rescind the regulation calling for mandatory commercial inside closures

    In the last 2 years the Cordova commercial drift gill net fleet has been restricted to fishing outside the closure area till the majority of the king run has moved upriver and still have harvested an average of 10,000 king each year. The inside closure areas' shallow low tide waters affords commercial fishers easy harvest of large numbers of king salmon as they school and mill near the mouths of the Copper River before heading upstream. With the recent poor king salmon returns to the Copper, the inside closure restrictions must remain in place if we are ever to see a rebound in king numbers.

  • Proposal 46 -- Limit the commercial king homepack to the sport fish king bag limit for that area.

The following link takes you to the BOF's online comment submission form:

http://www.adfg.alaska.gov/index.cfm?adfg=process.comments

In the box that says "Board Meeting" select Prince William Sound, Upper Copper/Upper Susitna. Fill out your info and proposal public comments.

The Board of Fisheries job is to weigh how much support or opposition each proposal carries. You can rest assured there will be plenty of opposition to our proposals from commercial and subsistence interests. I can't stress how important it is for you to submit your comments to the Board of Fish before the November 19 deadline.

We on the CDA board are all Chitina dipnetters. We passionately volunteer to promote and protect our ability to the harvest salmon as dipnetters, but we can't do this by ourselves. Please take a few minutes to think about and support the proposals we have submitted. Our proposals support the CDA goal of ensuring continued access for Alaskans to harvest salmon. We can only succeed with public support, your support, the support of everyone who dipnets on the Copper River. If dipnetters remain silent, if they don't submit public comment in support of dipnetting on the Copper River, the BOF can only assume the Copper River personal use fishery is not important to people. We know better than that. If you are a person of few words, submit a simple "I support the Chitina personal use fishery and proposals 38, 39, 41, 43 and 18" comment. If you have a few (or many) more words in support of our joint passion, please take the time to participate in the public process and submit your expanded comments. Forward this message to any and all your dipnetter friends. Stress to the Board of Fish how important dipnetting is to you, your family and your way of life.

Thank You,
Chuck Derrick
Pres. Chitina Dipnetters Assn

Feel free to call me with any questions at 907-488-3093