2021 Board of Fish proposal comments

Public Comments Concerning Submitted Proposals To The December 2021 PWS/Upper Copper and Upper Susitna Finfish BOF Meeting

The Chitina Dipnetters Association recommends the following support or opposition to these proposals put before the Alaska Board of Fish at the December, 2021, meeting in Cordova. The Proposal Book for this meeting with the full proposal texts may be found at the Board of Fish website (http://www.adfg.alaska.gov/static/regulations/regprocess/fisheriesboard/pdfs/2021-2022/proposals/pws.pdf)

Prop. 5 - support
Establish an Optimum Escapement Goal (OEG) for Copper River chinook salmon, increasing the escapement goal to 24,000-40,000.

Prop. 6 - oppose
Require in-season reporting of harvest for the upper Copper subsistence, sport and personal use fisheries.
This would require that dipnetters report daily harvest within 3 days of catch rather than end-of-season harvest reporting. This is a recurring proposal to the BOF. It has been rejected by the BOF each time mainly because F&G says in-season reporting is not needed to manage these upriver fisheries. Management of these fisheries and the in-river salmon goal is dictated by actual daily sonar counts at the Miles Lake sonar.

Prop. 7 - oppose
Prohibit guiding in subsistence finfish fisheries.
Many people rely on guided salmon dipnet harvest to supplement their annual family food supply.

Prop. 8 - oppose
Prohibit dipnetting within 500yds below and 100 yds above any stream entering the Upper Copper River.
This would eliminate dipnetting near the mouths of O'Brien Creek, Haley Creek, the Chitina River and, if I read it right, any small creek entering the Copper, further limiting harvest opportunity. Dipnetting is already limited, by regulation, to the main stream of the Copper River and prohibited in any stream entering the Copper.

Prop. 9, 10 & 11 - oppose
Prohibit dipnetting from a boat in the Upper Copper River District.
Public access along the Copper River is very limited for shore based dipnetting, especially in the Glennallen sub-district of the Upper Copper River District. Because access is limited, many dipnetters have opted to use their own boats to access the river and to dipnet salmon. Dipnetters have a set annual limit and once that limit is reached, they are done for the year. Dipnetting from boats is a popular means of obtaining that limit.

Prop.12 - oppose
Prohibit dipnetting from a boat when within 50' of a person dipnetting from shore in Chitina Subdistrict.
Talk about an enforcement nightmare.

Prop. 13 - oppose
Prohibit dipnetting from a boat within 75' of any operating fish wheel.
Enforcement nightmare.

Prop. 14 &15 - oppose
Prohibit use of gillnet mesh in dipnets because it harms king salmon to be released that are tangled in the mesh.
Alaska regulation 5AAC 39.105 states a dipnet mesh must be less than 4.5" stretch mesh. In my experience, the only problem with releasing fish from gillnet mesh is the smaller sockeyes that actually get stuck halfway through the mesh. King salmon, no such problem.

Prop. 16 - oppose
Prohibit the use of depth or fish finders on boats in the upper Copper River District.
The only person I know that tried to use a fish finder in the Copper said it was of little use in the fast, heavily silted water.

Prop. 17 - oppose
Establish specific permit and bag limits when dipnetting from a boat in the Glennallen subdistrict. (The Glennallen subdistrict is the subsistence area upstream of the bridge, not a personal use area.)
Access to shore based dipnetting upstream of the bridge is very limited due to private land ownership and few roads accessing the river. Dipnetting from boats is a means by which some people are able to harvest their salmon. Shore and boat dipnetting should continue under a unified permit structure — there is already a checkbox for selecting gear type when applying for the permit.

Prop. 18 - support
Extend lower boundary of the Chitina subdistrict 1/2 mile downstream.
This is a Chitina Dipnetters Association submitted proposal to address a safety issue. A favorable and high use area for drift dipnetting from boats lies at the downstream end of Woods Canyon, on the east side of the Copper River, just upstream of the lower boundary of the CPUDF. This short drift area is only approximately 250 yards long, has a gravel bottom and stays relatively snag free, saving the loss of $150+ dipnets. This short drift area has become the go-to spot for boat dipnetters and often becomes very congested with 15 or more boats drifting the same area. Extending the existing CPUDF lower boundary 1/2 mile downstream would allow more spacing between boats, and alleviate the congestion of boats that occurs now.

Prop.19 - oppose
When by June 1 the commercial harvest is 50% below the 10 year average, then the Chitina Personal Use sockeye allocation would be reduced from 150,000 to 50,000.
The Personal Use harvest times and lengths are dictated by actual sonar counts. When run numbers are low, it shows in the sonar counts and F&G reduces the PU dipnet opening times and lengths accordingly to meet in-river goals. When commercial harvests are low it is reflected in low sonar counts triggering reduced fishing time in the PU fishery. To reduce the PU fishery allocation on top of reduced fishing time is a double hit. If the run rebounds 2 weeks later, the PU fishery would still be stuck with a 2/3s allocation reduction.

Prop. 20 - oppose
Reducing the annual limit in the Chitina subdistrict to 15 salmon for a household of one and 30 salmon for a household of more than one.
CDA fought hard to get the Personal Use annual limit raised to 25 for the permit holder and 10 fish for each additional household member. F&G supported this bag limit increase at the 2014 Cordova PWS/Copper River finfish BOF meeting. It standardized the PU annual limit between South-Central Alaska PU fisheries and the Chitina PU fishery, thus eliminating confusion between the PU fisheries and making it a more equitable harvest for larger families.

Prop. 21 - support
Amend the opening date of the Chitina PU. fishery from June 7 to June 1.
If salmon sonar numbers warrant it then the Chitina PU fishery should open On June 1 as it did in the past.

Prop. 22 - support
Eliminate the Customary and Traditional finding for finfish other than salmon in the Chitina subdistrict.
If there is no customary and tradition finding for salmon in the Chitina Subdistrict, then why should there be a positive finding for other finfish?

Prop. 41 - oppose
Repeal mandatory closed waters from the Copper River King Salmon Management Plan.
Mandatory inside closures during commercial fishing statistical weeks 1&2 were initiated to protect those early run kings, that thru F&G radio telemetry programs, were determined to be those fish that go farthest upriver to spawn and supply the upper Copper subsistence fishery. To say that in the last several years the king salmon population has been healthy is a stretch as I remember upwards 20 years ago that today's total annual king run for the Copper River of say 60,000 is what the commercial fishermen out of Cordova were harvesting and we still met the total in-river goal.