A personal comment to Copper River salmon proposals 51, 52, 53

Hello Chairman Carlson-Van Dort and Members of the Board of Fisheries,

My name is Andy Couch. I live in Alaska’s Mat-Su Valley near Palmer and have fished for and eaten Upper Copper River salmon since the mid-1970s. With dramatic declines in salmon returning to Mat-Su Valley streams, during the past 5 years, my wife ( Frede Stier) and I have harvested a larger portion of the salmon we eat, or share with friends, from the Copper River. In the 1970s I caught king salmon by sport fishing the Gulkana River and caught both sockeye salmon and king salmon by personal use dip netting at Chitina. Since then, I’ve harvested king salmon by sport fishing in the Gulkana and Klutina River, and more recently my wife and I have harvested most of our sockeye and king salmon by subsistence dip netting the Copper River upstream from Chitina.

I support the concept of Proposals 51, 52, and 53 — but believe that each proposal (opening the Copper River Salmon Management Plan) — if adopted as written — may not be conservative enough to ensure adequate spawning escapements of early returning Copper River king and sockeye salmon, while also sharing reasonable subsistence, personal use, and sport fishing harvest opportunities with the thousands of Alaskans who participate in Upper Copper River fisheries on an annual basis.

I, therefore, suggest that the board consider the following ideas and concepts when considering / adopting changes appropriate for the management plan:

Most of the commercial king salmon harvest occurs during May (before the department has a good iassessment of the inseason abundance of king salmon). Because of this species’ earlier run timing, over harvest by the commercial fishery during May can jeopardize attainment of king salmon spawning escapement goals, and exacerbate restrictions and harvest closures for all Upper Copper Users groups — as occurred in 2024.

* Although the Department develops both daily and cumulative salmon sonar count objectives for each date of the season starting on or before May 15 — during 2023 and 2024 the department has not met a single one of the daily or cumulative objectives during the entire month of May. (Mark Miller with the Wrangell — St. Elias Park Service) has a graph demonstrating the significantly larger rate of commercial harvest during May compared to other portions of the season.

Even though not a single daily or cumulative salmon sonar objective has been achieved during the month of May for the past two seasons, ADF&G’s commercial manager stated that he managed the commercial fishery “Conservatively during 2024,” as he had restricted fishing periods to 12 hours on Mondays and Thursdays, closed waters in the expanded Chinook salmon closure area, and closed the 4th period in May to commercial fishing. Despite these actions commercial harvests during the 4 May periods that were fished totaled 253,183 sockeye, 6,053 kings, 5,613 chum salmon, and 65 coho salmon. Meanwhile the cumulative sonar count for the entire month of May was 34,587 salmon compared to the cumulative objective of 148,339 during the same time period. Conservative management might better be defined as meeting some level of daily and cumulative sonar objectives throughout the run.

While some of the salmon harvested during May were likely not bound to spawning areas upstream of the Miles Lake sonar on the Copper River, it is still worth considering that during May 2024: More than 7 times as many salmon (264,914) were harvested in the Copper River Commercial Fisheries as were counted past the sonar (34,587). Management Plan Recommendations: The harvest data suggests escapement needs for discrete early-run Copper River salmon stocks may be better served if the commercial fishery were managed on a step-up basis rather than the current [STEP-DOWN BASIS] which perpetuates over harvests of salmon stocks returning during May (and particularly during later spring / colder water years that appear to retard upstream migration).

Rather than opening by the calendar — perhaps the Copper River commercial fisheries should only open after a specific number of salmon are counted past the sonar (the cumulative management objective may be an appropriate number, that could better ensure adequate spawning escapements of discrete early-returning salmon stocks, while also better sharing harvestable surplus salmon throughout the run amongst lower and upper river user groups).

Opening the commercial season after a specific level of salmon passage above the sonar would be a good start, and with proper management, could also better ensure more consistent commercial harvest opportunities and spread more consistent salmon harvest rates throughout the run. Such conservative early season management is less likely to be interrupted by emergency closures. Consistent with managing on a step-up basis, however, it is important to note that during May, even when not allowed to fish in the expanded Chinook Salmon closure area, and only fishing a 12-hour period on Mondays and Thursdays, the commercial fleet has demonstrated the ability to harvest over 7 times as many salmon as counted passing the sonar. Therefore, some consistency in sonar passage should be measured before each commercial opener. Achieving an additional cumulative management objective before allowing each successive commercial opener would: better meter salmon harvests and escapements throughout the run, better share harvestable surplus salmon amongst ALL user groups, and more closely follows regulatory language in the Policy for Management of Sustainable Salmon Fisheries 5 AAC 39.222.

Additional Considerations:

Early-run Copper River salmon provide all user groups some of the first readily available fresh salmon of the year, and are therefore highly valued by all user groups. Economic benefit for the Upper Copper River sport fishery is directly tied to the number of days of fishing with reasonable king salmon harvest opportunity, and earlier arriving king salmon to the Upper Copper River brings substantially more economic benefit.

Although triggering the start of the commercial season by salmon passage at the sonar may, at times, delay commercial harvests, Copper River salmon will remain the earliest net -caught Alaska salmon available, and, therefore, should maintain their status of premium price for first-of-the-season quality salmon.

Thank you for your efforts in conserving Alaska’s wild king salmon, and in providing reasonable harvest opportunities for all Alaskans sharing a limited public resource.

I look forward to hearing and watching your efforts for the Copper River resource and its users,