Juneau, we have problems

From 5 AAC 21.353 Central District Drift Gillnet Fishery Management Plan: (a) the purpose of this management plan is to provide adequate escapement and a harvestable surplus of salmon to the Northern District Drainages (of Upper Cook Inlet) and to provide management guidelines to the department. . . . — Bracketed language added.

Problem #1

When more than 2.3 million sockeye salmon are returning to the Kenai River, the amount of drift gillnetting allowed under the drift gillnet plan is too great (without management reduction) to achieve the plan’s purpose of, “. . . to provide adequate escapement and harvestable surplus of salmon to the Northern District . . . ,” as stated in the first sentence / continued through the paragraph. After three consecutive years where the Alaska Department of Fish and Game (ADF&G) has attempted to harvest large harvestable surpluses of Kenai River sockeye salmon (under this plan), but failed to attain the two largest sustainable escapement goals (SEGs) for coho salmon in Upper Cook Inlet, this problem is obvious and well documented — and has a much longer history.

Article 8 Section 4 of the Alaska State Constitution states, “Fish, forests, wildlife, grasslands, and all other replenishable resources belong to the State shall be utilized, developed, and maintained on the sustained yield principle, subject to preferences among beneficial uses.”

Certainly both Deshka River coho salmon and Little Susitna River coho salmon easily qualify as “replenishable resources belonging to the State,” and therefore require maintenance on the sustained yield principle as mentioned in Article 8 Section 4. The State Constitution, however, provides few guide lines as to how, sustained yield, “subject to preferences among beneficial uses,” should be interpreted. For example: Alaskans who primarily harvest salmon from Northern Cook Inlet waters / drainages may interpret that phrase to mean that providing enough salmon escapement to meet all Northern Cook Inlet SEGs and to provide conservative inriver salmon harvest opportunities throughout the season uninterrupted by inseason restrictions or closures should be the preferred beneficial use. This interpretation would be supported by the purpose language in the first sentence/paragraph of the drift gillnet plan 5 AAC 21.353.

Other Alaskans and current ADF&G fishery management appear to interpret, “subject to preferences among beneficial uses,” as meaning large Upper Cook Inlet commercial sockeye harvests are the preferred beneficial use — even over providing for department set coho salmon SEGs, and far above providing conservative and reasonable coho salmon harvest opportunities for Northern Cook Inlet inriver salmon users. I know of no language in any Upper Cook Inlet salmon management plan prioritizing salmon harvests over meeting minimum salmon SEG levels, and request that ADF&G please provide such language for public examination — is there any?

Problem #2

While the department regularly produces reports and press releases detailing how many Alaska salmon have been harvested by the commercial industry, it often does not mention spawning escapement shortages or other management problems that should be addressed. Case in point being the failure to attain Deshka River and Little Susitna River coho salmon SEGs for 3 consecutive years.

One additional year without addressing excessive commercial harvests of northern bound coho salmon in the Central District drift gillnet fishery, and at a minimum both Deshka River and Little Susitna River coho salmon will likely reach the status of Stock of Management Concern as identified in 5 AAC 39.222 Policy for the Management of Sustainable Salmon Fisheries (d)(1)(D)(2) and (f)(21). If this occurred for either Deshka River coho or Little Susitna River coho it could be the first designation for a coho salmon Stock of Concern in the State of Alaska. If the designation was applied to both Deshka River and Little Susitna River coho salmon stocks it would mean that the coho salmon stocks with the two largest SEGs in all of Upper Cook Inlet could both be designated as Stocks of Management Concern during the same Board of Fisheries (BOF) cycle. What would the consequences of double coho salmon Stock of Management Concern designations in Upper Cook Inlet be?

At the 2024 Upper Cook Inlet BOF meeting, after late-run Kenai River Chinook salmon had been designated a Stock of Management Concern, regulation was developed that closed the Central District Eastside set net fishery (allowing only the use of dipnet by permit holders) until adequate Kenai River Chinook salmon escapement could be projected. This resulted in an expanding drift gillnet fishery 2 miles and further from the Kenai Peninsula coastline that took, not only a larger portion of harvestable surplus Kenai River sockeye salmon, but also harvested a significantly larger portion of northern bound salmon stocks, and in particular, coho salmon.

Therefore, it appears likely that coho salmon Stock of Management Concern designations for the two coho salmon stocks with the largest SEGs in all of Upper Cook Inlet could likely have serious salmon harvest reduction implications for the commercial user group that now takes most of the northern bound Upper Cook Inlet coho salmon harvest — specifically the drift gillnet fleet. I am not advocating that the drift gillnet fleet be restricted to using dip nets and releasing all coho salmon unharmed, however, I am advocating for a reduction in drift gillnet harvest of northern bound salmon stocks — sufficient to meet the purpose statement found in the Central District Drift Gillnet Fishery Management Plan.

While it is understandable that this administration / ADF&G may want to kick this issue down the road for the next governor and political appointments to deal with, I believe it much more appropriate for our current governor and his administration to step up to the plate, and at very least, acknowledge there is a problem with management of Deshka River and Little Susitna River coho salmon stocks that does not meet the purpose statement of the Central District Drift Gillnet Fishery Management Plan. It should be further acknowledged that if that problem is not addressed, within one year, there is high likelihood for Alaska’s first two coho salmon Stock of Management Concern designations.

Acknowledgement of this issue should also recognize that there definitely is a very real and pressing conservation purpose or reason identified in 2025 Agenda Change Requests (ACRs) #5 and #6.

Juneau, we definitely have problems. This is a request for your appropriate response.

Fish On.

Andy Couch is a member of the Matanuska-Susitna Borough Fish and Wildlife Commission and the Matanuska Valley Fish and Game Advisory Committee, however comments expressed in this column are his own unless noted otherwise.