After the February 2020 Upper Cook Inlet Board of Fisheries Meeting, I believed Northern Cook Inlet streams would see significantly better sport fishing opportunities for sockeye, chum, pink, and coho (silver) salmon this summer. Several groups worked together at the Board meeting including the Alaska Outdoor Council, Alaska Sportfishing Association, Kenai River Sportfishing Association, Matanuska Susitna Borough Fish and Wildlife Commission, Northern District Setnetters Association, Matanuska Valley Fish and Game Advisory Committee, Susitna Valley Fish and Game Advisory Committee, Mt Yenlo FIsh and Game Advisory Committee, Southcentral Alaska Dipnetters Association, along with several individuals and business owners, and Board of Fisheries members, Alaska Department of Fish and Game Commissioner Doug Vincent-Lang provided well prepared clarity on department information and assessments — and I believe most were excited about the prospects of improved salmon abundances in the waters and drainages of Northern Cook Inlet.
For sport anglers coho salmon run up numerous drainages throughout Northern Cook Inlet, and are prized as a top food fish and the most sport-harvested salmon species in the Northern Cook Inlet Management Area.
Where have all the cohos gone?
If you’ve been reading this fishing column through the summer of 2020, you likely know there was a strong return of pink salmon throughout Northern Cook Inlet’s Susitna River drainage, and the sockeye salmon return to FIsh Creek in the Big Lake drainage provided some of the best dip netting and sport opportunity at this drainage during the past decade, however, while steady throughout most of the season, coho salmon returns to many Northern Cook Inlet drainages were somewhat late and mediocre at best. Many anglers, fishing guides, and owners or operators of fishing related businesses told me of similar mediocre experiences with the 2020 Northern Cook Inlet sport coho salmon fishery. Therefore, the Board of FIsheries changes adopted to pass more coho North were extremely important during the 2020 season.
Recent Northern District commercial coho harvest levels
Some might attempt to explain mediocre sport coho salmon fishing in Northern Cook Inlet stream drainages as simply a result from poor ocean coho production, however, revised fishing regulations and management decisions for the Central District commercial fisheries of Upper Cook Inlet DID pass a higher percentage of Northern Bound coho salmon into Northern Cook Inlet waters. This can be seen in improved coho salmon escapement counts compared to last years, at 3 locations where the Alaska Department of Fish and Game (ADF&G) counted coho for at least a portion of the 2020 season. This can also be seen in another banner coho salmon catch in the Northern District commercial set net fishery, where their top 4 coho salmon harvests in the past 20 years have all occurred in the past 4 years (2018, 2020, 2019, and 2017) according to information posted on the ADF&G website.
Depressed Northern Sport coho harvests
How do Northern Cook Inlet Management Area sport coho harvests compare to the commercial harvests? The most recent ADF&G figures for sport harvests I could find ran through 2015 (why does it take so long to compile sport harvests?), but judging from coho salmon spawning escapements and the number of recent emergency restrictions placed on Northern Cook Inlet sport fisheries, I feel positive the top four sport coho salmon harvests in the past 20 years occurred in 2002, 2006, 2008, and 2001. The most recent of those large sport harvests was 12 years ago!
On a year where the Alaska Board of Fisheries adopted changes that to provide more reasonable shared harvest opportunities for all Northern District user groups, why this discrepancy in harvest levels between commercial and sport on a species (coho) designated for minimized commercial harvest in order to provide a reasonable harvest opportunity for sport, guided sport, and other inriver users over the entire run, as measured by the number of inseason restrictions?
What does the “Funny phrase” (found only in the Northern District salmon management plan), “or as specified in this section and other regulations.” mean? Is it really acceptable for ADF&G commercial management to use that phrase as a “Get Out of Jail Free Card” to avoid providing sport and guided sport users a reasonable coho salmon harvest opportunity over the entire run?
A little history
The years 2013, 2014, and 2015 are the last back-to-back years where ADF&G commercial management allowed enough coho salmon to pass through the Northern District to provide a reasonable sport coho salmon harvest opportunity, over the entire run without inseason restriction or closure at Little Susitna River. The Little Susitna River coho salmon escapement goal is the longest established coho salmon goal in Upper Cook Inlet, and the Little Susitna River sport coho salmon fishery is one of the largest and most important sport fisheries in Northern Cook Inlet.
During 2013 to 2015 the entire Northern District set net fishery was restricted to one net between July 20 to 31 as a conservation measure to protect Stock of Concern Susitna River sockeye salmon. From Aug. 1-6 the General Subdistrict south of the Susitna River was allowed to use a maximum of two nets, while the remainder of the Northern District would remained restricted to one net.
Management discretion: How does this choice help Alaska or most Alaskans?
From 2016 to 2020 commercial management made a conscious decision to start allowing the Eastern Subdistrict of the Northern District to fish two nets (instead of one) from July 20 to Aug. 6. During four of these five years (2016, 2017, 2019, and 2020) reasonable sport coho salmon harvest opportunity had to be restricted in Little Susitna River in efforts to meet the coho salmon escapement goal. (In 2016 the Little Susitna River sport coho fishery was entirely closed for a portion of the season and in 2019 both the Little Susitna River and Deshka River coho salmon sport fisheries were entirely closed for a portion of the season). In addition from July 20 to Aug. 6 the General Subdistrict East of the Susitna River remained restricted to one net AND was further restricted and or closed later in August during 2016, 2017, 2019, and 2020.
The Little Susitna coho salmon goal minimum at the time,10,100, was not attained by 102 fish in 2016, and in 2019 only 4,226 of the 10,100 —17,700 Little Susitna goal range was attained. Finally, even though ADF&G’s best genetic science shows Eastern Subdistrict harvests a substantial amount of Knik Arm coho salmon (Little Susitna is part of this drainage) commercial management allowed the Eastern Subdistrict to continue harvesting with the increased nets without adjustment each of the four years, with documented conservation concerns, that negatively affected many other users including sport, guided sport, and General Subdistrict commercial East of the Susitna River.
When will we ever learn?
Four out of five years this “new” management strategy has failed to provide reasonable harvest opportunity for sport and guided sport users as defined in the Northern District Salmon Management Plan. That is an 80% failure rate. In addition, this “new” management strategy has forced additional restrictions on other commercial users — once again at an 80% failure rate. Finally this “new” strategy has failed to attain even the minimum Little Susitna River coho salmon escapement goal 40% of the time over the past five years, even with restrictions and great financial costs to other Alaskans. How can such management possibly be good for the State of Alaska? or for a majority of Alaskans? Why is ADF&G commercial management favoring Eastern Subdistrict commercial set netters over all other Northern District users? Surely there must be some solutions that would better meet the Management Plan purpose and provide a better sharing of the valuable Northern Cook Inlet coho salmon resource.
Many Alaskans and visitors are willing to pay considerably more for a reasonable opportunity to recreationally harvest their own Alaska salmon, than they are willing to pay for the fish in a store. Therefore allowing a maximum number of people an opportunity to harvest their own salmon would seem to provide a maximum amount of benefit. The Northern Cook Inlet sport fishery is based on very conservative harvest methods and limits, and requires a maximum number of days of opportunity in order to best maximize benefit. This is likely the rationale behind the board-adopted direction in the Northern District Salmon Management Plan. Surely there is a way to allow reasonable sport harvest opportunity, under current conservative sport regulations, throughout the season, and without restrictions on most years, while still sharing the resource abundance with commercial netters.
The management plan states: “(b) the department shall manage the Northern District commercial salmon fisheries based on the abundance of sockeye salmon counted through the weirs on Larson, Chelatna, and Judd Lakes or other salmon indices the department deems appropriate.”
Because of budget reductions ADF&G did not operate the Chelatna Lake weir in 2020. Furthermore, even though the management plan calls for the minimization of commercial harvest of coho salmon bound for the Northern District of Upper Cook Inlet— in both 2018 and 2020 coho salmon were the most harvested salmon species in the Northern District commercial fishery. Therefore, it seems logical 1. the department (Commissioner) should deem it appropriate to manage Northern District commercial fisheries to attain at least two extremely important Northern District coho salmon goals: Little Susitna River and Deshka River.
At the February 2020 Upper Cook Inlet Meeting, Alaska Board of Fisheries members spoke to their clear intent that the Northern District be managed on a conservative basis, and adopted amended preamble language in the Northern District Salmon Management Plan directing a more shared management approach amongst all Northern District user groups. With this thought in mind, and considering the negative consequences of more liberal management outlined above, perhaps 2. ADF&G management should return to the more conservative practice of restricting the Eastern Subdistrict to one net between July 20 to Aug. 6 (similar to how the General Subdistrict East of the Susitna River is managed).
Concerning section (C) where the plan states: “. . . except from July 31 to Aug. 6 the commissioner may allow two set gill nets in that portion of the General subdistrict south of the Susitna River:”
The Department should use a logical guideline for when to allow (or not allow) two commercial nets such as: “If all measured Susitna sockeye salmon goal components are projected to be met as measured by Commercial Fish Division, AND the Deshka River coho salmon escapement goal is projected to be met as measure by Sport FIsh Division.”
Such logical guidelines are allowed under section “g” of the plan: “(g) The commissioner may depart from the provision of this management plan under this section as provided for in 5 AAC 21.363(e).”
Concerning when to allow the Northern District commercial fishery to go back to full gear after Aug. 6, appropriate guidelines for different portions of the Northern District might be:
For the General Subdistrict East of the Susitna River and the Eastern Subdistrict: “When the Little Susitna River coho salmon escapement goal has been attained, or can conservatively be projected to be attained by Sport Fish Division.”
For the General Subdistrict South of the Susitna River: “When all measured components of the Susitna River Sockeye Goal have been attained as measured by Commercial Fish Division, AND the Deshka River coho salmon escapement goal has been attained, or can conservatively be projected to be attained by Sport FIsh Division.”
Why should Commercial fish Division assess sockeye and Sport Fish Division assess coho salmon escapement goals, and why should both divisions manage for both species? On several occasions the Commercial Division and Sport FIsh Division seem to be making awkwardly disjointed management decisions that make little or no sense to the public. Some of these decisions (while allowed by management plan) appear opposed to management plan direction and opposed to intent provided by Alaska Board of Fisheries members during the 2020 Upper Cook Inlet meeting. Using one set of escapement goal projections with Commercial Fish providing sockeye and Sport Fish providing coho may provide a solution. At very least it may get commercial and sport fish managers talking / communicating more often and encourage better joint decisions that could benefit all users.
Warnings: Some 2020 management actions listed below are so skewed that two people, one a minister and the second a 40+-year professional Alaska journalist, separately commented, they believe some management decisions may have been taken to, “Get back at Northern Cook Inlet users who advocated for changes (providing more reasonable shared salmon harvest opportunities for all Northern Cook Inlet users).”
A Mat-Su salmon fishing guide said, “These management actions do not help, they just stir up animosity between the user groups.”
A Northern District commercial set netter lamented, “I don’t know why management is doing this, it just make us (commercial fishers) look bad.”
An Alaska resident who voted for statehood questioned, “Is the Department even meeting its Alaska Constitutional mandate to manage on a sustainable basis?”
Questionable ADF&G inseason actions during 2020, and the questions
Emergency Order (EO) 2S-19-20 Covering commercial fishing periods between July 20 to July 27 allowed the Eastern Subdistrict to fish with two nets, while limiting the General Subdistrict of the Northern District to one net.
Considering the Northern District Salmon Management Plan does not provide instruction that any portion of the Northern District MAY be allowed larger amounts of gear during this time period, and considering ADF&G failed to attain the Little Susitna River coho salmon escapement goal two of the four previous years (with less than half of the escapement goal minimum in 2019) this action was previously taken, and considering this same commercial liberalization had failed to provide a reasonable Little Susitna River sport and guided sport coho salmon harvest opportunity three of the previous four years this action was taken, and considering this action only exacerbated fishing restrictions / closure to General District commercial users East of the Susitna River 3 of the previous 4 years it was taken, What is ADF&G justification for this action?
Is there any reason to believe future use of this liberalization would produce different results?
EO 2S-24-20 Covering Aug. 3 and Aug. 6 Northern District Commercial fishing periods liberalized the General Subdistrict South of the Susitna River to allow the use of two nets and also allowed the Eastern Subdistrict to continue fishing with two nets.
Although not stated (how it was determined) in Emergency Announcement 24 — ADF&G should have somehow made an assessment that the Susitna River sockeye salmon escapement goals would be achieved in order to make this liberalization South of Susitna River. Extending the liberalization to two nets in the Eastern Subdistrict appears an irresponsible call considering ADF&G’s documented impacts on Little Susitna River coho salmon escapements in the past, the past record of restrictions to both the Little Susitna River coho salmon sport fishery and the General Subdistrict commercial fishery East of the Susitna River. Announcement 24 also mentioned the use of 3 nets starting on Aug. 10 in the entire Northern District commercial fishery — considering the
Commercial Fish Division’s poor track record over the past five years with Little Susitna River coho, why was this mention of a future gear liberalization for the entire Northern District commercial fishery appropriate? and why was this the time to make it?
EO 2-RS-47-20 Issued Aug. 4, Effective Aug. 6: Closed the sport fishery for all salmon species in Larson Creek and within quarter-mile of its confluence with the Talkeetna River through December 31, 2020.
This emergency order mentions that the Larson Creek weir sockeye salmon count is the lowest on record for aug. 3, and further states that the sustainable escapement goal (SEG) can not be projected even with late run models.
The Larson Creek SEG is part of the Susitna River sockeye salmon goals. If the Larson Creek sockeye salmon SEG can not be projected through the weir even with late run models, what other indices did ADF&G “deem appropriate” as called for in the Northern District Salmon Management Plan to determine Susitna River sockeye salmon escapement goals would be achieved? — After all, ADF&G’s own announcement mentioned this assessment as a necessary benchmark for EO 2S-24-20 — the previous liberalization of the Northern District commercial fishery.
If there was enough time to close the Larson Creek sport fishery by Aug. 6, ADF&G managers would also restrict the commercial fishery South of the Susitna River back to one net for at least the Aug. 6 period, right? Wrong!
ADF&G emergency commercial regulations continued to allow expanded nets for the remainder of the season, and the Larson Creek sockeye salmon SEG was not attained. How does ADF&G justify managing for continued liberalized commercial harvest in light of an ADF&G documented conservation concern, and in seeming defiance of the Northern District Salmon Management Plan, and Board of Fisheries intent to manage Susitna River sockeye salmon on a conservative basis?
EO 2 SS-2-48-20 Issued Aug. 4, Effective Aug. 6: Closed the Little Susitna River sport coho salmon fishery to the use of bait from Aug. 6 to Sept. 30, 2020. By the first week of August sport anglers, who regularly fish Little Susitna River, knew there was not much abundance of coho salmon in the river. Most anglers would acknowledge, it was a necessary move to close bait fishing if the escapement goal was to be attained.
Since commercial management is charged by the plan with providing enough salmon passage into Northern District streams to provide reasonable sport and guided sport coho salmon harvest opportunities, and for the fourth time in the last five years that was not happening, why did commercial management continue to allow the Eastern Subdistrict to continue fishing more nets than other users in the Northern District — even after the Little Susitna River coho salmon sport fishery was restricted? How does ADF&G management justify continued liberalization of the Eastside Subdistrict? especially considering language in the plan calling for minimization of commercial coho salmon harvest and providing for reasonable sport and guided sport harvest opportunity?
EO 2S-28-20 Issued Aug. 9, Effective Aug. 10 acknowledged the conservation concern for achieving the Little Susitna River coho salmon SEG and restricted the Central District commercial drift gill net fishery, BUT allowed the entire Northern District commercial fishery to fish three nets for the entire August 10 period. Action in the Northern District maximized (rather than minimized) coho salmon harvest during a time of department documented Northern District coho salmon shortage at Little Susitna River. Aug. 10 was the Northern District’s largest daily coho salmon harvest of the entire season with ADF&G’s website showing a preliminary harvest of 8,219 coho from a Northern District harvest of 12,992 total salmon. Allowing for maximum commercial coho harvest on Aug. 10 greatly reduced the small and late portion of the season where sport and guided sport anglers would have a reasonable coho salmon harvest opportunity at Little Susitna River. This would appear to be in direct defiance of Northern District Salmon Management Plan direction, and at the greatest possible economic loss and loss of reasonable harvest opportunity for sport fishing and guided sport fishing user groups.
In light of board amending the plan directing for more sharing with other user groups, and 2020 board members’ stated intent for conservative management, why did ADF&G take this action?
One distressed veteran Mat-Su Valley salmon guide business owner told me, he figured one individual Northern District permit holder harvested more than twice as many Northern Cook Inlet coho salmon on Aug. 10 than all his charter guests for the entire 2020 season.
From my experience as a Mat-Su Valley salmon fishing guide, and from my discussion with additional guide business owners, likely most (if not all) Northern Cook Inlet fishing guides had a similar experience during the 2020 season.
EO 2-SS-2-50-20 Issued Aug. 11, 2020 (one day after the largest Northern District coho salmon harvest of the entire season) Effective Aug. 13 reduced the Little Susitna River coho salmon sport daily bag and possession limits from two to one fish daily. Why does ADF&G issue these back to back contradictory emergency orders? How can there possibly be enough coho salmon for every commercial permit holder in the entire Northern District to harvest at maximum capacity with No Daily Bag Limit, IF there is not enough for a Little Susitna River sport angler to even harvest two coho salmon in a day? How can there possibly be enough coho salmon for every commercial permit holder in the entire Northern District to harvest using 3 large gill nets, if there is not enough coho salmon for even one Little Susitna River sport angler to fish a single salmon egg on a hook?
EO 2S-29-20, EO 2S-33-20, EO 2S-34-20, EO 2S-35-20 Effective Aug. 13, 17, 20, 24 These emergency orders reduced commercial fishing time in the General Subdistrict East of the Susitna River from 12 to 6 hours daily on Aug. 13, 17, 20, and 24, while allowing three nets to be fished per permit. These restrictions are a belated response to coho salmon sport fishery restrictions on Little Susitna River during the 2020 season, and after these restrictions were imposed, enough coho salmon did finally migrate past the weir to attain the Little Susitna River SEG and restore a belated sport fish harvest opportunity with bait. Commercial permit holders in this specific area were held responsible for the entire Northern District commercial conservation burden for Little Susitna River coho salmon, even though ADF&G’s best available genetic science shows Knik Arm coho salmon are also harvested, and earlier in the season, and in significant numbers, in the Eastern Subdistrict. With no specific direction from the Northern District Salmon Management Plan, why did ADF&G NOT share the conservation burden with the Eastern Subdistrict in proportion to its harvest of Knik Arm coho salmon, as called for in the department’s own Sustainable Salmon FIsheries Policy? Who in the Department makes this choice to favor a portion of one particular user group over all others? and why?
I hope all readers can see a clear trend here. All emergency liberalizations for a specific portion of the user group with the most and largest nets and no daily limits and no seasonal limits, which are not truly based on achieving Department established escapement goals, and which do not provide for reasonable harvest opportunities for other user groups at the same time, rob board-allocated benefit from the State of Alaska and from all other Northern Cook Inlet user groups. These well documented “robberies,” have occurred for too long and are unacceptable. The professional “criminals” who commit these robberies should be stopped immediately and held fully responsible. A friend suggested, “Perhaps, they should be required to pay full restitution to all they have robbed.”
While he has no degree to certify intelligence, Andy Couch has proposed a few Upper Cook Inlet fisheries regulation changes adopted by the Alaska Board of Fisheries. Opinions expressed in this article are his own, except as credited to others, and he appreciates your reading and consideration of them, and your possible participation in the public process. He knows people can change public policy/regulations for the better.