March 21, 2012
Tim Towarak, Chair
Federal Subsistence Board
1011 E. Tudor Road, Mail Stop 121
Anchorage, Alaska 99503
Dear Chairman Towarak and Board Members,
The Southeast Alaska Seiners Association (SEAS) would like to take this opportunity to humbly ask that you reject the request by Kootznawoo, Inc. for Extraterritorial Jurisdiction(ETJ) We represent the salmon purse seine fleet in Southeast Alaska. We were once proud to say that we represented the Angoon seiners as well for several decades, when there were yet seiners in Angoon. Our fleet includes 1500 fishermen, including the skippers and crews and we are the backbone of the Southeast commercial salmon fishing industry that is the largest employer in Southeast Alaska. Approximately 20% of our fleet is Tlingit-Haida and approximately one-third of our membership are Federally Qualified Subsistence users. We also represent through paying membership 68 support businesses throughout Southeast Alaska. Approximately 30% of the owners of these support businesses are Federally Qualified Subsistence users.
As we begin here, let's just say that even the very idea of Extra-Territorial Jurisdiction is insulting to most Alaskans. After statehood we have bestowed upon the most responsible, intelligent and determined individuals we could find to manage in trust our entire social and economic foundation and lifeblood- the Salmon. These men and women of ADFG blue take their responsibility seriously and between God and these managers, we consider both to be the creators and keepers of our salmon resource.
There are some small ironies here in that it was the Federal Government in 1968, 44 years ago, which first recognized and began changing the complexion of the Kanalku Falls and pools. One can look up the black and white pictures of the Kanalku problem on the internet today, just as it were 1968 again. That's 44 years. That's 11 sockeye life cycles.
It was also the Federal Government, throughout the 50's and 60's, which permitted the streambank at Kook Lake’s outlet creek to be logged all the way to the stream, causing erosion that likely caused significant sockeye spawn die-offs as recently as a decade ago. (When a large log and woody debris clogged up the sockeye caves- where the stream goes underground) So how fair would it be for the same Federal Government to return here today after knowing that these Federal Government issues with the local streams indeed either likely caused or exacerbated the underlying issues with these two systems. (Which, coincidentally are the two very systems that have received the most discussion of the Chatham Strait sockeye stocks)
Did the US Government not have knowledge 44 years ago that there was an issue with Kanalku sockeye safe passage to the lake? As recently as last year, the state of Alaska sponsored a USFS feasibility study to do just that- to build a fish ladder. And so for 44 years, and 11 life cycles of Kanalku sockeyes we have Federally studied and understood spawning barriers at Kanalku Falls. One would have to ask what the motive a group would have to seek to reach out up into Chatham Strait into the best managed fishery in the world without first attempting to solve these underlying, non-fishing related issues?
We believe that in order to get to the issues at hand these the Southeast Regional Advisory Council and the Federal Subsistence Board need to dispense with the frivolous petition to exercise ETJ and wrestle with the issues we’ve laid out.
And now we’d like to lay out our major points that we believe will help explain the Chatham Strait issue.
1. State management authority. The State has managed the Chatham Strait Corridor with as much conservation and precision as humanly possible. In 2011, there were 178 pink salmon for 1 sockeye harvested. This is simply not a target specie. Since 2006, new information came from USFS Biologist Ben Van Allen that there was up to 70% mortality for jumping Kanalku Falls. . How could we even begin to talk about closing fishing time and area when there is not safe fish passage to the lake on many seasons? And furthermore, how could we consider fishing restrictions when there has been absolutely no stock identification in our fishery.
Here is the most important thing about the ADFG Chatham Strait Management: The vast majority of Chatham Strait has been closed in the first 3 weeks of July for well over 2 decades in order to pass sockeye stocks into their creeks and streams of origin. Kootznawoo has asserted that there was no changes in the state of Alaska’s positions or management strategies regarding Chatham Strait sockeye stocks. And they are correct. But that's why there were no sudden changes in recent years with the ADFG's management system. It is what we do and have been doing in our day to day management.......and that's why recently, Kanalku sockeye numbers are the highest numbers we have on record.
2. In the past 2 decades the state of Alaska has drawn up corridors and boundary areas around Basket Bay as well as Kootznahoo Inlet. This, accompanied by a start time in mid to late July to avoid the earlier timed stocks of local Chatham Strait sockeye salmon, allows the seine fleet to begin the pink salmon season once the sockeye season is almost completely over. We'd like to use science and not speculation when there is ever any discussion of fishery time and area closures or removals. That's what introduces us to our next topic, Genetic Stock ID.
3. We need Genetic Stock Identification. Will we know vastly more than we know today? No. And why would we assert that. We will have far more precision and have more answers. But in the aggregate, since well over 80% of the sockeye caught in Chatham Strait are from the Snettisham Hatchery, Taku , Chilkat and Chilkoot Rivers, there will be some interesting identification that is closer than what we have now. But we intuitively have a pretty good idea that if a sockeye is caught off Danger Point or Basket Bay that it's got an exceptional chance of being a local Kanalku sockeye. So we close those places for good and we don't even fish nearby until the sockeye runs are 90% over.
We believe it will prove what we have known all along about our fishing during the pink salmon run timing, thereby avoiding the majority of the sockeye run timing. WE need the GSI to determine if the Kootznawoo Corporations' allegations of unfair sharing is really occurring here. It's really where we need to start. We have a basic question of unfair sharing of the salmon resource but we have no actual harvest numbers nor baseline to determine that.
4. The best example of the rebuilding of Kanalku is the 2009-2010 back to back run cycle. 2009 was one of the most fishing boat days along the Angoon shoreline we can recall. We had a typical season with high pink salmon abundance. We sat on the beach for the first 3 weeks of July for the most part and then began fishing along the Angoon shoreline. That year the total return to Kanalku (subsistence of 600, escapement of 2650) was 3250.
In 2010 there was no Chatham fishery. None. The return to Kanalku (subsistence of 600 and escapement of 2950) was around 3500 sockeyes.
These were the 2 biggest returns ever recorded to Kanalku, which is remarkable considering the fish passage issues that we’ve had in so many of the other seasons.
One when there was lots of fishing. One when there was no fishing.
Gets you to wondering if this closure of the first few weeks in July is doing something. Yes. It's allowing 90% of the sockeyes to get into their streams and lakes before the seine fleet begins fishing in the vast majority of Chatham Strait.
There will be some discussion here about how 2011 fell short but salmon biologists or fisheries manager would not compare year to year, but cycle to cycle. Just because 2009 and 2010 were off the charts means nothing for 2011. 2011 returning adults would have been halfway across the ocean in 2009 and out by the chain or 600 miles off Kodiak in 2010.
2011 was a product of 2007, which was a product of 2003, which was a very weak cycle. Cycle upon cycle, The 2007 cycle increased by around 80% over the weak 2003 cycle and the 2011 cycle improved by around 50% over the 2007 cycle. Besides the weak cycle, one wonders what the cause of the weak 2003 cycle really was. Was that the year of the treefall that filled up the jumping pool or was that a cycle where a fish ladder would have provided triple the escapement. We do know about 2007 because Ben Van Allen was there and at least a sockeye died for nothing before reaching the lake for every sockeye that made it to spawn.
5. Subsistence is the priority. SEAS supports the Subsistence priority. Always has. Always will. But this does not mean that seiners, trollers and gillnetters are going to be waiting on the beach for subsistence users to complete their fishery. It just doesn't work this way. We have to make in season forecasts and harvest and escapement predictions. SEAS supports vastly increased State and Federal funding for ensuring safe passage to the Kanalku Lake and other Chatham Strait Lakes in order to attempt to ensure that no further Kanalku sockeyes die while attempting to jump the 16 foot long jump required to get over the falls when water levels are high.
We believe that looking at Kanalku and the recent rebuilding going on, it's obviously the state's plan that's been working. The state has stayed with its early season run timing model. The timing of this fishery and keeping the seine nets out of the water for the early portion of July, is an important contribution for our shared success in quickly rebuilding Kanalku. Again, we urge you to reject the Extra Territorial Jurisdiction petition and move on to the local solution of actually identifying Chatham Strait sockeye stocks through Genetic Stock Identification program and building the Kanalku Falls fish ladder.
President, Southeast Alaska Seiners Association