Politics prevails over good science in recent regulations
One of the most dangerous aspects of human decision-making is when poor science combines with a political agenda to create a desired outcome. Usually this happens when the scientific process is violated or not allowed to proceed in an orderly manner. The actions of the Board of Fish in passing regulations governing early run Kenai River chinook salmon demonstrate this very well.
The scientific process requires that an individual investigator present data in a manner that other investigators can examine and question. This is an important part of the process and helps reduce bias of the investigator, quantifies uncertainty in the data, allows for alternative interpretations and finally a complete discussion of options for future action. The work can also be repeated to verify that results are valid. It takes time for this to work and most investigators welcome slow and methodical approaches.
However, every three years the Board of Fish meets on Upper Cook Inlet fishery issues. This meeting combines allocation conflicts and biological information into what has become an unfortunate game that impacts thousands of people. The Alaska Department of Fish and Game was caught in this game for early run Kenai River chinook salmon management.
Fish and Game presented data at various advisory meetings and the Board of Fish that suggested that the recent percentage of five-ocean chinook salmon in the return were reduced from previous levels. These data were presented in a manner that a lay board could understand and when the Board of Fish met instead of when the scientific process was finished.
What happened is that a regulation was passed that negatively impacted the lives and livelihoods of Alaskans. However, when one examines the data, it is obvious that Fish and Game does not have the data to state any position with confidence on the stock status of five-ocean chinook. The programs used by Fish and Game were not designed to make this type of assessment. Errors/bias in escapement counts using sonar, harvest estimates from creel surveys, gear selectivity in the test netting, insufficient sample sizes, age composition program design and the scale identification techniques used to age fish combined to create significant uncertainty in the data set.
While this uncertainty is serious, a more significant event was also unfolding. The Board of Fish meeting was scheduled, and Fish and Game felt the public should be aware of a potential conservation concern. When significant uncertainty exists scientists react just like everyone else, they speculate. This is not science, it is just human nature. The public should be wary of scientists who speak with authority and have little data to support their conclusions.
Enter the user group fights and discussions into the process. User groups historically try to use biological reasons to achieve allocation objectives. Taking the high road of biology makes hiding the self-serving arguments easier. In addition, government agencies have self-interests, and, in this case, the director of Fish and Game's Sport Fish Division wanted a stable and predictable fishery on chinook salmon. It is easier to manage a fishery with no harvest. Just turn it on and let it go. Money can be saved in this approach. In addition, if one user group wants it, and that group supported the political appointment of the division director (a political position) all the better.
If one assumes that there is a downward trend in five-ocean chinook salmon, then the next step should be to look for mechanisms that would cause this. Some of them are:
(1) Five-ocean chinook salmon stay in the ocean longer and are therefore subject to harvest for more years in that environment than say three- or four-ocean fish. Commercial and marine sport fisheries can reduce the number returning to their river of origin, and, as these fisheries increase in effort, more fish are caught at younger ages and fewer survive to older ages.
(2) Five-ocean fish are usually slower growing; therefore, a positive change in the environment favoring faster growth may allow them to return as four-ocean fish.
(3) Five-ocean fish are genetically isolated in the Kenai River and are being harvested at rates above sustainable levels causing a slow change in genetic makeup of the population.
(4) Five-ocean fish enter the Kenai River toward the end of June and are not counted in the escapement or harvest in some years, since July 1 is used as an arbitrary cutoff between late and early run fish. They are therefore counted as late run fish in the statistics.
(5) Environmental conditions in the Kenai River or marine environment have changed to negatively impact five-ocean fish survival.
(6) Three- and four-ocean fish are a higher portion in the return which automatically reduces the percentage of five-ocean fish by definition.
(7) A statistical error has taken place -- one assumes something to be true when in fact it is false.
Good science would evaluate each of these potential causes, evaluate the data to support or reject them and issue a report which outlines the data sets used, the conclusions reached and why. In addition, recommendations would be prepared, if needed, to address the situation.
What happened in this case is that local Fish and Game in trying to alert the public to some future action created a situation that ran out of control because of political agendas beyond its control. This is chaos theory in practice.
What would good Fish and Game leadership on this issue have done? The scientist who brought this to the attention of other scientists should not be taken to task. He/she just brought something to the table for discussion. Instead, the leadership of Fish and Game should have started the scientific process and thought this through before making it public. Waiting one or two years to evaluate data, programs and solutions would not have put the resource at risk. Peer review by outside experts would have helped bring credible conclusions to the findings.
Instead, the Sport Fish Division director and commissioner of Fish and Game failed their staff and the public in not providing a mandate for good science.
Kenneth Tarbox, Soldotna
Others would better serve state's interest on Board of Fisheries
Editor's Note: The following letter was written to all Alaska legislators and submitted for publication.
On April 23, at its public meeting in Ninilchik, the Central Peninsula Fish and Game Advisory Committee opposed the confirmation of Brett Huber to the Board of Fisheries. The discussion and justifications for this opposition centered on the fact that Mr. Huber has a proven performance record over the years; therefore, it is not subject to supposition as to how he thinks and what he supports or how he would try to structure the fisheries if he were on the Board of Fisheries.
It was brought out that Mr. Huber has numerously drafted and supported proposals and Board of Fisheries regulations that:
1. Take biological management away from the fisheries and management biologist.
2. Take the emergency order authority away from the management biologist.
3. Are in opposition to the reliable biological and scientific data available.
4. Allow for overescapement and the waste of millions of surplus salmon.
5. Prevent the local angler from harvesting salmon but allow nonresident, hook-and-release fishing.
6. Target and increase the mortality of the early run's large five-year Kenai kings even though their numbers have been drastically reduced from 7 percent to less than 1/2 percent of the total run.
7. Put mandatory closures on both sport and commercial fisheries for no biological or conservation reasons.
8. Prevent in-season, abundance-based management. In-season, abundance-based management is the policy of the state.
9. Do not protect the critical rearing habitat, but in fact contribute to habitat degradation.
He has also written letters to the federal government trying to eliminate several 20-plus years enhancement projects that Cook Inlet Aquaculture took over operations from the state and that provide numerous salmon for all user groups. He has defied Alaska's professional biologists' data and science and has hired outside interests to lobby the Board of Fisheries to discredit this reliable data and science. He does not conduct himself in an impartial, open minded nor professional manner. He gives no time and no credibility to local advisory committees.
The resource, the people of Alaska, the Board of Fisheries, the advisory committees and the Legislature deserve to have impartial and open-minded people on the Board of Fisheries. To do less is irresponsible and not in the best interest of the people of Alaska.
The Anchorage Advisory Committee and the Kenai-Soldotna Advisory Committee voted against Brett Huber's confirmation. There has also been a lot of opposition from hundreds of people from all user groups.
There are more qualified people available in this state who are open minded and who will use the most reliable scientific and biological data available to make regulations that provide biological management thus creating maximum sustained yield for the greatest benefit for all Alaskans.
We cannot take the chance of jeopardizing our fisheries resources or the ability of the people to make a livelihood or recreate this resource. Thank you for your time and consideration.
David R. Martin, chairman Central Peninsula Fish and Game Advisory Committee
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