Upon review of your article dated July 11, "State officials say judge's decision confirms current Fish and Game practices" there appears to be several misrepresented facts made by the Department of Fish and Game Commercial Fisheries Director Doug Mecum and Board of Fisheries Chairman Ed Dersham.
First of all, Director Mecum failed to inform the public in your article that the department and his office, in fact, submitted an emergency petition to the Board of Fisheries dated July 1, which stated an emergency exists in management of the Kasilof section of the upper subdistrict based on both run strength on sockeye bound for the Kasilof River and the mandatory 48-hour closure per week coupled with limitation on hourly limits on emergency orders issued by the department.
The department and the board met on July 1 and failed the measure by one vote (Ed Dersham voted against). On the following Monday, the department again met with the Board of Fisheries on the emergency petition submitted by the department. Again, Chairman Dersham voted against the department's emergency petition.
This action describes the current situation not described in the recent article. This action and inaction taken by Chairman Dersham describes the political measures involved in the management plans as they exist today and passed by the past board in 2002, not the present board except for Ed Dersham. Director Mecum submitted the emergency petition for the Division of Commercial Fisheries to the board as the emergency petition met the criteria for submittal to the board.
The department believes that the requested emergency action is warranted because of the unexpected and unforeseen strength of the Kasilof sockeye return. The department states in the petition addressing the Kasilof River Management Plan: "We further believe that a delay in allowing additional fishing time would result in a biologically allowable resource harvest not being taken."
In addition, when denied by only one vote from the board, the department through the commissioner's emergency order authority should have been implemented immediately on July 2.
Unfortunately, the emergency still exists within the department but the commissioner has not issued an emergency order to allow for management of the fishery on the Kasilof-bound sockeye stocks to try to stay within the established biological escapement goals.
The question is why not? Why continue reissuing the same emergency petition every few days to the board? If not politically motivated, then serious lack of leadership exists within the Department of Fish and Game's Commercial Fisheries Division. The commissioner's emergency order authority is useless unless the commissioner uses it.
If the commissioner fails to back his own department on this after the request has been made, denied and clarified by Judge Brown and Judge Huguelet, then a political not biological issue will fail the public and public resource management period.
Overescapement impacts production and future returns which affect everyone by the loss of millions of sockeye salmon fry due to starvation by limitations on food available in wintering conditions on zooplankton. Resource management and future economic and public resources are lost for no reason other than management plans that do not work.
Commercial fishing groups have submitted to the board several agenda change requests and three emergency petitions to address these issues to the Board of Fisheries in the past two years; all of which have been denied by the past board.
Unfortunately, legal recourse is at times the only public platform remaining to correct measures within management plans that are consistent with state policy and statute as described within the Salmon Escapement Goal Policy and the Sustainable Fisheries Policy.
It's really not a hard fix to allow flexible management tools based on run timing and run strength to curb escapement rates, it's just a matter of doing it. Failing to act is described by final escapement numbers into each river system. Biological escapement goals are established over scientific measures and time.
Unfortunately, both the leadership within the Department of Fish and Game and the Board of Fisheries has exemplified political cover for their own future not the resource.
Jeff Beaudoin, Kasilof
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