by Ivan M. Ivan
This is a letter, dated May 14th, 2019 to Charlene Erik, Chairperson of the Kuskokwim River Inter-Tribal Fish Commission.
Akiak Native Community is writing to propose 2019 Kuskokwim Chinook management actions. We request that each of our 33 Kuskokwim River InterTribal Fish Commission member Tribes and in-season management team to consider the proposals.
The upcoming May 17 KRSMWG and May 20 public call in provide opportunities to discuss these proposals. We request deliberations to take action on the proposals during the in-season management team meeting on May 21, 2019.
The 2019 projected return for Kuskokwim River Chinook salmon is between 110,000 and 150,000. The State of Alaska determines the amounts necessary for subsistence (ANS) uses of the Chinook salmon to be within the range of 67,200 to 109,800. This projection presents significant concerns for achieving both the upper end of the Kuskokwim River Chinook salmon.
We propose the following 2019 Kuskokwim fisheries management actions to fulfill these goals and implement a culturally appropriate framework restoring opportunities to practice our ways of life.
1) Issue community harvest permits and open Chinook salmon fishing to all 33 Kuskokwim communities identified in the 2014 OSM 804 analysis beginning June 1, 2019 to July 1, 2019.
2) Allocate a total of 22,000 Chinook salmon among each community according to their 20 year harvest average identified in appendix A.
3) Empower the Tribal Council Chief or one leader in each Kuskokwim community to equitably distribute Chinook salmon allocations among all community households.
4) Charge the community Tribal Council Chief or one leader with the responsibility for reporting household harvests to the YDNWR staff weekly.
We also support a proposal rescinding Chinook salmon harvest restrictions on all Kuskokwim River Drainage communities above Lower Kalskag. Chinook salmon harvest averages in these communities are historically low. This would ensure our families and neighbors living in communities along Kuskokwim waters adjacent to state lands meet their subsistence needs.
One ADF&G proposal to implement a 10 Chinook per household permit along Kuskokwim waters adjacent to state lands could be interpreted as unlawful given the current conservation concern.
Specifically, it ignores the Secretary of the Interior’s responsibility to ensure for the continued viability of fish and wildlife and opportunities for subsistence uses on public lands in Alaska. Not only the location but potential impacts of such actions must be considered when interpreting Section 802 of the ANILCA.
This second proposal provides a solution to avoid legal, conservation, and cultural implications the ADF &G proposal presents.
Yukon Delta National Wildlife Refuge staff propose using short window openers beginning sometime in mid-June. Rolling closures or window openers are not culturally appropriate management tools. These practices do not provide a method for equal distribution and present significant hardships to our people.
Many Kuskokwim peoples are unable to purchase gas or get off work to fish during limited window openings. Openings often do not coincide with optimal drying times critical to processing our salmon. Short window openers also encourage intense harvest pressure subjecting specific Chinook salmon stocks to unnecessary and significant risk.
Our proposals seek to ensure the long term health of our Chinook salmon and people. This can be achieved by aiming to meet the upper end of our escapement goal, spreading harvest across the season, and providing maximum flexibility to practice our culture and ways of life.
Charging our Tribal Chiefs or Community leaders with the responsibility to equitably distribute allocations and monitor harvest empowers our tribes and honors our cultural values of care, sharing, and respect.
This step would be a significant accomplishment towards achieving one of our shared KRITFC goals to meaningfully improve our tribes’ role in the management, monitoring, and care of our fisheries as we have done thousands of years.
We wish to thank all of our tribes, families, and friends for their tireless efforts. We must continue working together to ensure our fish, rivers, peoples, and culture remain healthy. Our children and future generations depend on us. We look forward to our discussions and negotiations in the days ahead.
Ivan M. Ivan is the Chief of Akiak Native Community.