Managing a mixed-stock and mixed-species fishery with stocks and species with differing productivities, similar run timings and overlapping spatial distributions is a fundamental challenge in the Nushagak District commercial fishery. King salmon are caught incidentally during the commercial sockeye salmon fishery, which makes the harvest of available, abundant sockeye salmon stocks while protecting struggling king salmon stocks difficult. Factors that may affect this challenge include: - When the first commercial openings for sockeye salmon are scheduled - When the fishery opens relative to the tide stage - How and when continuous fishing occurs - Selectivity of gillnet mesh size The NMKSMP directs the Department to keep the commercial sockeye salmon fishery closed until the projected sockeye escapement into the Wood River exceeds 100,000 fish. The Nushagak drift and set net allocation plan (5AAC 06.368) guides commercial fishing time for each gear type during the sockeye salmon fishery.

Uncertainties associated with the current king salmon assessment program estimates have limited the understanding of the king salmon stock, available yield, and fishery performance. Management suffers from a lack of information from the inriver sonar program, a lack of a rigorous king escapement goal, and a lack of a preseason indication of king run strength. Limited accuracy of commercial catch estimates, including age-size-sex. “Dropouts” in the commercial fishery are unaccounted for in the annual run accounting. Catch-and-release mortality in the sport fishery is not factored in to estimates of mortality associated with sport fishery. Catch and escapement age-sex-size characteristics in are not well measured or understood. Confidence in the accuracy of the inseason and post-season sonar-based estimates of inriver abundance has declined as research has examined assumptions made in the program. Without substantive improvement in these areas, and particularly with inriver abundance and escapement estimates, the development of brood tables is compromised, as is the ability to produce robust escapement and inriver goals, pre-season forecasts and inseason inriver abundance projections. Given the inaccuracy of assessment data, committee members felt the Plan remains too narrowly prescriptive. While the Board of Fisheries reduced the number of inriver abundance-based triggers in the Plan at the December 2018 meeting, some felt the feasibility of managing for even two triggers (55,000 and 95,000 fish) was questionable. Similarly, fishery management decisions are based on highly inaccurate inriver run estimates.

Impacts from inseason restrictions are costly to the different fisheries but vary in important ways: Sport Fishery In the sport fishery, complete inseason closures have had very large economic impacts for what was seen by most as likely modest biological benefits. Inseason closures have entirely precluded the ability to fish, typically for the remainder of the season. Closures carry obvious impacts to anglers, but also carry high costs, especially cancellations, to sport fishing businesses for the season, and negatively effect bookings for following years. In turn, the number of king salmon protected from harvest or incidental mortality by closures during years of low inriver abundance is low - in the hundreds or low thousands of fish. Unlike the commercial fishery, it is not possible to close and then re-open the guided sport fishery without substantial impacts to the fishery. Commercial Fishery In the commercial fishery, the directed fishery for king salmon had remained closed in 8 of the last 10 seasons. Closures in the sockeye fishery to conserve king salmon late in the season had disproportionately higher costs in terms of foregone sockeye harvest, with a lower gain in king salmon conservation than restrictions applied earlier in the season. Subsistence Fishery The subsistence fishery has a statutory priority over other fisheries. Reducing inriver subsistence fishery access to less than 7 days per week when the projected escapement falls below 55,000 fish potentially jeopardizes the ability of the fishery to achieve amounts necessary for subsistence (ANS) of salmon. Conservation Inequities The burden of king salmon conservation has varied among fisheries (stakeholders), years, and run sizes. The fisheries, as well as the stocks, are somewhat separated in time and along the migratory path, which can lead not only to king salmon conservation issues but to unequal burdens for conservation as well. In small king salmon runs, the sport fishery had typically borne the greater burden of conservation through inseason fishery restrictions in July while current management plans have focused on prosecuting the commercial fishery. Inseason closures, as implemented in the sport fishery during 1999 and 2010, represent a very large impact on the guided sport fishery operators. When management allows for pushes of sockeye to move into the escapement in June with the intention of protecting kings and there are no subsequent restrictions to the sport fishery, it could be argued the commercial fishery has borne a greater burden of conservation. In any event, the separation in space and time for when each fishery is restricted can lead to unequal sharing of the conservation burden.

Declines in abundance, size and returns per spawner of king salmon over the past 10 years have raised biological concerns and caused increased fishery restrictions. King salmon runs have gotten smaller in recent years, failing to meet escapement goals for several years, causing more frequent and severe inseason restrictions in the commercial, sport and subsistence fisheries. Based on existing data, king salmon productivity (returns per spawner) appears to have decreased. King salmon have also been getting smaller in size. Committee members asked how this decrease in size affects the reproductive potential of a given number of king salmon spawners in terms of egg deposition, and whether the escapement goal needs to take these declines in body size into account.

The lack of accurate assessment data during periods of extremely high sockeye productivity and very low king productivity has resulted in both foregone harvest of early season sockeye salmon and failures to meet the king salmon escapement goal. In an unfortunate positive feedback effect, recent large sockeye returns to the Nushagak District have influenced Bay-wide drift boat fleet dynamics, leading to unprecedented increases in fleet sizes (>600 drift vessels). Larger fleets have further increased early season harvest rates versus historical rates, and negatively affected any attempts to limit catch of king salmon in the commercial sockeye fishery. To further amplify this phenomenon, later sockeye run timing in recent years in Bristol Bay’s Eastside districts (e.g., Egegik and Naknek) can attract almost half the entire Bay’s drift fleet to the Nushagak District in the early season.

Several points pertaining to specific provisions of the Plan arose in meeting discussions. First, some felt the basis for the inseason Nushagak River king salmon escapement and inriver abundance projections was not clear. For example, it wasn’t clear whether the Plan intended to use projected inriver returns in some provisions and projected spawning escapement in others, or whether the use of the different terms was intentional. It was also not clear how inseason projections are made, i.e., what data is used in projecting inriver returns and escapement. Committee members also stated that the method for estimating the projected sockeye escapement into the Wood River under NMKSMP provision (e)(1) was not clear.