ADF&G Boards Support,
 P.O. Box 115526, Juneau, AK, 99811-5526		Dec. 28,2017

Chairman John Jensen,
Alaska Board of Fisheries
Dear Chairman Jensen and Board members,

	The Sitka Advisory Committee thanks the Department for releasing their action plans for Chilkat and Unuk King Salmon last Friday, December 22, in time for us to comment by the Dec. 28 deadline. Over the last five days our members have carefully analyzed the ADF&G plans and have the following comments.

	First, it should be noted that the Sitka AC has a long history of supporting conservation for fish and game in the Sitka area.  We were the first committee to recommend a shellfish sanctuary from commercial fisheries (abalone in the 70’s) a minimum estimated biomass threshold for the sac roe herring seine fisheries (1977) a lingcod and rockfish sanctuary (19-34 pinnacles) and a Local Area Management Plan (LAMP) for halibut.  All adopted by the BOF and in the case of the pinnacles and LAMP also adopted by the NPFMC.

	We are greatly concerned for the health of the Chilkat and Unuk King Salmon as we are the community with the largest troll and sport harvest of king salmon. We are committed to working with the Department and BOF to conserving and rebuilding these stocks.  We are also committed to using our intimate knowledge of the fisheries in our area as fishermen, conservationists, and traditional users to advise the department on how to improve their plan by more precise use of area and time management tools, tag data, and fishermen knowledge.

	We understand it is the role of the department to prioritize the conservation of the resource. While the foremost priority of the BOF is also conservation and sustainability of the resource, it is also your role to consider the socio-economic and allocative impacts of the action plans.  We believe some amendments to the ADF&G Chilkat and Unuk action plans can have great socio-economic benefits with very minor impacts on king salmon escapements based on the best information (Coded Wire Tag) available to the public.

In Option B, Specific Action To Implement the Objective: on page 20 &21 of the Chilkat and King Salmon Rivers Stock Status and Action Plan 2018.

2. Troll Fisheries: Combination of time and area changes and closures.

Winter Troll: notwithstanding any remaining seasonal guideline harvest level [CLOSE THE WINTER TROLL FISHERY IN ALL WATERS OF SEAK/YAKUTAT BEGINNING SW 12, WITH] Section 15-A in Lynn Canal/Chilkat Inlet north of the latitude of Sherman Rock remaining closed to commercial trolling through December 31.
Spring Troll: limit opportunities during May and June spring troll king salmon fisheries to [TERMINAL HARVEST AREAS, WATERS IN CLOSE PROXIMITY TO HATCHERY FACILITIES OR RELEASE SITES; AND] areas and times that have not been identified as having relatively high proportional harvests of wild stock Chilkat [SEAK/YAKUTAT] king salmon; spring troll chum fisheries, as described in the District 12 and District 14 Enhanced Chum Salmon Troll Fisheries Management Plan (5 AAC 20.114) to open June [15] 11 with the retention of king salmon prohibited.
Summer Troll: [DELAY THE FIRST RETENTION PERIOD FOR KING SALMON DURING THE GENERAL SUMMER TROLL FISHERY BY A WEEK]. Open on July 1 to target 70% of the remaining troll king salmon annual allocation minus the number of treaty king salmon harvested in winter and spring troll. [ON JULY 8.] Remaining 30% to be harvested in August!

Troll Benefits: These amendments provide great socioeconomic benefits to the troll fishery, do not disrupt the traditional July 1 opening of the summer troll fishery with retention of king salmon, preserve chum troll opportunity beginning on June 11 as negotiated for a section of District 12, with minimal impact on Chilkat king salmon.  See attached sheet.

Troll Detriments: The proposed ADF&G plan will eliminate an average of 3020 troll kings in district 113-95 and 114 worth over $300,000 to save on average of 92 Chilkat king salmon in the spring troll fisheries.

The winter troll closure, while having some benefits in late April for Unuk king salmon does not benefit Chilkat king salmon.   
The summer troll opening delay will cause huge disruptions to the troll fishery to save no more than 10 Chilkat kings a year.