Alaska Board of Fisheries: 2026 Board of Fisheries Work Session (10/28/2026)

Good morning, everybody. The time is 8:46 AM. The date is October 28th. Welcome back to almost everybody in the room. Almost everybody.

We've got a couple new faces, um, around the table here. Um, we have 7 of 7 board members present. So before proceeding further, I'd like to have my fellow board members, uh, introduce themselves, followed by staff. And let's start with the, with the new faces. Mr. Seer, would you like to introduce yourself on the record, say hello and where you're from?

Hello, my name is Paul Sear. I'm from Ketchikan, Alaska.

Mr. Hickson.

Hello, I'm Blair Hickson. I'm from Wasilla, Alaska. Welcome to the new members, and we'll go start at this end of the table. Mr. Wood. All right, thank you.

I'm glad to be back for another 3 years. My name is Mike Wood, live in Chase, north of Talkeetna. And I am happy to be back, and I just want to send out my condolences to the department for their loss and friend of Phil Stacy. Starting a new year thinking of all the people that we have had with us giving us good information. So thank you.

Thank you, Mr. Wood. Ms. Irwin. Zan hazoon, Olivia sa'ooza, dehoond na gaheelay, hinahee seeznee. Good afternoon, everyone. My name is Olivia Hinahi Irwin.

I'm from Ninana, Alaska, and this will start my second year on the board. And I thank all of you for being here in person and those of you listening online. Hope everyone had a successful summer.

Good morning, everyone. My name is Curt Chamberlain. I'm from Wasilla, Alaska, starting my third year on the board. Glad to see you all.

Good morning, everyone. Tom Carpenter from Cordova. Good morning. Marit Carlson-Van Dort from Anchorage via Chignik Bay and Juneau. Let's go ahead and do department introductions, Mr. Commissioner.

Doug Vincent-Lang, Commissioner, Alaska Department of Fish and Game.

Good morning, Madam Chair. I'm Forrest Bowers, Director of the Division of Commercial Fisheries, and with you, with us Today from the division, we have Karla Bush, Extended Jurisdiction Program Manager, Bill Templin, our Chief Fishery Scientist, Andrew Monroe, our Statewide Salmon Fishery Scientist, Flip Prior, our Aquaculture Section Coordinator, Heather Skinnell, the Regional Supervisor for Central Region, Colton Lipka, Cook Inlet Management Coordinator, Kyle Gatt, Acting Cook Inlet Research Coordinator. James Jackson, Westward Region Management Coordinator. And Birch Foster, Westward Region Research Coordinator. Thanks, brought the guns today, nice.

Mr. Payton. Good morning, everyone. My name is Israel Payton. I'm Director of Sport Fish, and with me today here, I have Deputy Director Jason Dye, South Central Management Coordinator Patrick Fowler, also Management Coordinator Jay Balmer, Research Coordinator Nick Djokovic, and Regional Supervisor Chrissy Dunker is here as well. Thank you, Madam Chair.

Thank you, Director Payton. Director Pappas. Good morning, Madam Chair. George Pappas, Director of Division of Subsistence, and I believe I'm running solo today. It's great to see everybody.

Good, good, uh, Time to kick off another cycle. Thank you, Madam Chair. Thank you, Director Pappas. Looks like we've got a new face from the Office of Subsistence Management. Welcome.

Thank you, Madam Chair. Uh, Brian Eubaker. I'm the current acting state liaison for the Office of Subsistence Management. Welcome. Thank you for being with us.

And Department of Law. Good morning, Madam Chair. Edward Lee with the Department of Law. It's good to be here. And Department of Public Safety.

Good morning. Captain Derek DeGraff, Alaska Wildlife Troopers. Thank you. Good morning. Nice to see you guys back at the table.

Thanks. Director Nelson, will you please introduce yourself and your staff? Good morning, Madam Chair. My name is Art Nelson. I'm Executive Director for the Board.

And from Board support staff here, we have Annie Bartholomew, our Publications Specialist, Savannah Hollingworth, Publications Specialist for the Board of Game. And Annie and Savannah have been tag-teaming the implementation of our new sound system. You've probably all noticed the— spiffy new mics we've got around the table. So, uh, if you have any trouble hearing, just obviously let me or Annie know and we'll adjust sound levels. Uh, past Savannah, we have Layla, who is not here at the moment— Layla Williams.

Uh, and then at the very end, a brand new boards face, Jessica Byland. Uh, Jessica is our advisory committee coordinator for Southern Southeast. Welcome to boards. Thanks. Thank you, appreciate that.

Anybody that we missed?

All right, moving on. Um, just a little note for those here in the meeting room, as usual, if you have a hearing disability or just need a little help, um, hearing things, um, even with our brand new, uh, sound system, we do have wireless headsets that tie into our sound system and you can hear, uh, that'll help you hear the meeting better. Please ask board support staff and they'll provide you with one of the headsets And lastly, a reminder for those here in the room and those of us around the table, um, please turn off or silence your cell phones lest you go on a donut run. By the way, we've got some donuts in the back of the room, courtesy of Mr. Wood. Thank you, Mr. Wood.

Um, okay, I think with that we'll move on to election of officers, which is the next item on our agenda. The election of chair and vice chair— we'll do both of these and then we'll stand down for a short break. So starting with the chair.

Madam Chair, I would like to nominate Marit Carlson-Van Dort for chair of the Board of Fisheries.

Second.

Madam Chair, I would like to nominate Tom Carpenter. Is there a second?

Hearing no second.

Okay, so we've got two nominations for myself and for Mr. Carpenter for chair. I guess we will do a ballot vote, and we will stand down so that Director Nelson can prepare the ballots.

Please announce the roll— uh, the tally. Madam Chair, it is 4 votes for yourself And 3 votes for Mr. Carpenter. Thank you. Moving on to vice chair. Madam Chair, I'd like to nominate Tom Carpenter for vice chair.

Okay, thank you. Madam Chair, I'd like to nominate Olivia Irwin for vice chair. Okay, and we will go ahead and prepare ballots for vice chair vote. Mr. Nelson.

Mr. Nelson, please announce the results. Madam Chair, it was 4 votes for Miss Irwin and 3 votes for Mr. Carpenter. Thank you, Mr. Nelson. So the new chair is myself and the new vice chair is, um, member Irwin. Congratulations.

Member 1. All right, we will go ahead and move on to our next order of business. Mr. Carpenter.

Thank you, Madam Chair. I move the Board of Fisheries enter into executive session to discuss the following matters: confidential ethics issue concerning a board member, including legal advice from our attorney, legal issues concerning regulations adopted in March 2026, and issues in pending litigation. The executive session is authorized by the following sections of the Open Meeting Act, AS 44.62.310, paragraph C, uh, sentence 2 and 3, as ethical issues to be discussed include subjects that tend to prejudice the reputation or character of any person and includes matters of which by law, municipal charter, ordinance are required to be confidential. And AS44.62.310, paragraph 3, sentence 3, as regulations and pending litigations matter, will include discussions with our attorney that are protected by attorney-client privilege.

Madam Chair, I'm going to object for the purposes of— uh, I want to hold this discussion out in the open. Um, I will waive any confidentiality provisions related to that. Okay, there are—. Can I second? Yes, thank you.

Um, there are multiple issues on the agenda, so I, I think we should probably roll into executive, discuss those issues, and then come out if, if the member has waived privilege. Okay, Mr. Lee. Madam Chair, thank you. Yes, there's a motion before the board right now, so there needs to be an oral vote on that. Um, what Mr. Carpenter requested be discussed in the executive session.

I think the path you've kind of outlined, that can happen in the executive session. We can come back out and have the discussion publicly if that's the request of—. So to be clear, the motion is to go into executive, and there's a second for that? Yes. Okay, let's go ahead and do a roll call vote, please.

I'm sorry, Madam Chair, I didn't hear the second. Mr. Woods seconded. Oh, I'm sorry, I didn't hear Mr. Woods.

On the motion to go into executive session. Carpenter? Yes. Irwin? Yes.

Seer?

Yes. Carlson-Van Dort? Yes. Wood? Yes.

Hickson? Yes. Chamberlain? Yes. Okay, motion carries 7-0, Madam Chair.

Okay, thank you. We'll go ask— go ahead and ask the room to be cleared of all But the attorneys and the board members—.

Okay, we are back on the record. The time is 10:47, and, um, we just concluded our executive session. Mr. Carpenter. Thank you, Madam Chair. For the record, I and my fellow board members are returning from a meeting of executive session.

During executive session, the board members only discussed items identified in the motion to move into executive session. The trustees did not take any action while in executive session. In executive session.

I'll second that.

Any discussion, opposition to the motion? Hearing none, um, we have come out of executive session. We had a lengthy discussion. Before we move into ethics disclosures, um, there is a pretty beefy RC, I think, that's going to be prepared. Um, so we're going to go ahead and take an early lunch.

So that we can get that RC'd, get that distributed, people have an opportunity to take a look at it, and then we will move forward with our regular agenda following that, beginning with ethics disclosures, going through the committee reports, and then into staff reports. So, um, let's see, it's 10:50 right now. Um, let's go ahead and come back on the record at 12:30, 12:30, to convene, uh, to reconvene and move on with our agenda. Any questions, discussion? All right, we'll see you at 12:30.

Thank you.

All right, good afternoon everyone. Thanks for your patience. Um, hopefully you enjoyed an early lunch. The time is 12:36. We are back on the record and we're going to get back onto our agenda here, and I'm going to go ahead and give some of my usual instruction to the board and to the public, and then we'll move right into ethics disclosures and through the agenda as is.

Um, identified. Okay, so as most of you already know, but for some of the new board members, as members we are available to you for the purpose of receiving added information. This process doesn't work without your help. Many of us often meet with stakeholders informally during the breaks and both before and after daily meetings. We're here to serve you and benefit from your input.

There is a lane— line called the sanctuary line in front of the tables. Across which the public may not cross during our meetings and breaks. However, if you wish to talk with one of us, please just ask someone to notify whoever you'd wish to speak with, and generally we will come to you. Please keep in mind, however, that it is during these breaks and both before and after daily meetings that we find time to read all of the materials that's submitted during the meeting. If you have process questions, please let me know.

In order to ensure that the public is fully informed on the board's process, the chair, the vice chair, and the Executive Director, will answer all process questions that the public may have during the course of the meeting. It is hoped that the practices of the board outlined will maximize public participation in the board's process, and certainly the board believes an informed and engaged public can only result in better conservation and development of our fishery resources. The Alaska Board of Fisheries and the Department of Fish and Game are united in support of fostering a respectful workplace We are committed to ensure that our workplace is free from negative, aggressive, and inappropriate behaviors. Harassment of any nature is unacceptable and will not be tolerated, and we appreciate everyone's assistance in joining us in that effort. In accordance with the Open Meetings Act, the board staff published a notice in the Alaska Online Public Notice System, posted the notice on its main website, meeting website, as its designated posting place, and also distributed it to our list of email recipients.

I won't read it, but copies of the notice are in the meeting binder at the back table and are also available from the Executive Director for those who are interested in the complete text. The public notice and agenda change requests were distributed to the local Fish and Game Advisory Committees and many other interested organizations and individuals. Public comments were solicited, and board members have received copies of all written public comments. The timely public comments and timely Advisory Committee comments are available for the board's use and are also available to the public in the workbooks at the table at the back of the room. Copies of the agenda change change requests can also be found on the board's website along with all of the other written materials for this meeting.

Copies of the agenda for this meeting can be found on that back table. The agenda is subject to change throughout the meeting, but I will generally make an attempt to stay on it, um, and if there's any deviations, provide adequate notice to the public. We don't have a roadmap for this meeting, but it's not necessary as we intend to go through the agenda change requests in numerical order. Record copies The board encourages the public to submit written comments on specific ACRs or issues. Written public comments submitted by any individual or group cannot exceed 10 single-sided or 5 double-sided pages until the board begins consideration of the agenda change requests, at which time written comments cannot exceed 5 single-sided pages or the double-sided equivalent.

Exceptions to these page limits are only allowed if the information is requested by the board. Written comments submitted during the meeting are assigned a log number referred to as an RC and with a number in the and with a number in the order received. Written comments can be submitted through the board's website as a PDF or a Word document only. A link to the comment submission portal is prominently featured on the page of our website where all of the documents for this meeting are posted. If you want to turn in hard copies of written comments, please do so to the board support staff at the end of the table down there.

Please note that you will only need to turn in one copy. However, Board support staff will not have printing, um, will not be able to print submitted materials in color. So if you have something that you would like to have the board to see in color, you'll need to turn in 20 copies that the support staff will then distribute. With no exception, all materials are to be submitted to the board for— all materials which are to be submitted to the board for its consideration must be presented to the record keeper for distribution or uploaded through our website. Please do not give documents to board members directly.

If you do so, those documents will be handed back to you and you'll be asked to submit it for the record. All written materials submitted will be retained for permanent record of the board. The record keeper will distribute RCs in the morning, typically before the meeting begins, after the lunch break if there's an evening session, um, after the dinner break. I'm not anticipating that happen, um, for this work session. The practice— this practice ensures regular distribution of all written materials to the board member as well as proper retention of board records.

I'll just note that, uh, while you have the right to submit the maximum number of pages of written materials, please keep in mind that there's a lot of materials for us to read, and we appreciate your brevity. The board does not take oral public testimony during its work session. However, the board does accept written comment throughout the meeting, as I described in the RC process.

The work session is a non-regulatory meeting. However, at its 2013 work session, the board agreed that given the weight and importance of decisions that are made on acceptance and non-acceptance statements of agenda change requests, it's good public practice to provide ethics disclosures. I will also note that we were given guidance, recent guidance from the Department of Law as a reaffirmation of the board's practice, historical practice of not conflicting members out of agenda change request votes. So the ethics disclosures again are going to be put on the record as a matter of good practice. But, um, there's no conflicts that are associated with agenda change request acceptance votes.

If agenda change requests are accepted, they will be scheduled and noticed at a subsequent meeting, at which time any conflicts will be considered and determined by the board— by the chair and the board. Okay, any questions from members before we get going in the ethics disclosures? All right, we'll go ahead and begin our ethics disclosures. We'll start with Mr. Wood at this end of the table. And, um, Mr. Wood, the floor is.

Yours. Got a fresh one now. Don't have to bore you with 2 pages. All right, my name is Mike Wood. I live in Chase, Alaska, 5 miles north of Talkeetna, up the Susitna River.

I am a self-employed carpenter and do contract work for the Alaska Mountaineering School and Antarctic Logistics and Expeditions and other clients. I have a SO4H set gillnet permit and have registered in the Northern District on the west side of Upper Cook Inlet for 11 years. My wife and I own a fish camp on the Ivan River and a DNR shore lease site nearby. Our business, Sioux Salmon Co., is a small-scale catcher-seller operation that supplies low-volume fresh salmon to local markets. I am the volunteer chair of the board of the Susitna River Coalition and the past chair of the Chase Community Council and the Matsu Borough Fish and Wildlife Commission, where I served for 10 years, 6 of which I was chair.

My wife Molly is an independent consultant. We both received the Alaska Permanent Fund dividend. I have a current hunting, fishing, and trapping license. Neither my wife nor I are involved in any lawsuits against the State of Alaska Board of Fisheries. Or the Department of Fish and Game.

And, um, everything I say is true, correct, and dead on to the best of my knowledge. Thanks. Dead on and complete, since complete is an issue. Yeah,. It was complete.

Thank you. Um, Mr. Hickson.

My name is Blair Hickson. I live in Wasilla, Alaska, originally from the Bethel area in the Anvik River. During the summer and fall, I work as a fishing and hunting guide at my family's lodge on the Anvik River. I'm a registered guide and outfitter. I also hold a resident sport fish hunting and trapping license, as well as a guide registration card.

While serving on the Board of Fisheries, I'll receive a stipend. I also receive a permanent fund dividend. My parents, Cliff and Cheryl Hickson, own Alaska's Anvik River Lodge, a fishing and hunting lodge on the Anvik River. We host guests on guided trips to fish for Arctic grayling, Arctic char, northern pike, whitefish, and salmon. I also guide hunters out of the lodge.

My immediate family consists of my parents and one sister, all of whom live in Alaska. In 2023, prior to my service on this board, I gave testimony on SB 128. No action I take on this board will benefit me or my employer personally or financially. Neither I nor any member of my immediate family nor my employer is involved in any lawsuits against the state, the department, or the Board of Fisheries. I certify that this disclosure is true, correct, and complete to the best of my knowledge.

Thank you, Mr. Hicks. And Ms. Irwin. Thank you, Madam Chair. My name is Olivia Henahi Irwin. I am Inupiaq and Koyukon from Ninana, Alaska.

I am employed full-time as the Projects and Watershed Operations Manager for the Yukon River Intertribal Fish Commission. My responsibilities focus on implementing watershed projects and coordinating the practical work needed to complete them. This includes organizing habitat stewardship, fish camp activities, monitoring, and restoration. These responsibilities focus on carrying out projects and supporting practical work in the watershed. They do not involve any— the development of any fisheries policy or deciding the organization's position on regulatory proposals.

I receive project priorities and strategic direction from my executive council. My job description expressly excludes responsibility for developing fisheries management strategies, managing governance systems, or leading organizational communications. I take leave without pay during our Alaska Board of Fisheries meeting. Neither my current nor past employer are responsible for authoring any proposals before us at this work session. Prior to my employment at the Fish Commission, I was the community engagement coordinator at the Yukon River Drainage Fisheries Association, and prior to that I was a natural resource policy consultant with Tanana Chiefs Conference.

Prior to my time on the board, my other sources of income include honorarium from the University of Alaska Fairbanks in 2016 2026 for guest lecturing two classes in the Tribal Governance Department, a dividend from both Doyon Inc. and Evansville Inc. as a shareholder of the Alaska Native and Village Corporations established under the Alaska Native Claims Settlement Act, and I received a permanent fund dividend and will receive a stipend from the state of Alaska for my time serving on the Board of Fisheries. I have no current or past financial interest in any fisheries. My immediate family consists of my four siblings, only one of whom resides in Alaska. Along with 2 aunts and 4 uncles who also reside in Alaska, none of whom are currently involved in fisheries work or business. My Aunt Marie Monroe retains 2 commercial fishing permits for the Tanana River, net and fish wheel.

She is not an active user and has not fished the permit or financially benefited from it since 1993. She has no intentions of fishing for the permit in the future. She reauthorizes her permit annually to honor my late uncle. I am a pers— I have a personal use dip net permit holder, uh, for the 2025 season, and I hold an Alaska resident hunt/fish trapping license. No member of my immediate family, myself, or my employer are involved in any lawsuits against the state, the department, or the Board of Fisheries.

I certify that this disclosure statement is true, correct, and complete to the best of my knowledge, Madam Chair. Thank you. Any questions? Hearing none, we're going to go ahead and move on to Mr. Carpenter.

My name is Tom Carpenter.

I reside in Cordova, currently retired. I've divested myself completely of all businesses, including limited entry permits and IFQs. I receive an Alaska Permanent Fund dividend, as does my daughter. I receive a stipend for serving on this board. I purchase Alaska sport fish hunt license each year and hold annually a Copper River subsistence permit.

Neither I nor anyone in my immediate or extended family have any financial interest in any business which relates to fish and wildlife resources or belong to any organizations to which any financial gain can be attributed. There are no ACRs before the board that will benefit myself nor anyone in my immediate family. No member of my family is involved in any lawsuits against the state of Alaska or the Department of Fish and Game. I believe this statement to be true, correct, and complete. Thank you, Mr. Carpenter.

Any questions? Hearing none, we'll go ahead. Mr. Chamberlain. Thank you, Madam Chair, and for the public. I'm sorry, this is going to be long but necessary.

Uh, good morning. My name is Curtis Chamberlain. I work as Deputy General Counsel for Chalysta corporation. My wife is a school administrator. I currently hold a hunting, fishing, and trapping license.

I am a TKC shareholder, which is an Alaska Native Village Corporation created under the Alaska Native Claims— or under the ANCSA, Alaska Native Claims Settlement Act. I'm a descendant of Chalista. I get a dividend from TKC every year.

No member, neither my— neither I, my employer, or anyone in my family has any interests or financial interests in any fisheries.

Similarly, neither I, my family, or my employer have any litigation that involves the state or the Board of Fisheries. I will receive a stipend for serving on this board. As disclosed recently in RC-5, the Department of Law issued a finding of ethical violations in my disclosures before the Alaska Peninsula Aleutian Island Chignik Lagoon meeting last year. Though it did not make a finding of conflict and it did not rule that I misrepresented or lied in any way, it opined that I did not sufficiently disclose my background but offered as a remedy the ability to seek an advisory opinion from the Department of Law so the board can correct this error in the future. I sought an advisory opinion from the Department of Law pursuant to their recommendations.

After several— and after several months, an advisory opinion has not yet been issued. I was seeking to keep this matter confidential to avoid embarrassment for the department, the board, my employer, and myself. I was hoping for a clear advisory opinion so the board could move forward. However, less than 12 hours before the meeting, I was informed that my statement would be shared with the board. Having worked in project management, I know that maintaining confidentiality among 7 individuals is impossible, and to control the narrative, I opted to disclose my communication, uh, with the public to ensure the narrative doesn't go off the rails.

And as a personal note, I got this notice at roughly 9:30 last night. I went into my offices and forgot my key card and got locked out where my computers and keys were in there. I had to sleep in the lobby. So if this is choppy, that's why. Sorry, everyone.

And so what I'm looking to do right now is I want— I'm going to disclose as much as I can to the public. I've asked— and I've asked Eddie, the ethics advisor, is for the board is going to be on— is listening in. I am going to ask at the end if the Department of Law has any questions for me because what I want to do today is I want to cure that ethical violation and make sure that my record is complete. And I also want to say publicly on there that I do not believe I was incomplete or inaccurate in any of my disclosures. I fully stand behind my disclosures as previously made.

But I will need to make a very complete disclosure to ensure this. There's been several rounds of back and forth, as you'll see in RC5, where I have standing questions with the department. They've asked— they've come back with more questions that I, I believe misrepresent the law. And— but I want to make sure that we are covering everything exactly. I want to be crystal clear on this record.

That everyone— everything I am doing is above board, and I want to ensure complete transparency. My opinion is that this is— that this filing— that this finding from the Department of Law was politically motivated and not supported by the facts or the law, and I want to bring this out in the open. I think, uh, airing this out in, in a public venue is probably the best way to do that. I also don't want this to happen again. I want clear direction for the board, and I want to have clear expectations for the board.

So with I'll continue.

My father owns a drift net permit on the Middle Kuskokwim. It was last fished in the summer of 1994, I believe, or it may have been fished in 1995 or 1996. That was the last summer I fished it, and I'll correct that. When the combination of fishing closures and processors pulling out caused the closure of the Middle Kuskokwim fishery, the lower river fishery limped around for about a decade or so until the processors pulled out and fishing opportunity was effectively we eliminated. Even in the years where the processors were in the lower Kuskokwim, the fish runs and prices could not support the cost of gas to make the trip to the lower Kuskokwim economically feasible.

There has been no reasonable opportunity for commercial fishing in decades, and my father has been— hasn't been able to give it— even give his permit away. It's common for fishermen on the Kuskokwim to state their permit's not worth the paper it's printed on. My father and I are two of those people. Neither I, my siblings, nor any of my children have ever expressed any interest in continuing commercial fishing or holding the permit.

I'll speak next to my employment advocacy through Chalista Corporation. I am employed as Deputy General Counsel for Chalista Corporation. Chalista Corporation is a regional Alaska Native corporation created under the Alaska Native Claims Settlement Act. Challista has more than 40,000 shareholders living across the world, including in the Aleutian Peninsula. Challista employs over 5,000 people and has annual revenues of roughly $1.27 billion.

Uh, Challista is number 6 on the Alaska Business, uh, Top 49ers in terms of revenue. Uh, as most Alaska Native organizations, a lot of those make up the, a large portion of, of the of the, the top 49 businesses in the state and operate as a large economic driver in the state. Chilista operates with over 100 subsidiaries, primarily in the areas of government contracting in aerospace and defense, heavy civil construction, oil field services, and real estate. I was brought to Chilista for my— based on my experience as a trial attorney and owner of a law firm focusing on construction law, civil litigation, and business law. My title prior to becoming Deputy General Counsel was Assistant General Counsel for Corporate Governance and Litigation.

As my prior job title suggests, my expertise is not and has never been fisheries. However, I volunteered to advocate for fisheries as I had a background in commercial, sport, and subsistence fisheries. I want to make the record perfectly clear. Chalista does not have an interest in fisheries and generates no revenue related to fisheries. With respect to the area and fisheries, Chalista and I will receive no financial or personal benefit on any of the proposals that were ever before the Board of Fisheries.

Chalista has advocated for responsible fishery management, including but not limited to time and area restrictions for Area M. Since it has no commercial interests in Alaska's fisheries, Chalista's advocacy was pure political speech, which is entitled to the highest protection under the First Amendment of the United States Constitution. Chalista merely having an opinion on a matter does not create a conflict of interest where Chalista has no commercial interest at stake and is not paying me to obtain a particular result. To that end, Chalista does not engage with me in any regulatory discussions related to any matter before the Board of Fisheries and has never advocated for or against any proposal before the board while I sat on it. Growing up in the Chilista region, my views largely align with those in the region. As such, my views largely align with those of Chilista when it comes to fisheries management.

In 2023, I volunteered to take on drafting and speaking for Chilista Challista in the fishery space. This permission was permissive and not tied to my employment metrics. Similarly, my application and for the— and for and participation in the Board of Fisheries was permissive. I asked to run for the Board of Fisheries and was granted permission to do so by Challista. Challista did not ask for me to do this.

It was my choice. None of my employment metrics were tied to participation in the Board of Fisheries or any proposals before it. Though I drafted two letters for Chalista to the Board of Fisheries and put these statements through the protocol groups, all opinions were expressed therein were my own. In no other statements did— regarding fisheries did Chalista seek to influence my opinions or insist I take any action, even before joining the Board of Fisheries. Since I joined the Board of Fisheries, Chalista has ceased all regulatory actions in federal, in state and federal water fisheries.

Notwithstanding these statements, I want to go into as complete of a description of my, my statements on behalf of Chalista, independent of Chalista, and Chalista's statements independent of me. My statements, my involvement in statements on behalf of Chalista as follows: I drafted RC-11 on behalf of Chalista Corporation in for the February 2023 Alaska Peninsula regulatory meeting and testified live in support of these comments at the regulatory meeting. My written statements and verbal testimony were vetted and approved by the Chalista Protocol Group, but no edits, but no changes were recommended to me other than minor grammatical changes. My responses to the board's questions were my own.

RC-11, I'll be attaching this as an exhibit, and I'll be attaching much of what I'll be stating as an RC later, later down the road. I just didn't have time to draft this on this short of a notice. I assisted in drafting through Chalista's protocol group, a president's message to Chalista shareholders urging all shareholders to provide testimony and input in the upcoming Aleutian Peninsula Board of Fisheries meeting prior to that meeting. In 2023. I drafted RC number 5 in October of 2023 for the Hatchery Committee meeting and testified live in support of those comments at the meeting.

The written comments were vetted and approved by Chalista's protocol group. The verbal testimony was my own. RC—. And I drafted PC 10 for the October work session in support of agenda change request Number 3, for the October 2023 work session, and testified for the same at the work session. The written comments were vetted and approved by Chalista's protocol group, and the verbal testimony was my own.

On top, on top of that, I regularly participate in meetings on behalf of Chalista where we engage in either advocacy with governmental agencies or before the shareholders or the general public. These are too numerous to speak on. I estimate I speak publicly every, every once every week or two. However, all regulatory meetings regarding fisheries have been, are being disclosed to the best of my knowledge. I have testified before the United States House of Representatives, the Secretary of Interior, the Secretary of Energy, the Secretary for the Small Business Administration, both legislative houses for the states of Alaska, Washington, and Oregon.

I speak regularly at public forums with very few engagements actually speaking on fisheries. The vast majority are actually on government contracting, infrastructure development, or large political issues. In fact, I'm invited to speak at a defense forum Friday at the Denaina Center to speak on government contracting and infrastructure needed for the United States to be defense ready in western Alaska. I believe this is an only event, an invite-only event. But if you can attend, I encourage everyone to do so.

My statement's independent of Chalista. On May 1st, 2023, I testified as an invited fact witness before the Senate Resources Committee to testify as part of an Area M overview. Although the topic of the session was for an overview of the Area M fishery, The underlying context was SB 128, which was pending at the time. This, this bill aimed to close the area and fishery for the month of June. I spoke, I spoke, I spoke to the relative abilities of the Yukon and Kuskokwim regions and the Aleutian Peninsula to withstand reductions in salmon fishing.

My intention at that hearing was to inform the legislature on the effects of the salmon crash in the Yukon and Kuskokwim Rivers. And the resilience of the— resiliency of the Aleutian Peninsula due to the diversity of its fishing activities. Though my job description was listed when I was introduced and I asked Chalista executives if they had any issue with me testifying, this was less than 24 hours notice.

They didn't have any issues. I consider this statement to be my own because I drafted it on my own. I did not review this with any protocol groups. In fact, I think I finished speaking on this less than 10 minutes before, or drafting my comments less than 10 minutes before they, they went, before I said them.

I was initially asked to speak as an expert witness on the legality of SB 128, but declined as I did not know this area of law well enough to classify myself as as such. I want to clarify, I come from the world of litigation where there are fact witnesses and expert witnesses. An expert witness speaks as to specialized areas of law or fact that are not available to the general public. A lay witness testifies as to their general knowledge. I considered myself speaking as a fact witness in this forum, not as— and when you look at the ethics opinion, it takes exception that it viewed my statement as advocacy.

Of course it was advocacy. You don't testify before the Senate Resources Committee unless you want a particular result. And in my instance, this particular result I wanted was to inform the legislature of the economic disparities and the disparities in the social situations between the Aleutian Peninsula and the Yukon-Kuskokwim areas. Now, SB 128 had no chance of passing at that time. Everyone knew it.

The proposers knew it. Um, but I— and so my intention there was to lay the groundwork for future action. This was advocacy. It just wasn't— and I did not advocate for or against passage of SB 128. My intention— and I intentionally stayed silent on that matter.

On October 20th, 2023, I was selected as one of 5 speakers for the Yukon Kuskokwim Delta Caucus and approximately 60 speakers overall to speak on issues of subsistence across Alaska. I was selected by the Yukon-Kuskokwim Caucus to speak on issues related to the Yukon-Kuskokwim Delta. I was selected by the caucus with about 1 hour to draft the remarks before speaking and did this independently of Chalista. Though I did solicit the help of another coworker to proofread my statement to help me shorten it down to 3 minutes. Those of you who see me speak regularly know 3 minutes is a challenge.

This did not go through Chalista's approval or protocol processes, though my comments were later published in Chalista's Storyknife newsletter. They were also published in approximately a dozen other newspapers and outlets nationwide. I view these comments as my own, as I drafted them on behalf of the residents of the Yukon-Kuskokwim Delta, not on behalf of Chilista.

On November 2nd, 2023, I was an invited guest on the radio show Native Americans Calling to speak on the history and practical effect of the American National Interest Land Conservation Act. I spoke on personal knowledge, and this testimony or this speaking engagement was my own. On or about March 25th, 2024, I was again an invited guest on Native American Calling to speak on the history and legal frameworks on the Treaty of Cession, how the United States acquired Russia's interest in Alaska, and how it influenced and led to the passage of the Alaska Native Claims Settlement Act and the status of Native American subsistence rights as it pertained to that historical significance. In September of 2024, I was an invited panelist for the Kenai River Classic roundtable on the benefits of engaging with Alaska Natives for cooperative removal of pinnipeds for the purpose of, uh, uh, rehabilitating salmon and shellfish populations throughout the coastal areas of Alaska. On or about October of 2025, statements I made surrounding climate change, outmigration, and salmon collapse were published in an online magazine, The Margin.

These statements were a personal reflection of my experience outmigrating after the Kuskokwim salmon collapse and the effects of severing my cultural ties to the land. In addition, I don't have a specific date on this one because I just don't remember, and I didn't have time to look through all the historical documents with the short time notice. I did testify before the North Pacific Fisheries Management Council on chum bycatch on one occasion.

Chalista's advocacy, advocacy on fisheries that do not include me. On August 6th, 2020, Chalista issued a letter to Governor Dunleavy to drop Alaska's lawsuit against the Federal Subsistence Board, or asking— yes, on August of 2020, Chalista spent about $10,000 in CARES Act funding to send salmon to lower Kuskokwim villages. Alaska when they started experiencing their salmon crash. In or around November of 2020, Txe'lista advocated for increased funding from the Department of Commerce for research that fully incorporates Indigenous knowledge amounting to declining salmon runs in the Yukon and Kuskokwim River drainages, including climate change, the life cycle of salmon in ocean, and the effects of the ocean environment and other factors for the decline. In and around November of 2022, Chalista issued a statement to the— on the Alaska Salmon Bycatch or Alaska Bycatch Review Force, of which Director George Guy served as co-chair of the Western Alaska Subcommittee.

On June 1st, 2023, Chalista sent a letter to the North Pacific Fisheries Management Council regarding exclusion of the Exclusive Economic Zone from its Salmon Fisheries Management Plan. This opinion was drafted by outside counsel and I had no involvement. In August of 2023, Chalista published an article in the Storyknife with a Q&A with the executive director of the Yukon River Drainage Fisheries Association. In November of 2023, in its November 2023 Storyknife newsletter, Chalista published comments I made on behalf of the Yukon-Kuskokwim Delta Caucus.

In its March-April Storyknife newsletter, Chalista published an article outlining upcoming Federal Subsistence Board meetings and provided links for shareholders to comment on that platform. In its May-June 2024 Storyknife newsletter, Chalista Corporation issued a message from President Andrew Guy encouraging Chalista shareholders to engage in regulatory meetings. In one sentence of the message, President Guy announced my appointment to the North Pacific Anadromous Fish Commission Advisory Panel and my nomination to the Alaska Board of Fisheries. In its March and April 2025 Storyknife, Chalista's president and CEO wrote on the importance of advocacy and encouraged shareholders to participate in the upcoming North Pacific Fisheries Management Council meetings. President Guy also announced a donation to the Yukon River Drainage Fisheries Association fund of rural Yukon residents for travel for a few rural Yukon residents to the North Pacific Fisheries Management Council meetings.

The newsletter also featured an article encouraging shareholders to participate in upcoming FSB meetings, AFN subsistence listening sessions, and the upcoming North Pacific Fisheries Management Council meetings. In a March-April Storyknife letter of this year, Chalista Chair Willie Kasayeli drafted a letter to Chalista shareholders encouraging them to make themselves heard through public advocacy, including, amongst other areas, fisheries. Now, I want to go into some detail in the level of search I did.

I looked throughout the Board of Fisheries submitted RCs and public on-time public comments all the way back to 2003. There were 3 RCs submitted by Chalista Corporation. All 3 of those were drafted by me. There is no other instance before the Board of Fisheries in the 23 years prior that Chalista had engaged in Board of Fisheries regulatory processes. With regard to the story, nice knife newsletters and press releases.

Challista holds those publicly on its, on its web page. I scoured through roughly 700, over 700 press releases and newsletters to find these, these results. The earliest I ever found advocacy on fisheries issues was in 2022. Prior to that, there were no, no press releases and Challista did not engage in Fisheries regulation. With that, I'm comfortable saying that the bulk of regulatory actions Chalista took with regard to the Board of Fisheries were primarily the result of me weighing in and offering to speak on behalf of Chalista on this.

Now, given the severity of the salmon crash in 2020, I have no doubt that Chalista would have drafted that. But me being the attention hog I am, I stepped in and took over. Um, but Chalista's advocacy for the Board of Fisheries is complete, uh, as far as I know. I, I inquired to, uh, the Land and Natural Resources Vice President, um, the External Affairs Vice President, to look for public statements and search through, uh, uh, internal documents of prior opinions with that I had access to. And was not able to find anything of any significance in there.

Now, there, there may be things I've missed. Uh, I spent roughly 3 days scouring for these documents, uh, but there were a lot to go through.

Um, so as I stated before, Chalystia generates over $1.27 billion— or generated over $1.27 billion in revenue in 2025. None of this revenue is derived from fishing interests. However, the needs of Chalista are much greater than, than fishing alone, and I'm going to spend some time going on to what, what the needs of the region are, because they're very— they're all of high importance to Chalista, and it's important to form the context of fisheries in relation to the other needs of Chilesta. Um, the communities within the Yukon-Kuskokwim region face many challenges, including but not limited to basic infrastructure, lack of stable or sustainable economy, high poverty rates, lack of employment, and some of the highest costs of living in the nation and the world. Many lack basic infrastructure such as roads, running water and sewer.

Electricity in some Alaskan communities is among the most expensive in the world. For example, for a period in 2023, Alaska's electricity rates topped out at $1.60 per kilowatt hour, nearly 4 times that of Bermuda, which has the highest prices— electricity rates of any country in the world. The Denali Commission report in 2020 reported in 2020 that 29 of the 34 communities in the Yukon-Kuskokwim region were economically distressed. According to the Alaska Department of Labor and Workforce Development, distressed status is determined by comparing average income of a community or CDP to full-time minimum wage earnings, the percentage of the population earning greater than full-time minimum wage earnings, and a measure of percentage, uh, we—. There's—.

They have a formula. I don't want to read it to you guys, sorry. Uh, the high cost of living due to our community's remoteness only amplifies the effects of poverty and inadequate infrastructure and services. For example, because many of our communities are not connected to an energy grid, most rely on barged oil for heating and heavily aged diesel generators to provide electricity. As a result, The electrical utility rate in Alaska Native communities are some of the highest in the nation, as I previously described.

Moreover, in the dead of winter, many of these communities have failing generators and are facing crises where their water source wells are freezing up and they're not able to generate even fresh water as a result of unreliable electrical infrastructure. Fuel for vehicles must be barged into communities. In the region's largest economy, Bethel, barge fuel prices drive a wedge into basic life affordability. Recently, a gas station in Bethel charged $8.13 for a gallon of gas and $8.58 for a gallon of diesel. Heating oil is even higher.

Similarly, food and other necessities are barged and flown into the communities and are especially expensive. In the Yukon region communities. For example, a gallon of bleach could cost $30, a 12-ounce count of coffee beans costs $15. Uh, compound these crushing economic conditions, there are simply too many job— too few jobs available in the Yukon-Kuskokwim regions due to lack of economic opportunity and the high cost of doing business. Regional planning documents identify concrete barriers to economic participation.

The April 2024 Yukon-Kuskokwim Comprehensive Economic Development Strategy, uh, YKSED's education and work workforce development summary reports they have an average unemployment rate of 11.2% for Bethel and Kusilvak census areas, citing 2022 American Survey 5-year estimates. The same summary identifies limited local jobs and vocational training, high teacher turnover, unreliable internet and cell service, inadequate affordable childcare, limited long-term career advancement. These conditions underscore the importance of accessible training, portable, portable credentials, and sustained local hiring. Housing and essential infrastructure needs are also substantial. The April 24 YKSED's Housing and Water Sewer Infrastructure Summary reports complete plumbing facilities in only 70.7% of occupied housing units in the Bethel Census Area and 73% in the Kusilvak Census Area, citing 2022 American Community Summary 5-year estimates.

It identifies a lack of available and affordable housing, high construction and shipping costs, and limiting capacity for infrastructure and operations. I'm going to— and I'm done with that part. So for all intents and purposes, Chalista is a for-profit corporation with nonprofit purposes. Outside of a reinvestment, all of Chalista's, uh, Chalista Corporation profits, like all NCs, goes to dividends of all its shareholders. Chalista's September 2026 statements include cumulative dividends distributing— distributions exceeding $180 million, including $13.7 million in elder benefits and more than $7.7 million in scholarships provided by Chalista Education and Culture since 1994.

As these figures demonstrate, Chalista's focus is much more than fishing. Chalista Region faces massive infrastructural and economic changes long before the salmon crash, and it will face much, much more than the— and it will take much more than the return of the salmon to cure these ills. To give clarity to these facts, I want to put the, the, the complainants who submitted RC-4 and RC-139 from the 2025 Alaska Peninsula Aleutian Island Chignit Finfish meeting into perspective. Oh, okay, I've already covered that. I'll— I'm trying to skip ahead to save you guys time.

As it— so Chalista is a for-profit corporation that is working to develop profits, to develop and, and work for— to, to distribute to its 40,000 shareholders and to work for the socioeconomic conditions of betterment of its region and its shareholders throughout the world. As it should, Chalista is dedicated to ensuring it maintains a profitable business.

As you know, as to accusations that my employment at Chalista were tied to obtaining restrictions in, in fisheries, I wish that were the case. It's not. Uh, fisheries is not tied to my employment metrics at all. Uh, sadly, my job is way more complex than that. Over the past year, I've been responsible for ensuring each of our over 100 subsidiaries remains compliant with all state and national governments they're in.

I've overseen dozens of litigation cases in various jurisdictions. I've assisted in negotiation and drafting agreements with values in the hundreds of millions of dollars. I've negotiated and drafted credit agreements worth even more. I've overseen construction projects across the country. I've worked with Alaska Native corporations and tribes across the nation to address recent threats to the SBA's 8 program.

I've worked with a mining partner to ensure the opening of a gold mine on Celeste, with a Celeste-owned gold deposit with, with proven gold deposits worth over $100 billion. This includes overseeing litigation before the Alaska Supreme Court, negotiating and drafting partnership agreements for the construction of the mine, reviewing and recommending changes to the supplemental EIS that was just issued, assisting with the mining partner's listing on the New York Stock Exchange. This matters.

I oversee serious HR complaints for over 5,000 employees. On the upside, I assisted in the search and the hire of a new vice president of human resources. We're super excited to bring her aboard.

I read roughly 500 pages a day for work. A little of that is related to fisheries. I have to track work hours for federal reporting purposes. I worked 185 hours in the last 2-week pay period. None of that was related to fisheries.

I want to make the record clear that none of my compensation is tied to fisheries. I cut my teeth as a trial attorney in Las Vegas for over a decade. None of my professional experience on my resume was ever tied to fisheries prior.

At no time, point in time, did— before my time on the board, did Chalista direct, supervise, review, or evaluate me based on any actions before the Board of Fisheries. Since serving on the board, I do not provide legal advice to Chalista on matters pending before the board, nor or review any Chalista submissions before the board because there are none. Chalista does not condition my compensation, employment, evaluation, or advancement on any action I take or refrain from taking as a board member. No officer or employee has ever spoken to me on any fisheries matter before the board, let alone attempted to influence my vote. Chalista has engaged outside counsel to ensure this is this is— that we have sufficient processes in place.

Uh, fisheries are simply not part of my job duties. Um, I want to say, uh, recently a board member complained at the Alaska Peninsula Aleutian Island meeting that I get paid six figures and then that may influence my decision-making. Uh, that decision was reiterated yesterday before the Department of Law and in orientation and training. I want to say, and I sympathize with that board member, I, I grew up in dire straits. I remember sleeping in my brother's pickup truck in Fairbanks in December and figuring out how to make $4 feed me for a week.

For those of you wondering, red beans and rice collectively contain all the amino acids you need to fulfill your protein needs. I credit my Yup'ik upbringing to getting me out of that life. I grew up, we started working at 6 AM and we'd go to midnight. This work ethic helped me work 3 jobs to get through undergrad, helped me win a national championship in judo and earn a full scholarship to law school at Michigan State, and then eventually hang my own shingle at a law firm. I owe a lot of what I have to my Yup'ik upbringing, and without it, I would never be here.

I'm not cashing in here. I—. Working at Chalista is my way of giving back to the region that raised me, and my service on the Board of Fisheries is me giving back to the state of Alaska. God knows it's not for the money.

I want to speak now to the Department of Law's order of corrective action. I want to first enforce— first and foremost, emphasized that the board— that the Department of Law did not find a conflict, yet still voided a full slate of proposals. Moreover, in my discussions with the Department of Law, they did not disclose that there was a remedy where I could form— well, they did disclose a long-term remedy, but they did not disclose that there was a short-term remedy for correcting this. I followed their recommendations to seek a determination, and I did so, and it's now been 3 months without a determination. When the Department of Law sent questions surrounding my ethics disclosure, I invited them to ask questions.

And this was during the litigation, if they needed more clarification. Instead, I received a phone call saying that I will be thrilled to know that they— that I'd be thrilled to know they voided the action. They didn't have to disclose any perceived wrongdoing. I, I may have done. Uh, I would have been more pleased if the Department of Law opted to charge me for an adjudicary— adjudicatory proceeding so this could have been held out in the open.

Um, I've been waiting for an ethics determination for months now so I can get a determination of no conflict, but I got a call less than 12 hours before the start of the meeting that what was supposed to be a confidential opinion was going to be shared. The Department of Law opted to hide behind confidentiality to obfuscate what can only be a political decision and a series of delay tactics and ambush, ambush techniques to throw me off. If that's to be, I'd rather this happen in the light of day with— so I'm sorry, I'm trying to shorten this up for you guys.

Um, to the best of my recollection, the only time I, I advocated for a time and area reduction in REM was in 2023, where I drafted a written proposal on of Chalista and offered verbal testimony for a reduction in time and area in the month of June where a high abundance of AYK salmon, and actually increased time and area where AYK salmon abundance was low. Even under the most generous of observations, I can't— this cannot be construed as advocating for the Area of M. I did not state— I did state that the board had chronically mismanaged Alaska salmon stocks, including Yukon Chum, This was based on facts present prior to the 2023 meeting and not reflective of the facts before the board in 2026.

In its order of corrective action, the Department of Law presumed my testimony before the Senate Resources Committee— they presumed an intent that was not there. I never stayed— I never advocated that for the closure of that, of that, of the fishery for the month of June. I stand by, and even if I had advocated for the passage of SB 126, the area and fishery operates through the month of September. As such, SB 128, if passed as, as drafted, would have reduced time in the area and fishery by approximately 20%, but not closed it. I stand behind the truth, accuracy, and completeness of my statements.

With respect to Chalista's positions, the Department of Law again presumed misleading testimony where none exists. I can affirm Chalista has taken steps not to interfere in any regulations in matters before the board. I'm actually going to ask that, you know, my supervisor is a licensed attorney who went to law school at Harvard. My— the CEO is a licensed attorney in the state of Alaska. The vice president of external affairs is a licensed is a licensed attorney in the state of Alaska.

Each of these people undertook an oath to uphold the law and to operate ethically within this platform.

And any conflict there or any imputation on that is distressing. I was recently asked how would I feel if one of the Aleutian Islands attorneys was on the board of directors or was on the board of fisheries. If— and quite frankly, I know that attorney, his name is Rob Masulich. Alyut made an amazing hire when they got there. And I think if he maintained the separation I did, I wouldn't have a heartbeat of issue with him being on the board of fisheries, with the exception that he knows nothing about fisheries.

From an ethical and An ethical standpoint, I, I've worked with Rob over the, over the course of my career, and he is one of the finest men I've ever met. I have no reason to, to, to, uh, to question him. The fact that I'm an attorney creates— is it— but that question creates a different standard for me than every other person in the public. And it creates an impossible standard that no, no person can, can live by. I am bound by the rules of professional conduct for as an attorney, and these are rules that no other person has.

And so I am very careful and deliberate when I state things, and I'm also very careful and deliberate not to break any laws, not to misstate things in the public forum. And so I want to be very, very careful on that. The Department of Law asked for questions on Chalista's prior stances on subsistence and, and restoring Aboriginal hunting and fishing rights. Chalista's stances on subsistence. Chalista supports a subsistence constitutional amendment or a constitutional amendment supporting a subsistence priority.

This priority is no different than what is already codified in state law and really affects no real change in the regulatory scheme.

There are no pending constitutional amendments put forth is an innocuous question from the Department of Law to which I can't answer because there are— it's a very broad statement made by Challista's president and CEO, and there are no concrete legislative proposals before the legislature that we can speak to. With regard to Aboriginal hunting and fishing rights, Challista supports a repeal of ANCSA Section 4B, which terminated Alaska Native Aboriginal hunting and fishing rights. However, even that is innocuous because nobody— there's no firm understanding of what that means. If you were to restore Aboriginal hunting and fishing rights, does that Is that limited to subsistence or is it to commercial fishing as well? These things are very broadly defined and are very broad terms.

I can't elaborate on more because there is no elaboration.

The Department of Law also asked, and I should also point out that a subsistence priority constitutional amendment in recent polling before the Alaska Federal presented to the Alaska Federation of Natives showed 75% support among Alaska residents. Native subsistence proposals showed support 65% among Alaska residents. These are not unique and these aren't unicorn issues. These are issues tied to very broadly defined groups of people. With respect to— and I apologize to the Department of Law, I said Proposal 24-1.

Resolution 24-1, they asked for more explanation on that. I want to give that on the record. Resolution 24-1 is a resolution passed at the annual convention. I think it might have been 23-1 if I'm going— and I may have mistyped, I have to double-check that. But it was a very broad— and it was where I spoke to AFN.

It was a very broad resolution introduced by Tanana Chiefs Conference and passed by all but I think Aleut and maybe Koniag or Siri, but it was passed overwhelmingly amongst Alaska Natives at the, at the Alaska Federation of Natives convention, annual convention. Now, question is, what's being done on that? Chalista serves as one of 32 board seats, and since that resolution has passed, AFN has passed a unity, uh, uh, like, uh, a position where they try not to engage in divisive decisions. Um, I'm going to speak on my personal opinion. This is not Chalista's because they, they'll want a distance from it.

But, uh, a consensus model is the perfect way to make yourself useless. Um, there have been listening sessions, but there's been no con— no concrete action, uh, taken, uh, with respect to 24-1. It is a large-scale, um, uh, effort that I applaud for, uh, AFN for taking, but there just hasn't been a lot of movement on this. Um, and finally, I just want to state that none of the— none of my public speaking instances on fisheries regulation took place before I took place while I was on the Board of Fisheries. Um, I, I know I'm getting some, some looks, uh, and, and I need to wrap this up, but I— we were here for 2.5 and 3 hours, 2.5 to 3 hours at the last Aleutian Peninsula meeting, and I answered every question to the best of my ability, and the Department of Law found that it was not enough.

So I want to make sure that I am here and I am crystal clear on everything that we did. Um, there were hundreds of people in from hundreds of communities that were paying upwards of $1,000 to fly out to the Board of Fisheries meeting, and to have 5 proposals voided on something as innocuous and political as this is just a slap in the face to those communities. Um, I I want to add, and so what I'm going to finish with is I want to ask Eddie from the Department of Law, does the Department of Law have any questions for me or have anything else that they want me to elaborate on further?

Madam Chair, if I may.

Thank you, Mr. Chamberlain, for your comments. My hope is that my response now will help contextualize some of your comments insofar as your actual question. I can't answer whether or not law is still going to be seeking answers from you regarding your ethics disclosures. I want to start by reminding the board and alerting the public to the fact that complaints or issues related to ethics are not vetted by myself as the board's attorney. Rather, the Department of Law is a large department.

I'm part of it, but we have a dedicated ethics attorney and ethics section that has been communicating with you in the wake of certain Area M regulations being invalidated. As such, I cannot answer any ethics-related questions you have, nor is it law's practice necessarily to make an ethics attorney available to discuss an outstanding ethics matter in a public forum like we're in here right now. Notwithstanding that practice, you do have a right, Mr. Chamberlain, to waive any confidentiality privileges associated with ethics matters involving yourself, and you've you elected to do that here this morning. Regarding the issue of whether an advisory opinion that you've sought pursuant to the order of corrective action will be issued, law's position that I've been authorized to relay to you here now is that an advisory opinion cannot be completed because there are still outstanding questions that the Department of Law believes needs to be answered by yourself before that could be issued. You may disagree with that conclusion, but it's a discussion you can have with the ethics attorney, just not here in a public forum.

Further, if the advisory opinion were issued today, LAO would be in the position where they believe that there are unanswered questions that the ethics analysis requires And so if an opinion were to issue, it would essentially have to allude to that fact, or it would just be incomplete or incapable of completing the analysis. Regarding your ability to vote on the Area M ACRs tomorrow, the Department of Law has determined that a member may vote on an ACR at the work session even in the event that the same member would have a conflict with underlying proposal. The member's action on an ACR vote would have an insignificant or conjectural effect on the member's personal or financial interests, and therefore would not run afoul of the Executive Branch Ethics Act.

So, I'll leave it at that. Mr. Chamberlain, again, I appreciate your comments. I do think there's a possibility that based on your questions and communications with the ethics attorney that may be outstanding that based on the disclosure you just made, you might have answered a bunch of those questions. But what I can't say is that I'm not the one kind of controlling that conversation, and you've built a pretty comprehensive record that we should be able to get that ethics opinion out or that advisory opinion out before assuming the ACRs are accepted for Area M. Before that meeting is scheduled. I want to express my frustration on this one because I'm— I've been asking, and as far back as April, I've invited the Department of Law to reach out to me and call me if they have any questions.

And when I did that, they called me and said, well, we voided everything you did, and you— and you— and you violated these ethics acts. And, but we're going to keep it quiet and nobody's going to know about it. So you're not going to, you're not going to face the blame. I've gone through hell this summer. There was a gubernatorial debate where this ethics violation was stated, made as a statement of fact.

I've reached out to the Department of Law 4 times, 3 or 4 times. And I'm in here. I am, I'm asking in a public forum, what do you want me to disclose? I'm here to disclose it. And the answer I'm getting is, well, we can't speak to that.

Mr. Chamberlain, if I may, what I'm trying to relay is that I personally, as the board's line attorney, cannot speak to that. And again, it's the department's practice not to have these conversations out in an open public forum. I understand your frustration, sir. I really do. Is Jesse Alloway listening on this call?

I do not know, Mr. Chamberlain. Okay. Yesterday she said she was going to be available, uh, during this, and then we held up— we held off this discussion until her plane landed in Fairbanks.

Keep it focused. Not a debate between you and law, but to the disclosures. Okay, where— what I want to state is I need a concrete question. I've asked time and again, I've asked in private, I'm asking in public, and for me not to get that question, for everything to be your disclosure is still incomplete. I've written 13 pages here, single-spaced, and I've gone through everything I can think of.

I've researched back 20 years on this. I've asked executives at Chalista, and I still don't have— and I still can't get an answer on whether I've done a sufficient job. I want to know what the standard is for, for someone to go and make a complete ethics disclosure. And I don't think that's unreasonable for someone to do in a public for someone to have to go through a dog and pony show like this. Eddie, you've been absolutely professional.

I, I hold you in the highest regard, and I don't want this to, uh, impugn your integrity because you are one of the most honorable men I know. But when this litigation came about and the lawsuit surrounding REM, my initial thought is that someone who tried 75 cases is, oh, this is cute, but I never thought my biggest adversary in that case would be the party that's holding them out themselves out as my, as my attorney as late as yesterday.

I am extremely frustrated with the Department of Law, and I feel this is absolutely unprofessional. And with that, I'm open to any questions the board has, but I'm, I'm done with law. Thank you, Mr. Chamberlain. So just so that I am clear on sort of what I understand to be the underlying message of the RCs and, and your disclosures, is that essentially there has been no finding of conflict of interest.

There may have been a finding of violation, but there has been no finding of a conflict yet, correct? That is correct. Uh, Eddie, if you have any Nothing to say on that. I'll welcome that as well. Nothing in addition to what Madam Chair stated.

A violation was found, but whether or not that constitutes a conflict of interest is something for the ethics attorney to comment on in further explaining that.

Other questions? Mr. Carpenter. Thank you, um, and thank you, Mr. Chamberlain, for— I mean, I'm not sure how you put that together in the middle of the night, but that's pretty impressive. Um, I guess one thing you said, um, in that very long statement was, is that, um, a lot of the speaking that you have done in public in different forums has, has been of a personal, personal nature, and you've, you've stated that quite eloquently. I guess the one question I do have is that you also stated that prior to doing that, you ran personal comments by the protocol committee, and it's something that I'm unfamiliar with, and so I'm just I'm just curious, is that a general thing that, I mean, shareholders in the Chilista Corporation have to do, or is it just somebody that works for them that has to do it before they engage in public comment?

If you could just maybe address that. Thank you very much, Mr. Carpenter. That's a great question. So the protocol group for Chilista is a group of executives who approve statements made on behalf of Chilista Corporation. The voice of Chilista is not me.

It's the board of directors. The board of directors has a sole employee who's the president and CEO. The president and CEO created a protocol group to approve statements made on behalf of Chalista. Chalista has very strict requirements on what statements can be made on their behalf in public. Generally, those go through the PR— through the public relations group.

Legal has to review them. External Affairs and in any relevant departments. So when there are official Chalista statements, there is a very narrowly tailored statement on that. Now, I've been given liberty to speak on my personal— in my personal capacity on several issues, and I do do that. And as a courtesy to my employer, I say, hey, I've been asked to speak on this.

Take for instance Native America Calling.

I've been asked to speak on this. Does anyone have any grief with that? And that's me running it by, like, am I free to speak in my personal capacity? Now, I don't always say I'm here to speak in my personal capacity, and that's where the Department of Law may find, take difference, but this is how I'm defining it. And, but I have, but I did disclose is to the best of my ability.

And for clarification, all those statements were true, true, correct, and I got— I hope complete to the best of my ability. Um, and so with those, I, I'm trying to lay that framework for, um, for what was done. Um, and so if, if, if you need more clarification, Tom, I'm happy to do that.

Any other board questions? Miss Irwin. Thank you, Madam Chair. Just for clarification, Member Chamberlain, in your first ethics disclosure that's in question at the, uh, Area M meeting in 2025, did you— or 2026— did you knowingly and/or willingly withhold any information that would have supported the ethics determination? No, I have not.

Any other questions? Thank you for your, um, for your very complete disclosure, Mr. Chamberlain. Um, moving on, Member Seere.

My name is Paul Seere, currently reside in Ketchikan, Alaska. I work part-time for Seagrove Kelp and Oyster Company. And I operate a seasonal tour business in Ketchikan. My spouse is a hairstylist in Ketchikan. I have two daughters that both reside outside the state of Alaska.

Neither I or any member of my family holds commercial fishing permits or have any financial investments in fishing interests. My past involvement in fisheries is fishing lodge ownership and management. Board service with Sarah and prior employment in seafood processing. I hold a senior permanent sport fishing and hunting license. My spouse and I received the PFD, and I will receive a stipend for my participation in the Board of Fish.

No member of my family is involved in any lawsuit with the state of Alaska Department of Fish and Game. Or the Board of Fisheries. This information is true and correct and complete to the best of my knowledge. Thank you, Member Seere. Any questions?

Mr. Owen. Thank you, Mr. Seere. You mentioned prior ownership or involvement with fishing lodge and processor. Are— do you have any current involvement or financial interest in either of those? No, I do not.

All right, any other questions? Seeing none, I'll go ahead and put my ethics disclosure on the record as well. My name is Marit Carlson-Van Dort. I was born and raised in Alaska. I currently reside in Anchorage.

I'm employed as the President and Chief Executive Officer of Far West Incorporated, which is the village corporation for Chignik Bay, formed under the Alaska Native Claims Settlement Act. I am also a shareholder in Bristol Bay Native Corporation in Koniag and in Far West. I receive State of Alaska Permanent Fund dividend and I will receive a stipend for my service on this board. I also annually purchase a resident sport fish license. Neither I, members of my immediate family, nor my employer have any financial interest in fisheries.

Similarly, neither I, members of my immediate family, nor my employer are involved with any lawsuits in the State of Alaska, the Alaska Department of Fish and Game, or the Board of Fisheries. And this information is true, correct and complete to the best of my knowledge. Since Member Chamberlain kind of took us down the path about the corrective action, and that's now been our seed, I kind of want to make a couple comments in that space as well. First of all, in the— as related to the corrective action, back in, I don't know when the complaint was initially filed, there were 3 of us. That were named in a complaint, um, and that was myself, Member Irwin, and Member Chamberlain.

On April 24th, 2026, I received a letter dismissing the complaint against me, which I waived confidentiality and made public on May 22nd. Um, to read from it in part, we'll say that the complainant alleges that my determinations misapplied the Ethics Act and therefore constituted a knowing aid to an ethics violation after conducting a preliminary evaluation under 9AAC 52-140, including listening to the audio of the board's ethics disclosures and determinations, we conclude that the allegations, even if true, would not establish a violation of the act.

The—. Further moving on, The Department of Law said the complaint alleged that I violated AS 3952-190 by issuing ethics determinations allowing members Chamberlain and Erwin to participate in deliberations. The complaint asserts that the determinations were contrary to the facts and law and therefore constituted knowingly aiding violations under AS 3952-120 and AS 3952-220. The preliminary review, including listening to the audio of the February 19th disclosures and deliberations does not support those allegations. The record reflects that one, each member was made on, made on the record disclosures consistent with the process described in AS 3952-220 and 9 AAC 52-122.

I was asked, I asked clarifying questions, invited input, and applied the board's established process for reviewing conflicts. Third, I made a determination on the record for each member consistent with my role as a designated ethics supervisor Fourth, I asked the board for objections consistent with AS 3952-220A. Fifth, no objections were made and the determinations became final. There is no evidence that you knowingly disregarded information or intentionally aided a violation. My determinations reflect an application of my understanding of the governing law to the facts disclosed by the board members, not knowing violation of the Ethics Act.

Not a knowing violation of the Ethics Act. So I would just also draw attention to— by law and the public, now that the order of corrective action is made public and I've had an opportunity to read it in full, again, there's made reference to the fact that a false or incomplete disclosure therefore provides no protection and the supervisor's determination is only valid as the facts on which it was based. And I would just like to reflect on what I just read and that the facts on which that was based were disclosed in the proper procedure. I would also take issue, though, with— and I think it was page 3 of 7, mid-page, paragraph 3. The Department of Law writes, although the board chair allowed for discussion on this additional information during the February 23rd meeting, she did not provide the board members with with an opportunity to object to her determination and call for a vote.

That's factually incorrect. After receiving the letter, a member had more questions for Member Chamberlain. I allowed that questioning to happen and additional discussion to occur based on the ethics determination that was made at the beginning of the meeting. And the chair cannot make motions. At that time, no member moved to revisit, no member objected, and there was no reason to call a revote because no member objected or called for a revote.

I just want to make that abundantly clear on the record. Any questions of me?

Okay. I think that concludes ethics. Let's move on, shall we?

And I think with all the paper that I have here, what do we have next on our agenda, Mr. Nelson? Committees. Let's go ahead and take a stand down to— I already do assigning, are we, uh, committee reports? Okay, let's go ahead and do some committee reports. I've got, um, actually a few committees have been meeting as of recently.

Um, I will go through and just down the list and see if there's any reports from the committee chairs.

For the Board of Fisheries, Board of Game, are there any committee reports to relay to the full board?

Thank you, Madam Chair.

Olivia Irwin, I am the chair of the Board of Fisheries, Board of Game, not Stans Array, which is on the agenda. And we have not met as a committee yet. However, we have— I have been in conversations with committee members as well as Director Art Nelson and the Director at the Board of Game, that as this meeting's election season is, is upcoming, there is a possibility of a vacancy in the Commissioner's Office. And the Joint Board is responsible for when a vacancy is open to meet and gather interviews and individuals and applicants and then provide a list, a suggested list, to the Governor's Office. So we have not met yet, and if a vacancy does arise, we will be meeting— whether or not we will be meeting on November 10th as a committee, the 6 of us, to discuss next steps, alternatives, and timelines and procedure on how we as a committee will carry out this effort.

Upon a vacancy arising, we will then schedule additional meeting notices and application openings for folks to apply and set up interviews. So the committee will probably have at least 2, if not maybe 3 meetings, the first of which will most— will be public. I'm looking, hoping to have time for public testimony in that meeting. The portion where we're interviewing folks and having that— those discussions will be private though. The hope is to get a list, if a vacancy arises, a list of recommended candidates to the to the governor's office, um, before the new year, Madam Chair.

Thank you. Thank you. Any questions for Member Owen? Okay, moving on to the Committee on Federal and State Subsistence. Chair Chamberlain, is there anything to report?

Nothing to report, Madam Chair. Moving on to the Habitat Committee. Chair Wood, is there anything to report? Nothing to report, Madam Chair. Thank you.

And moving on to the Hatchery Committee. I'm the chair of that committee. The full board is the is on that committee. There was no Hatchery Committee meeting this last year, nothing to report. Moving on to the Joint Board of Fish and PFMC Protocol, um, Chair Carpenter, is there anything to report?

Thank you, Madam Chair. Yes, uh, the Joint Protocol Committee, um, met on October 16th at the Marriott. There were 5 parts to the agenda. This meeting kind of stemmed from trying to gain knowledge from the federal staff and the council members in regards to some issues that have come before the board recently. Um, parts of the conversation, um, surrounded pelagic trawl fisheries operating in state waters in the Aleutian Islands, Bering Sea, federal fishery management measures that have taken in place to affect the and minimize the adverse effect.

Statutory requirements regarding habitat for assessing impacts of council-managed ground fisheries on habitat. And then we also had a presentation regarding advancements in technology specific to things like sensors and other technical aspects that would be involved in trawling. And then there was also a short conversation on council actions that are underway that could help inform the board if the board were to entertain any of these proposals into the future. So that's, that's a general synopsis. Thank you, Member Carpenter.

Any questions? On the committee. All right, the, um, final committee I believe is the Committee on Board Process Management and Research Needs. I chair that committee. That committee met twice.

The first meeting was on Friday, September 25th, 2026. It included a hand— an agenda that covered a lot of things, sort of miscellaneous things that had been percolating over the course of the last couple years related process primarily, um, issues that the, the department had brought up, other members had brought up, members of the public had brought up. So, um, I think there was a couple of weeks notice, um, uh, for that. And, uh, I think what I heard from the public during the committee and also in their written public comments was that they would appreciate a little bit more context and time in terms of what the discussion items were. So we sort of walked through and talked through and took public comment during the committee, oral public comments during the committee.

It was an informal committee process where it was more conversational, I would think, than anything else, including with members of the public. I appreciated the— very much appreciated the engagement and the comments that we did receive. Based on the comments that they didn't have enough time to form sufficient, uh, written public comments and having addition— requiring or requesting additional context for the agenda items, the committee met again on Wednesday, October 21st, 2026, and, and discussed a handful of things. Um, first of all, on that, um, second committee agenda, we discussed the Department of Law's recommendations for approving board process. Um, I believe that there are going to be some, um, some final— some additional final discussion about, um, a regulatory language approval process, um, with the Department of Law and the board, including sort of timing and policy, um, procedure around what that looks like under the miscellaneous business for this meeting's agenda.

We also discussed remote public testimony at board board meetings. There was a pretty good discussion about this. I think there was a recognition that having just a broad remote public testimony, given the compressed time periods of our meetings, would be problematic since we already seem some— often to be rushed in the deliberative process and also bound by budget, that having a full-blown remote public testimony opportunity might not be reasonable at this time, but we did talk about a potential pathway for ACs and RACs to, um, to provide remote public testimony, um, and TK. And recognizing that particularly the advisory committees are only able to send a member representative to one meeting a year, at least that's what's paid for by the department. It's my understanding, and anybody can correct me if I'm wrong.

So, um, oftentimes I think we would benefit from having, uh, a little bit more AC engagement, and perhaps, um, being able to, um, provide remote testimony for ACs. Racks and TK, um, would be a good thing to be able to, um, engage the ACs more, especially if there's a weather delay, they can't travel, and then they can't be here to represent their, um, their ACs at the regional meeting. So we can discuss that more under miscellaneous business if the full board so chooses. We also again revisited the discussions on, um, the review opportunities for public input at board meetings. So testimony, traditional knowledge, committee of the whole, record copies, um, based on sort of complaints and discussions that I had from various board members, um, of redundancy or repetition in those spaces.

The question was, are there ways to improve meeting efficiency? How does the public utilize and/or value each of the opportunities and mechanisms to communicate directly with the board? Um, I think what I heard at that meeting is that, um, the department and all members of the committee that, um, participated found a lot of value in each of those sort of components of, of a board meeting, um, but that, you know, it, it could get repetitive and that it was really incumbent upon the committee chair to keep things on track.

The issue of substitute language generation also came up in the context of the committee work and the desire for people to have the opportunity to comment on substitute language prior to deliberation. I think that there's a recognition that that's important. Certainly it's been my, um, I, I've tried to make the effort or the, the meetings to remind people to get to work early on substitute language, um, get with board members, get with department staff in order to do that. Um, sometimes that hasn't always worked, even despite rearranging of the agenda, um, to try and accommodate larger pieces substitute language and conversations in that space. I thought there were some, some interesting suggestions brought forth.

Um, I believe Director Nelson, you discussed the potential for each, each proposal kind of goes into a committee of the whole. Maybe the board picks out certain proposals, i.e., drivers that additional discussion would be valuable on. And then I believe there was a member of the public who also thought put forth a really interesting idea of sort of a final committee of the whole for those ones that really are emerging during a board meeting as drivers, which is fairly typical to do sort of a final committee of the whole just to kind of give everybody a last look-see at, um, at any substitute language that has been developed. Nothing is formalized in that space. I'm, I'm, I remain open to suggestions And I would like to think about that, especially as we enter the regulatory meetings of Lower Cook Inlet/Kodiak and Upper Cook Inlet for this cycle.

Let's see.

We also considered that rules be applied to proposal submissions in the future for calls for proposal, and the committee discussed whether to consider a requirement that the board support that the board support provided forms for proposal submission and also considering a page limit on proposal submissions since some of them are pretty lengthy. There's AI-generated stuff that's coming in and it's difficult and time-consuming for board support staff to essentially parse out and try and understand what the intent— what the proposer's intent was on their form. So Um, there was pretty wide, um, agreement amongst the committee and the public, I think, that, um, that that was a reasonable request to support board support for proposal submissions, um, and also to put a reasonable, uh, length on it. I think the, the, the page length was considered between 3 and 5 pages, something along those lines. 3 May be not enough to capture a full, you know, regulation package, if you will, or section.

Um, so perhaps 5, and I think it's my intention to bring that forward, um, so that it can be, um, more formally suggested or adopted by the board, um, during the miscellaneous section of this meeting as well. We also reviewed the 3-year review of traditional knowledge reports and asked the question if there were any changes moving— needed moving forward. I didn't really hear, and anybody on the committee can feel free to jump in, necessarily any requests for how that is operating in terms of procedure. I did hear, and we did hear, that there was a sort of wide recognition and appreciation for the information that's been conveyed or being conveyed to the board under that agenda item. And also, um, I opened up sort of the call for folks to think sort of creatively in the TK space, again understanding that it's difficult often to travel, and if there's potentially, you know, video submissions that the board can consider as long as it's, um, able to be made part of the public record.

So that's part of what was discussed under that agenda item. We also discussed the timing for consideration of hatchery proposed— hatchery production related proposals and Hatchery Committee meetings during the 3-year board cycle. I think there was pretty broad agreement that those large or broad production-related proposals continue to occur at the statewide meeting, finfish meeting, and that a Hatchery Committee meeting would precede it sometime during that cycle. But that more surgical or specific hatchery-related proposals, i.e., related to special harvest areas and terminal harvest areas, things like that, should be considered during the regular sort of regional board cycle. And then we also discussed the timing issues between the board's determinations of stocks of concern and development and adoption of action plans under 5 AAC 39.222.

And, um, There was two parts to that. Number one, consider making the stock of concern designations at the board's work session one year prior to each regular in-cycle meeting in order to allow department staff more time to develop draft action plans and for advisory committee and public input before final action is taken. And also, should the board consider out-of-cycle stock of concern determinations even if this consideration is adopted above? If so, um, how should ACRs— are ACRs appropriate for that? Um, in the discussion with the committee, I think I heard consensus that, and a recognition that sort of our current cycle of how stock of concern designations are brought before the board really doesn't allow the department the time, especially on early meetings, to be— if there are stocks of concern designations, the time to be able to produce a comprehensive action plan for the board to consider at its regular regulatory meeting.

And so I think we're going to be looking to explore how do we change that going forward. Certainly that's not going to be available to us this year, but I think subsequent boards and, and administration should be— continue to be active about how to implement that and make it easier for the department to respond and also easier for the board and the public and the ACs to respond in that space. And I don't know, Commissioner, if you have any comments on that. Yeah, I do. First off, I think these process committee meetings were very useful.

We touched on, like you said, a wide range of subjects, but clearly the stock of concern designation is not working from our perspective. It's like you're going to be defining stocks of concern at this meeting potentially for lower cooking list stocks. And, and you're going to be less than probably 5 weeks from the meeting, and having us come forward with an action plan that nobody has a chance to review prior to that meeting, including the ACs, and have, and have that in the context of the agendas of, of the proposal that you'll be facing, is just not fair to the public. It's not fair to staff. So what we're very supportive of is moving that process forward one year or backwards one year, so you would have that designation at your work session this year for the ones you're taking up the following year.

That would allow us to get an action plan out there in front of the ACs. People be able to see the proposals and merge those things and have, have comments on them. But again, I know that you're going to have to have a little bit more discussion about this, but letting the public know that that's kind of a direction you're going is going to be important as we plan next year's work session. Thank you. And so just to make it clear, The department is not anticipating bringing forth any stock of concern recommendations, determination recommendations for next year's cycle at this meeting, correct?

Not at this meeting. We'll have to have a transition, you know, from next meeting out. And I think we put together a document that we'll be sharing here. Thank you. But again, I want to thank— I think these process meetings have been very good in terms of trying to get a better control of the meeting cycle here so we're not rushed into meetings at the end and taking up those more controversial issues like a different Committee of the Whole might be a very good idea to try to get some more public comment on that.

Thank you. Thank you. And then the second part of that, the Board considering out-of-cycle stock of concern determinations through the agenda change request process, and I think what I heard, at least amongst my members, and I'm going to open it up to them, too, to provide their comments on the committee, is that we did not feel that agenda change requests were the appropriate way to make stock of concern determinations. That really is a department function, and the department has a process and a review process based on our 3-year meeting cycles by which that occurs. And sort of inserting those stock of concern questions through an agenda change request out of cycle is problematic for a variety of reasons and, and isn't appropriate.

So I will go ahead and conclude my report there and open it up to other members of the committee if they want to weigh in. Mr. Wood or Mr. Carpenter? Mr. Carpenter. Thank you. I think that was a good summation.

I thought the meetings were also very good. I think it's probably a good idea to have at least one of those every year. There's always, always things that the board can look to do to innovate the process. I do think that one of the things that came out of that was the idea that, you know, each meeting does have 4 or 5 pretty heavily, I guess, more important or I guess that's not really the correct word, but they're very heavy topics that generate a lot of conversation. There's a lot of public that wants to participate in those Committee of the Wholes.

And so I think it would be an interesting thing to maybe entertain on miscellaneous business to try and figure it out if there's a meeting this year that we might test that case, um, to potentially allow the chair to pick out what they deem maybe 4 or 5 of the most heavily important topics to the public and maybe try and move those towards the end of the meeting so that it does give not only board members the ability to work with the department to create substitute language so that the public— and this is the most important part of this— so that the public has a chance to comment on the substitute language at that final Committee of the Whole to be able to tell the board, yes, we like it, no, we don't. And so I think it would be— I hope it's something that we consider. But thank you for your summation.

Thanks. No, I think it's an interesting concept. I really appreciate the suggestion. I think it was Dan Norman who brought that suggestion forward. And I think it would be interesting to try and test it out again.

I think I think these— the issue of the development of substitute language is frustrated just sometimes by the timing and the amount of time that we have for the meetings. And it's certainly not my intent of chair to arbitrarily or to cut those discussions off on substitute language. It's really a matter of needing to keep the meeting moving. But the other thing that I think that's important in that discussion and how we sort of view that is that if there is substitute language being developed, it also provides— hopefully could provide— the opportunity for an AC chair or an AC representative present at the meeting the ability to confer with their advisory committee to try and see if we can get, you know, input, updated input from the advisory committees on any changes that are— language changes that are being considered by the board. Um, so that isn't to say that what comes out of the committees of the whole would be final.

There's always the deliberative process where amendments could be made and changes could be made, but that's the intent of the board and of the committee, is to try and provide as much opportunity to the public to comment on substitute language as it's being developed at the meetings. All right, I think what we'll do is I will get the, uh the rubric for new committee assignments right now and confer with members on if they have interest in certain committees. And so we'll stand down for a few minutes and then I'll come back on the record and announce the committee assignments. Thanks.

Okay, thanks everyone. The time is 2:33. We're back on the record to, um, just wrap up the committee assignments portion of our agenda. So for the, uh, 2026-2027, um, Board of Fisheries meetings. Chairing the Board of Fisheries, Board of Game Committee will be Member Irwin.

Members will be myself and Member Carpenter. For the Federal-State Subsistence Committee, the chair will be Member Chamberlain. Oops. And, um, standby. Hold on a second.

Maybe I screwed up. Hold on.

Okay, I will go ahead and announce these under miscellaneous business because I think I've got my math a little screwed up here. I want to make sure that we don't have too many people on one committee. Um, so we'll go ahead and take a short break while department sets up for staff reports, and then we'll come back on the record and go through staff reports today. Thank you.

Okay, I think I've sorted myself out, but before we move on to, um, to staff reports, Mr. Wood, I think you had a question or a comment. On the process committee. Yeah, I, I just wanted to add to the process committee's findings. Um, I thought it was appropriate timing to have these process committees to address the structure of how we get information and hear from the public and then put together our language, our, you know, of the existing proposals, especially given the new information we're getting from law about ratifying the decisions that we made throughout the entire year at the end of the year. And I think it really puts the onus on the board to slow down and make sure that the language is in front of the public to be commented on, and the board with very minor additions beyond a certain point, and, um, so that that process is much more deliberative.

That way we all know what is being put into regulation. And I really, really super appreciate that. And also I'd like to say, just for the stock of concern, I think this year is a prime example of the difficulty of dealing with stock of concern for the department and for us making these judgment calls. And so I look forward to seeing how this will work out. Again, more deliberative process.

And I hope we can carry through with that on the criteria for Board of Fish generated proposals, like Board generated proposals and whatnot, so that all of these things have time to be, you know, considered with full respect. And that came out during the process committee meeting. Some people brought that up. We didn't really address it in that process committee meeting. But I just want you to know you were heard and that, you know, making sure that you can comment on the decisions the board is bringing before you is of utmost importance.

So thank you. Thank you. Appreciate your comments, Member Wood. Quick committee announcements. Here we go.

I changed my mind. We're going to do it now before I forget. Okay. On the Board of Fisheries, Board of Game, the chair is Member Irwin. The other members of the committee are myself and Member Carpenter.

On the Federal and State Systems Subsistence Committee, the chair is Member Chamberlain. The other members are Member Seere and Member Hickson. On the Habitat Committee, Member Wood will be the chair. Other members will be Hickson and Member Seere. All of the board members will serve on the Hatchery Committee that I will chair.

On the Joint Board of Fish and PFMC Protocol Committee, uh, Member Carpenter will chair. The other members of the committee will be myself and Member Wood. On the Board Process Management and Research Needs Committee, I will chair. The other members will be Chamberlain and Irwin. And that completes committee assignments.

And we can now move on to staff comments. Mr. Commissioner, just before we get into staff reports, I just want to point out for the board and public some information that RC 04004 is the 2026 Alaska Hatchery moratorium on production levels of pink and chum salmon. I know last year we discussed extending that moratorium. This is an extension for 5 years. I'll let you read it in detail, but it's got a clear signature by nearly all of the P&P hatcheries across the state, with the exception of one Valdez.

But the moratorium applies to all of them that I won't increase production levels beyond that current production levels for another 5 years. So I just wanted to make— I know you're going to talk about ACR tomorrow, but I just wanted to make sure everybody was aware that this is signed and it's in, in place, and that we follow through on our commitment as a department. Thank you. And that's in the RC— you said RC4? RC4.

Perfect. Thank you, Commissioner. All right, you guys have been very patient. We're on pins and needles to hear from you. You're on.

All right, how does that sound?

All right, Madam Chair and members of the board, my name is Kyle Gatt. I am the acting fisheries research coordinator for the Division of Commercial Fisheries in Southcentral Alaska. Joining me today are Nick Dokovich, my counterpart with the Division of Sport Fish, and Birch Foster. Birch is a research coordinator for the Kodiak Management Area for the Division of Commercial Fisheries. At this time, I ask you to please refer to the Lower Cook Inlet escapement goal memo located in RC3.

On page 6 of this memo, you will find a table summarizing the 17 existing escapement goals for Lower Cook Inlet. The table identifies the goal type, the year each goal was adopted, and recent escapement performance relative to the established goal at the time of assessment. Between September 2025 and September 2026, an interdivisional committee reviewed salmon escapement goals in the Lower Cook Inlet management area. These reviews were conducted in accordance with the policy for the management of sustainable, sustainable salmon fisheries and a policy for statewide salmon escapement goals. The committee evaluated whether existing goals should be maintained, revised, or eliminated.

They also considered whether goals should be established for other monitored or exploited salmon stocks. For each stock, the committees considered the appropriate goal type, either biological escapement goal, or BEG, or a sustainable escapement goal, or SEG. The committee has also evaluated the quality and quantity of available data to determine the most appropriate methods for reviewing existing escapement goals and developing new ones. The reviewers focused on goals for which updated data could support a substantial change from the previous recommendation, as well as goals that warranted establishment or elimination. I will now summarize the committee's findings for the Lower Cook Inlet, for the Lower Cook Inlet Management Area, starting with the Anchor River King Salmon.

The current sustainable escapement goal for Anchor River King Salmon is 3,200 to 6,400 fish and was established in 2024. During this review, the committee discussed whether to revise the goal to include only large fish, as defined as king salmon greater than 28 inches in length. The committee determined that large fish goal was not appropriate for this stock, and as a result, the committee found no change to the existing SEG of 3,200 to 6,400 total king salmon. The committee also noted that further analysis is needed to evaluate the incorporate— incorporation of fishery demographic data into escapement goals.

Deep Creek King Salmon. The committee made no change to the existing lower bound SEG of 350 King Salmon, which was adopted in 2017. The committee discussed eliminating the goal because of budgetary limitations and because management actions for the stock are tied to the performance of Anchor River King Salmon under the existing management plan. Ultimately, the committee retained the goal because funding for future aerial surveys may become available.

Nenilchik River King Salmon. The committee made no change to the current SEG of 900 to 1,600 naturally produced King Salmon. This goal was last updated during the 2023-2024 board cycle. For this review, the committee discussed alternative approaches, including establishing a size-based goal and incorporating hatchery-produced fish into the spawning escapement. However, similar to the Anchor River King Salmon, the committee did not support establishing a large fish goal at this time.

The Nanilchik River is an integrated hatchery system in which naturally produced King Salmon are used as broodstock and their progeny are stocked into the river to increase hatchery returns. Returning hatchery-produced fish identified by the absence of an adipose fin are either harvested, culled, used as broodstock for terminal fisheries, or permitted to spawn in the wild with naturally produced fish in accordance with genetic policy guidelines. Currently, hatchery-produced fish that spawn in the wild do not count towards achieving the SEG. The committee determined that more time and analysis are needed to evaluate the implications of including hatchery-origin fish in wild escapement goal and could not recommend a change to the goal at this time.

Anchor River Coho Salmon. For Anchor River Coho Salmon, the committee established a new weir-based SEG of 2,300 to 4,700 fish. This range was developed using the three-tier percentile approach as described by Clark et al., 2014, based on an intermittent time series, time series from 1987 to 2025. The lower and upper bounds correspond approximately to the 15th and 65th percentiles respectively. There are currently no other Coho salmon escapement goals in the Lower Cook Inlet Management Area.

Moving on to chum salmon. Following the 2024 Board of Fisheries cycle, management transitioned from individual escapement goals for 12 chum salmon stocks to 3 aggregate district-wide goals for the Southern, Outer, and Kameshak Districts. This change was intended to provide greater management flexibility and improve stock assessment by reducing uncertainty associated with assigning mixed stock harvests to individual streams. Individual stocks are still monitored, allowing managers to respond to weak escapement in specific streams when necessary. For this review, the committee found no change was warranted to the existing chum salmon aggregate SEGs.

Pink salmon. Similar to chum salmon, following the 2024 border fishery cycle, management transitioned from individual escapement goals for pink salmon stocks to 3 aggregate goals for the Southern, Outer, and Kameshak Districts. For this review, the committee found no change was warranted to the existing pink salmon aggregate SEGs. And finally, sockeye salmon. The committee made no change to the existing SEGs for 8 sockeye salmon stocks.

In summary, the committee reviewed the 17 salmon escapement goals in Lower Cook Inlet Management Area and found no changes those goals. The committee findings were to also establish a new— one new weir-based SEG for Anchor River Coho Salmon, bringing the total number of goals to 18. A written report detailing escapement goal findings and methods will be presented to the board in December 2026. This report will summarize the current and newly established escapement goals for Lower Cook Inlet and provide a detailed description of the methods used to inform those determinations. Madam Chair, members of the board, that concludes my summary of the Lower Cook Inlet Excavatable Review.

Nick and I would be happy to answer any questions you may have. Thank you. Questions from the board? Mr. Carpenter. Thank you.

Um, this is specific to McNeil River. So McNeil River has a designation, but we also have a situation to where there's an aggregate now that applies, and I'm trying to figure out if we're using an aggregate to establish escapement, how would you apply— how would you delist a specific river within the aggregate? Board Member Carpenter, through the chair, within the action plan, it is stipulated that we would continue monitoring the stock and it would be assessed based on its old SEG prior to aggregation. So the delisting criteria specifically is attached to something that we don't use currently for management? Currently there is a management objective which is reflected.

So from— there used to be SEGs, and then when aggregation happened, we still monitor individual stocks with individual management objectives. The delisting criteria is for that specific stock is the same goal from the SEG and the management objective. Okay, thank you. Other questions? Mr. Wood.

Yeah, thank you. Um, with your Coho salmon and establishing a new goal, I appreciate that you're using a weir base on the Anchor River. Is that what you said, weir, or weir and sonar? But remember what the chair— I guess that is correct, it is a weir. Okay, and how— what is your ability to keep that weir in with the way the water is fluctuating?

And, um, how late in the season is it staying in?

Turn it off. Board Member Wood, the ability is enhanced to keep that weir in because we're using a video weir, so like the water can be higher. So the video weir does help, and they did move that weir upstream a little bit to make it more manageable. I wish Homer staff was here, or if anyone else could chime in, but they seem to be able to hold that weir in at its new location, and the video weir's helping to get complete counts. That's great, thank you.

Yeah, I visited that weir this summer, so that's the one you're using, the video weir. That's— that was pretty great to see how that was working and being able to count the fish in the office. So that was— thank you.

I don't see— oh, Member Irwin. Thank you, Madam Chair. Thank you very much for the report. You had mentioned one system that there was consideration for doing a 20, uh, a large fish count, and then it was deemed not appropriate. Could you go into that of when is it appropriate and advantageous for us to include a large fish count in an escapement goal, um, and when is it not?

Uh, board member, through the chair, currently in South Central Alaska, um, large fish goals have typically, typically been adopted on the basis of assessment issues. A prime example of this is the late-run Kenai River king salmon goals. That is an apportionment issue. The department is currently looking into establishing the possibility of establishing large fish goals, which was indicated as including fisheries demographic data into the escapement goals.

Okay, thank you.

I don't see any more questions. Moving on to, I think it's the stock of concern memorandum.

At this time, I will now present the department's recommendations for stock of concern designations for the Lower Cook Inlet Management Area. I will ask that you now refer to page 5 of the Lower Cook Inlet stocks of concern memo, which may be found in RC3. This table lists all stocks evaluated for stock of concern status with exceptions of the aggregate chum and pink salmon escapement goals for which contributing stocks were assessed, assessed individually relative to their respective management objectives. The table also summarizes recent escapement estimates relative to the established goals or management objectives in effect at the time of assessment. Shaded gray cells indicate escapements that did not meet the applicable goal.

Following the 2026 salmon season, the department assessed all 17 salmon stocks with formal escapement goals, along with individual stocks managed under specific management objectives for potential stocks of concern designations. For this review, the staff used the definition of chronic inability within the policy for the management of sustainable salmon fisheries to identify potential stocks of concern. Chronic inability is defined as the continuing or anticipated inability to meet escapement thresholds over a 4 to 5 year period, which is approximately the generation time for most salmon species. The evaluation incorporated input from headquarters, regional, and area staff from both fisheries divisions. There are currently 2 stocks designated as stocks of management concern in the Lower Cook Inlet Management Area, the McNeil River chum salmon and McVic Lake sockeye salmon.

Starting with McNeil River chum salmon. In 2016, the board designated the McNeil River chum salmon run as a stock of management concern. Stock assessment information and management measures were summarized in an action plan developed at the 2016 board meeting. The former SEG range of 24,000 to 48,000 chum salmon was eliminated in 2023 with the adoption of the Kamasak District aggregate escapement goal. Because the stock of concern determination predated the adoption of the aggregate goal, the former SEG range of 24,000 to 48,000 continues to be used as a management target for evaluating the delisting criteria.

The McNeil River chum salmon management target has only been achieved once in the past 5 years and 3 of the last 10 years, despite annual closures to all directed chum salmon commercial fisheries in the McNeil and Paint River subdistricts throughout this period.

To consider delisting this stock, the management target must be met or exceeded in 3 consecutive years and expected to be met in future years, or is met in 3 out of 5 consecutive years and expected to be met in future years. Because the delisting criteria for this stock have not been met and are not expected to be met in the near future, the department recommends continuing the stock of management concern designation for McNeil river chum salmon.

McVic Lake sockeye salmon. McVic Lake sockeye salmon were listed as a stock of management concern in 2023. Stock assessment information and management measures were summarized in an action plan developed at the 2023 board meeting. The current SEG range of 3,400 to 11,000 spawners was established in 2017 using the three-tier percentile approach. McFick Lake sockeye salmon escapement goal has been achieved in 2 of the past 5 years for which reliable escapement estimates are available.

In 2024, the McFick Lake video weir lost power on July 9th for the remainder of the season, resulting in a no count that cannot be used to assess whether the escapement goal was achieved. The preliminary 2026 escapement index of 6,455 fish was within the SEG range but does not represent a complete index, as this number The number represents passage only through July 14th. Passage data from late summer is currently being processed. To consider delisting this stock, the midpoint of the SEG range of 7,200 fish needs to be met or exceeded in 3 consecutive years and expected to be met in future years, or is met in 3 of 5 consecutive years and expected to be met in the future. The department recommends continuation of the stock of management concern designation for McFick Lake sockeye salmon because the delisting criteria for this stock has not been met at this time.

Nenilchik River king salmon. During this review period, the committee identified the Nenilchik River king salmon as a stock of management concern. As previously mentioned, the Nenilchik River king salmon SEG was last revised in 2024, increasing the range from 750 to 1,300 900 to 1,600 naturally produced fish to account for spawning throughout the entire river system. King salmon escapement on the Nailchik River is currently monitored using a video weir at river mile 2, while a second weir at river mile 4.8 is used to collect and hold broodstock for the hatchery program. King salmon are known to spawn between the two weir locations.

The previous goal, which was in place from 2017 to 2023, accounted only for fish passing the upstream upstream broodstock weir and did not include fish spawning downstream of that location between the two weirs. The revised goal reflects the inclusion of spawning throughout the entire river system. The SEG range for Nenilchik River King Salmon was last achieved in 2025, and escapements have been below the lower bound in 4 of the past 5 years. Because the lower bound of the escapement goal has been consistently missed in 4 of the past 5 years, the department recommends designating Nenilchik River King Salmon as a stock of management concern.

In summary, that concludes my summary of the lower Cook Inlet stock of concern. Nick and I are happy to address any questions you may have at this time. Thank you, Mr. Carpenter. Then Miss Irwin. Thank you, um, Mick Vickley.

It's an interesting situation because I'm not sure I've ever seen this before. I possibly have, but is it possible that the escapement could come in 100, 200 below the 7,200 midpoint 5 years in a row and that still wouldn't delist the stock even though it's at the midpoint of the escapement range?

Because the way I read this, the midpoint of the escapement range, 7,200 fish, needs to be met or exceeded for this to be delisted. And I find that that's, that's a very— that's a pretty big threshold to meet, and I'm not sure I've seen that anywhere else around the state. I don't know if there's anybody from the department that could maybe— because I don't think I was on the board when this, this happened, but, um, is there, is there any— is there a reason why that happened? Does anybody know that?

Board member Carpenter, I apologize, I, I wasn't around when the action plan was adopted during the last board meeting.

Um, maybe there's a number of staff member can then assist with that. Mr.

Bowers. Board member Carpenter, I, I, through the chair, I can get back to you with an answer on that.

Well, I'd appreciate that. I'm just more curious than anything. I mean, obviously this is something that's in place already. It's not something that the board needs to take action on necessarily, but I do think it's an unusual circumstance, and I would be curious to know because it seems that's a very high threshold to meet, especially on a very small system like that, especially when we're talking about sockeye salmon specifically. So if you find something out, I would be glad to hear it.

Mr. Bowers, can you shed a little light? Thanks, Madam Chair. So your, your question, Mr. Carpenter, was, uh, why the midpoint rather than lower bound of the range? Um, you know, so, so those— that was the criteria the board selected. Um, and there are other instances where the board has Alaska has had criteria— delisting criteria other than the lower bound of the goal range as, as part of the recovery criteria.

Kenai River is a good example. Um, yeah, so that was— I, I don't recall the specific rationale that went into that, but it, it certainly is a higher bar than lower bound.

Mr. Owen. Thank you, Madam Chair. It seems to me the board or the staff wanted to rebuild the stock. I think that's a great goal to achieve. My question is, um, to the staff: did you use the same methods to reevaluate the Nenilchik River king goal as the Anchor River king goal?

Uh, board members, to the chair, are you referring to For the stock of concern designation or for the escapement goal?

I believe the stock of concern designation, the percentile models approach, and the stock recruitment, or am I getting them confused? Um, so the, the stock of concern designation is in relation to the established escapement goal for that stock. Okay, I'm sorry, my, my question was for the, the change in the escapement goal. Uh, yes, it was still It was, uh, the evaluation was done with a percentile-based approach. Okay, thank you.

Yeah, Mr. Wood. Yeah, thanks. With it, when it comes to the McNeil River chum, was there a reason that, um, with the way you were judging the escapement this year, just in time or ability to see, or the weir, that it, that it came in so much lower this year than past years?

I'm looking at 3,944 in 2026. So you were basically counting them as throughout that period of time, just like you would all the other previous years?

We'll get cozy.

Hello, for the record, Colton Lipka, Cook Inlet Regional Management Coordinator.

Through the chair, Member Wood, so you're asking on survey conditions for McNeil chum just in general, or I mean, because what we saw this year was a low abundance of chum. Survey conditions were difficult, in later summer when we do those surveys. But to my knowledge, um, it's a low number. We don't see many chum. Okay, thanks.

So that was aerial surveys you rely on for those counts? Correct. Okay, thank you.

Miss Irwin. Thank you, through the chair. Um, So my first question is, um, I think I've asked the department this question before, so I apologize, but is there an accepted margin of error for weir counts in general, or is that specific to a specific system or, or weir? And then my second question is, using this percentile approach to shift those escapement goals, what was the purpose of that? Is there additional information that was, that was found, or a new methodology why was that percentile approach applied?

Board member Irwin, uh, Nick Dukovich, Regional Research Coordinator for Sport Fish. Your first question was about weir counts and the margin of error around them. They're our most accurate assessment for sure. We usually count every single fish. There's cases where like fish, say small fish like.

Small king salmon sometimes slip through weir pickets, and you'll see, well, we have an index of the jacks because of that or something like that. For the most part, it's our best, but sometimes when we do an analysis, we do assume an error, and when we do, it's usually low. We usually come up with something like 2% or something like that. So, um, the margin of error on a weir count is normally low, but when we use a video weir, things like that, it's because maybe the water is too cloudy or murky, But even so, we're still trying— our intent is to basically do a census of the escapement with a weir.

And then there was a second part, I think. Yeah, for the record, Kyle Gatt. Was your question referring to the update to the previous goal? Correct. I'm specifically wondering about the Anchor River Kings and why was there the goal— basically, why was the goal updated?

Was there additional information was provided, a new methodology to get a more accurate escapement? Just curious as to why that change occurred.

You got the—. Yeah, sure. Um, Miss Irwin, uh, it was updated, I believe. Was it 2024? Yes.

Yeah, we updated with just the, the time series. When we review these, we look at, um, we update the time series of escapements and then evaluate. And the time series of escapements basically does, it basically kind of sets the goal, because you look at the criteria for what tier of percentiles you're going to choose, and you choose that based on what the criteria is. It's fairly prescriptive. So the goal changed because of that.

Okay, thank you. Another question for you. With respect to chum salmon, And I'm looking primarily at the aggregates here. I'm assuming 2024 is when that— well, I know that that's when that change was made. It's a bit of a mixed bag, it looks like, in terms of performance and being able to meet the escapement goals.

My question is, are you— how are you monitoring? I'm assuming you're using index streams. If so, how many for each of those districts? And I guess they're really, really broad escapement goals, like exceptionally broad escapement goals between 1,500 fish and 10,000. So I'm just kind of curious how you're utilizing that.

And like I said, it's a little concerning just because it seems to be a bit of a mixed bag. And with that broad of an escapement goal range, not being able to hit your targets is concerning.

Yeah, Madam Chair, there are currently 21 index streams used to assess chum salmon performance in Lower Cook Inlet.

And the goals, the management objectives that were derived were based on historical escapement estimates. It was similar to using the percentile-based approach, but it was more, they adapted those methods a little bit to form the aggregate management objectives, and all of this is outlined in the 2023 Excavate McCall report.

Okay, but I guess what I— that's fine and good. It's outlined in the report. I mean, but does the department have any concern about those index streams if you have that broad of— just explain it to me. I mean, pretend I didn't read the report because I didn't.

Um, moving into this, um, with that broad of an escapement goal range and not being able to hit an aggregate goal with that broad of a range using the index streams, and I don't know how many are in each of the aggregate goals, um, that was one of the questions I asked, like, does— and you're not hitting, you know, you're not hitting your, your SEG targets in, in a couple of those pretty by a pretty, pretty good margin. I'm just, I'm curious, what level of concern do you have? How is the department looking at that, considering that it's a relatively new change to how you're assessing? And overall performance of chum salmon in the lower Cook Inlet does not look to be great, especially looking at the McNeil River, which we have the most data in front of us for. So I guess I'm just curious what the department sentiment is on the performance of chum salmon.

Now that we have these aggregate goals, I have long stated my opinions on these aggregate goals. I understand the reason for them, but I don't like them for this reason. They obfuscate information. So I'm curious sort of what your assessment is on how generally how they're performing, given the very limited amount of data that we have. And whether it's appropriate not to be a little bit more vigilant about the chum salmon in the Lower Cook Inlet.

Madam Chair, I'll take that question. So just to be clear, I understand what you're looking at. I'm looking at Table 1 on the stock of concern memo, and in 2026, we met 2 of the 3 aggregate chum goals, and the goal that we did not meet, you know, we missed it by less than 10% of the goal. We were pretty close to meeting that goal. We did not meet the McNeil River goal.

As you pointed out, that is not an aggregate goal, that's a single system goal.

You know, these aggregate goals are working as intended. The monitoring hasn't changed. The goals are sustainable. When I look at this table, it appears to me that we had poor chum returns across Lower Cook Inlet in 2026. You know, each of the 4 stocks had lower escapement relative to 2025.

However, escapement was better in 2026 than it was in 2024. So, I believe the goals are working as intended. They're sustainable. The monitoring hasn't changed. Fishing practices haven't changed, you know, on targeting these stocks.

Aggregate goals are not unusual around the state. They're an accepted tool that we use.

So, no, I get it, and I appreciate where you're coming from. I guess let's take the outer district aggregate goal for an example. Okay, so you made it 2 out of 3 years.

The range of that goal is 17,500 to 235,000 fish. You're nowhere near the midpoint in terms of the performance. You're flirting with the bottom of a huge escapement goal range. And so my question is, given the performances of chum salmon stocks around, you know, I guess, does the department have any concern about kind of what's going on? Because I guess the Kameshak District performed better, but also the range is isn't as wide.

Looking at the Southern District, again, 1,500 to 110,000. You made your escapement goal, aggregate goal, by 1,928 fish in 2024, 8,000 in 2025, and 3,917. So I— it is concerning to me. I don't know if it's, if it's a if it passes the sort of the red face test to think that these stocks are performing well when the aggregate goal is so low or the aggregate, you know, escapement numbers are so low relative to a very wide escapement goal range. Yeah.

And so I want to be clear, I didn't— I wasn't implying that the stocks are performing well. It's obvious to me that we're in a period of low productivity. And keep in mind, these fish that you are seeing counted here in 2024 through 2026 were spawned prior off of escapements that were managed under prior goals. All right. So we, we don't have enough information on returns to really truly evaluate how these goals are working.

I'm— when I said they were working well, I meant from a stock assessment and fishery management perspective. We can measure escapement relative to these goals. We can manage fisheries off of these goals.

And with, with these relatively low escapement numbers, I expect that we manage the fisheries conservatively. Okay, fair. Thank you. Mr. Wood. Yeah, thank you.

So for these, for, for this aggregate, these surveys are aerial surveys Board member Wood, it's a mixture of both ground surveys and aerial surveys. And when you miss something, say by 10%, is that like a day that you flew could have been really murky water, or should you have flown like one more extra day? Like, what, what is the buffer in there? Like, when you say 10%, just give me like you missed a week.

Typically, when an aerial survey goal or when an aerial survey estimate is produced, there is a rating criteria for aerial survey conditions. And if the conditions were poor, then it would likely be that there just would be no estimate for that if we don't have confidence in it. I hope that addresses some of your—. Okay, it does. And when you do these surveys of, like, the Southern District aggregate, you try to do all those surveys of those creaks that day?

Is that—. Over the course of the season, it takes a little while, and it's typically based on the peak of when that run typically hits. And then if survey conditions are poor, they'll come back again and try and aerial do a survey within that same timeframe. Okay, thank you.

Okay, Member Irwin. Yeah, thank you, Madam Chair. Um, so continuing this conversation that, uh, Member Carlson-Van Dort brought up about us kind of just barely meeting that lower end of the escapement goal and feeling like that's good enough, um, my question is the Anchor River king salmon goal was changed, and for the— out of the 6 years prior to the change, it only met the goal 2 times out of 6 years the goal was changed, and then the goal has been met in the last 3 years by very slim margins, I would say. The bottom end of the goal is $32,000, the upper end is $64,000. We're looking at $3,300— I'm sorry, $3,200, $6,400.

We're looking at $3,300, $4,000, and $3,400. Um, does the department have any concerns about this stock? Since there has been quite an inconsistency in its ability to even meet the lower end of the escapement goal. I'll leave it there for now. Yeah, Ms. Irwin, we did not recommend this one as a stock concern listing because it's just like you pointed out, it's making the bottom end of its goal, but you're correct, just barely.

Like I wouldn't hold the Inka River up there as it's doing. My assessment of it is, as far as like the other stocks in Cook Inlet, it's probably doing the best of any of the stocks that we have goals on in Cook Inlet. But it's by no means a shining example of, you know, productivity. It's, it's low. You're absolutely correct about that.

And that's with significant restrictions to fisheries. So, okay, thank you. And I recognize that there's, there's an importance of evaluating these escapement goals and shifting them based on new information that we have, but this is also what continues to lead to shifting baseline syndrome and us not being able to actually see the way in which this run is consistently meeting or not meeting goals because the guidelines are always changing. So I'll leave it at that for now. Yeah, I mean, I think the Anchor River is an interesting example, considering that if that goal hadn't changed, you would be looking at only 4 in 10 years that met the escapement goals.

Um, the only reason I think you would not be more legitimately considering a stock of concern designation is because that goal was changed.

So I'll leave it there and. See if there's any more discussions on the stock of concerns.

Mr. Wood. Thanks. On the Ninilchik River, Four Kings, you said that the— that the wild—. Where was that thing? It was Ninilchik natural 900 to 1600.

You also have a hatchery stock in there as well. Are they, are they doing equally as well or poorly as the natural stock?

Mr. Wood, if my best answer to that question is that the smolt to adult return rates for the hatchery component of that stock are performing similarly to the wild stock. The difference is, is that we have control over the number of smolt that go out, right? So we're stocking a certain number of smolt, but once they go out into the ocean, they're subject to the same, and it's a similar rate of return off of those smolt that is the wild smolt. Is that getting at the question? That's a great explanation.

That was what I was looking for. Thank you.

Member Irwin, if there's no further discussion, Madam Chair, I would move to, um, for the board to accept the department's stock of concern recommendations.

Any second? Thank you. Any additional discussion?

Hearing none, so moved.

Madam Chair, move the board designate the Anchor River Kings as a stock of yield concern.

Second. Board discussion. Miss Irwin. Thank you, Madam Chair. I'll speak to the motion.

I recognize that there is explicit language written in the Sustainable Salmon Fisheries Policy on what stock of concern designations, the criteria for them. 4 Out of 5 of the past years of not meeting escapement goals. However, there is enormous amounts of language and defense within the Sustainable Salmon Policy and within our regulations that demand that we take a conservative and precautionary approach to management during times such as these. I believe this is one of those instances where we need to take a precautionary approach to management. If this stock hadn't had a change in the escapement goal, and I'm not putting any blame onto the department for that, I believe that there's scientific proof as to why you all made that decision.

There was defensible argument, I'm sure. Um, but this is a problem that I see with management of sustainable fisheries within our state, is we have to have a consistent baseline understanding how to compare where we're at now with where we've been. And if this, if the goal had not been changed, then it wouldn't have been met in '24 or in '26 either. And I'm not very comfortable with the slim margin in which it met the goal in '24 or '26. And we're about to go over Cook Inlet stock of concern designations where we're about to list 13, potentially list over 13 Chinook stocks.

The kings are not doing well anywhere in this state, and I think that it's time for us to take a precautionary approach to this. So I'll leave it at that. Can I get a— Madam Chair, Ms. Irwin, could you please restate your motion? I was still writing down action on the previous motion when you made it. Thank you.

Absolutely, Director Nelson. My motion was for the board to adopt Anchor River King Salmon as a stock of yield concern.

Mr. Carpenter. Thank you.

To the department, When you change escapement goals, there's a pretty clear procedure in which you go through. This is something that happens all the time, and I'd like you to state for the record some of the things that you consider when deciding to change an escapement goal. Productivity, ocean survival, is it habitat? Just if you could just touch on that briefly.

Uh, Board Member Carpenter, uh, when we are revising a goal, um, we typically take into account first when the last time that goal had actually been changed. For example, with the percentile-based approach, we try not to change the— change a percentile-based goal very often. It's once in several, several cycles if necessary. And then we also look at what recent production data is available to us. So some years, you'll— newer production data just doesn't really yield anything new.

But then if we are seeing new escapement estimates that have come in that could potentially alter the goal or suggest that there is a change warranted, then we would do that.

If I could follow up, please.

So specific to the Anchor River, what were— what was the main rationale for you changing the escapement goal when you did?

I have that previous recommendation pulled up in front of me if you'd like me to read it to you, Member Carpenter. Okay, this is reading from the 2023 Lower Cook Inlet escapement goal memo for the Anchor River. The committee finds there are a change in the current goal of 3,800 to 7,600 to an SEG of 3,200 to 6,400. The spawner recruit model that was used to develop the current goal was updated using aerial survey data, weir data, age and harvest data. Based on the updated analysis, the current escapement goal range is one of the most conservative High relative to MSY, king goals in the state.

Comparing the 2023 stock parameter estimates to the current goal, the lower bound of the current goal approximates S-MSY and the upper bound approximates S-max. Based on this and the updated optimum yield profiles, the committee finds modifying the current goal to a range of 3,200 to 6,400 improves the probability of maximizing sustained yield.

Thank you, Director Peyton. And I guess I just wanted the department to state that for the record because, you know, at least myself, when I listen to recommendations from the department, especially when it comes to stock of concern designations and changing escapement goals, I mean, that's the department's job to change escapement goals. I mean, you're the scientific body that comes up with this. I'm definitely not the expert on that. I just find in a situation like this where I understand the conversation, and I think the department stated it pretty clearly that, you know, there's a fairly good possibility that if the escamago wasn't changed, that maybe we wouldn't have met it.

But I think that the reasons that the escamago were changed, as Director Payton read from the 2023 report and what the department has said here, I'm not sure right now that that's exactly what we should do. I think we need to listen to the department on this one, and I think that if they felt that after changing the escapement goals, the productivity shift wasn't being met, it wasn't going in a positive direction, I think maybe they would have come to us this meeting with a different, a different question for us to answer. So I'll just leave it at that for now. I'm going to take a step back and, and I'll and take a look at this a little bit more holistically.

'Cause I hadn't really contemplated listing the Anchor River as an SOC until sort of digging into and hearing the conversation that we just had. But let's take a look at what the department is proposing and what you've put forth in terms of escapement goal performance for the entire cycle. And in the Lower Cook Inlet, we've talked about, Deep Creek has essentially no information for the last several years. Prior to that, 2 out of 50% of the time, the escapement goal was not met. We've talked about the Ninilchik River.

It's— I think there's a recommendation to list the Ninilchik River. Looking at Kodiak, the 2 rivers there, the Karlik and the Eyakuluk, at least in terms of Chinook only at this time, performing abysmally. And then to Member Irwin's point, looking at the upper Cook Inlet, we've— the recommendation from the department is to maintain— I don't know, what was that? I just had that page.

There's 13. I can't remember what the recommendation is to roughly maintain the existing stock of concern designation for roughly half of that 13, and then you're recommending stock of concern designation for the rest of them. So I guess my point is, is that if you step back and look at the big picture of king performance in the Cook Inlet, in and around the Cook Inlet, including Kodiak, it doesn't look good. And we can parse out whether 200 fish above the changed lower escapement goal is appropriate for considering listing, the big picture is that they're having problems. And perhaps the board come out of the weeds a little bit and take a look at the big picture that the entire Cook Inlet, the lower Cook Inlet, and Kodiak is not performing well in terms of king escapement goals.

I don't know if the department would disagree with that. I would be all ears if there's a disagreement to that. But my point is, is that I get that the nuts and bolts, the nitty-gritty of the Anchor River might not warrant to the letter of the regulation a delisting, but that's— this board has the opportunity to consider that. And I think that the big picture is not pretty, and that perhaps we should be considering the Anchor River because, you know, if every other stream essentially in the Lower Cook Inlet and Kodiak for Chinook salmon is not performing well, I don't know why it would be, you know, best practices of the— of this board to consider or to think that the Anchor River is. Those are my thoughts on it.

Mr. Wood. All right, thank you. Um, I think a lot of this statewide is the ability to count, and when you are looking at the Anchor River, I see a river that has had a lot of attention to the ability to count. Alaska, and to manage because of the location, the confidence in changing the escapement numbers is based on, like, real numbers over a period of time, and it reflects the population of salmon at this point in time, which I respect. Like, we can't just keep looking back at 2006.

And expect it to be there again tomorrow. So, um, I understand that. I also, having visited the Anchor this year, I watched, you know, seining in the river to count fish and to tag them. I also noticed there was screw traps. So was that for outmigrating Chinook as well this year in the Anchor?

So you're getting a really good picture on how many fish are outmigrating, to your point, on some of these rivers, both the Hatchery and the natural fish are having problems, you know, getting the eggs to survive once they're out. So, um, I totally respect the fact that the department hasn't listed this one and that they are close to the line. And I think it's really good to put into perspective how these— all these different rivers that we're going to look at this year are counted and the area in which they're counting. This is a nice small area. Other areas are the size of West Virginia.

So, but with a lot different water quality. So I'm not inclined to lump it all together. And I also, if the department didn't list the Anchor River, I would support them not listing it right now. Okay, just to correct my previous, I'm looking at the Upper Cook Inlet. Memorandum, and there's 1, 2, 3, 4, 5 king salmon continued listing of existing Upper Cook Inlet stocks of management concern for Chinook, and 1, 2, 3, 4, 5, 6, 7, 8, 8 new listings in the Upper Cook Inlet.

I think that is the, you know, I think that is the broader area in my opinion. Mr. Commissioner? Yes. This is, I think, the struggle we're facing now is with individual stock designations of stocks of concern and where you have a Cook Inlet problem. You know, there's very little we're going to do different for Anchor River than we're going to do for, for the other stocks in that, in that system to try to reduce harvest to get to them.

And, and we're starting to think about this internally. Maybe, maybe the approach is to have a, you know, a Cook Inlet king salmon action plan rather than a a, you know, West Susitna, East Susitna, lower Cook Inlet, Kenai River system, you know, have all these have their own individual, you know, stock concerns because largely the management actions we're going to take are for almost all of those stocks are almost identical in terms of how we're going to control marine harvest, intercept, how we're going to deal with in-river fisheries. They're very similar. So I think We're facing the same struggles as you're facing. And when we take this on an individual stock basis, these kinds of discussions you're having— do you add Anchor River to that list?

You know, there's quality data and those things. I think the department would agree Cook Inlet salmon aren't meeting yield requirements. We don't think they're at risk of extinction, but we certainly aren't meeting yield requirements right now. We'd like to get back to having those stocks provide yield. Thank you, Commissioner.

I think you just I solidified my vote in favor of the designation. Mr. Carpenter and then Mr. Payton. Sorry, Mr. Chamberlain. Thank you. So looking at this, you know, one of the things we've seen over the last 20 or 30 years is a shrinking in king salmon size and poor marine survival.

How have have the department's internal, like, return analysis or recruitment analysis changed as a result of these, or have the department's models changed at all to account for poor marine survival and poor fecundity?

Through the chair, so our data sets of escapement are fairly long-term. So they've gone through different cycles in the oceans and different, different conditions. So we're capturing both the highs and lows. The question is, is do we average those out over time or do we just have periods of time where we're going to change our escapement goals on low productivity versus high productivity? Those are discussions we're having internally.

You're correct. Look what's happened to the Bering Sea is cooled and all of a sudden we're getting chum salmon back into the, into the Yukon River. And it seems to be driven really by those ocean cyclic temperatures that are occurring out there in those oceans. Ocean temperatures. Right now, the ocean's not a good place to be if you're a king salmon.

You got a lot of marine mammals running around out there. You have warm temperatures, which requires the energy demands of king salmon to be larger. And you're probably having a differential prey base. So you're on, you're on an exercise regime, eating a diet food in an ocean that's warmer. That's not just not a good place to be.

And then you potentially get 10 times the marine mammals you had 10 years ago. You're, You're getting eaten out there. So you're coming back younger, you're coming back earlier, and you're— it's just, yeah, it's just not a good place to be. But again, if the temperature changes, you know, like we're seeing in the Bering Sea now, that can change relatively quickly. And we saw king salmon in the Deschutes River early in my career in the 1980s.

King salmon were very low numbers. You know, they've very similar kinds of conditions, but it turned around. So the question is, do we have escapement goals for periods of low ocean productivity and escapement goals for higher levels of ocean productivity, or do we average those out over time to try to provide a yield over that time period?

Mr. Payton. Thank you. I'd like to— the board mentioned a couple times precautionary approach. I'd like to remind the board that there's a board-written management plan for the Anchor River and the Deep Creek, that the 4,800, or roughly the midpoint, is the trigger point to prosecute a fishery, whether catch and release or or, or, you know, harvest. So in this system, the board and the department have already put precaution in place in the management plan where just because the low end is achieved, it doesn't open up.

It—. There is a 4,800 midpoint trigger point to that system. Okay, Mr. Owen. Mr. Payton, um, So does that mean that there was that trigger, that trigger point? When was— I'm sorry, when was that put into— when was that enacted?

Trying to think. I think I was on the board around 2000. Uh, it'd have to be, I guess, maybe 2020 at that Upper Cook Inlet meeting. Okay, so it's never hit that midpoint then, so that management— those actions have never been enacted, correct? I believe this year we opened it up for a few days for catch and release according to the management plan.

This year's count was 30— was 3,431. You just said the midpoint was 4,800. Did they open it? Give me a second on that. Thank you.

Yeah, we're reading through the merchant, so we're order, it did open for a few days to catch and release based on projection of hitting that. Okay, so the projection was— the projection said that it would be over 4,800, so you opened by emergency order, and then the total escapement ended up only being 3,400, which achieved the goal? Yep. Yeah, barely. Okay, thank you.

Um, without anything else, I'll call the question. Question's been called. Any errors or omissions?

Quickly. Seeing none, Director Nelson, please call the roll on the motion.

On the motion to designate Anchor River Chinook salmon as a stock of yield concern, correct? Thank you. Uh, Hickson? Yes. Wood?

No. Chamberlain? Yes. Tom Carpenter? No.

Marit Carlson-Van Dort? Yes. Anna Vanderhoeven? Yes. Irwin?

Yes. Seer? Yes. Motion carries, 5 in favor, 2 against, Madam Chair. Okay, thank you.

Anything else to cover for Lower Cook Inlet? Looks like not. Moving on to Kodiak.

All right, uh, good afternoon, Madam Chair and the members of the board.

I'm Birch Foster, um, the Region 4 Research Coordinator for Commercial Fisheries, and I will be presenting the Kodiak Management Area Eskimo Review Findings and Stock of Concern Recommendations alongside my colleague from Division of Sport Fish, Nick Dukovich, who's been already introduced, and James Jackson, the management coordinator from Kodiak.

Please refer to RC3, the Kodiak Management Area Escapement Goal Memo.

In March 2026, an interdivisional committee reviewed salmon escapement goals in the Kodiak area. These reviews were conducted in accordance with the policy for the management of sustainable fisheries and policy for statewide salmon escapement goals. The reviews focused on stocks for which updated data could support a substantial change from the current escapement goals, as well as goals that warranted establishment or elimination. On page 6, you will find a table summarizing the 21 existing escapement goals in Kodiak Management Area. The table identifies the goal type, the year each goal was adopted, and recent escapement performance relative to the established goal.

I will now summarize the committee findings for the Kodiak Management Area. Based on this review, the department recommends no change to escapement goals for any king, chum, or pink salmon stocks. Updating the Buskin Lake sockeye salmon BEG to a range of 4,000 to 8,500 fish. Updating the Buskin River Coho Salmon SEG to a range of 2,500 to 6,000 fish with a new indexed escapement.

Updating the Passagiac River Coho Salmon lower bound SEG to an SEG range of 1,500 to 4,500 fish when enumerated via aerial drone survey methodology.

And no escapement goals will be added or eliminated. In lieu of reading to you the escapement goal memo in its entirety, I will focus today on the work done by the committee, which includes the goals for Buskin, Sakai, Coho, and Pisagsek River Coho salmon. So for Buskin Lake Sakai salmon, The current BEG range, 5,000 to 8,000, was adopted in 2011, and it was based on a spawn recruit model. Annual escapement of sockeye salmon to Buskin Lake watershed has been counted at a weir since 1985. A spawn recruit analysis was completed in 2026, incorporating brood years 1990 through 2018.

Based on the spawn recruit analysis, estimated spawning escapement for maximum sustained yield is roughly 5,755 fish. Uh, the 10 additional years of data since the goal was implemented indicate a change in stock productivity, and the committee agreed that the goal should be adjusted according to the new analysis from a BEG range of 5,000 to 8,000 to a BEG range of 4,000 to 8,500.

Buskin River Coho Salmon. The current SEG range, 4,700 to 9,600, was adopted in 2020 and previously based on a spawner recruit model that was from 2017. Coho salmon are counted on the Buskin River via a weir. The weir is often inoperable during extended periods of high water. Coho are known to pass over the weir during these high water events, but cannot be enumerated directly.

For this review cycle, the estimation of fish passage during the inoperable periods was more closely examined. Missed fish passage on the Buskin River has been estimated inconsistently during these conditions, and escapement estimates should be considered an index. Further, recent dry warm falls have delayed escapement timing to October, after the weir is removed for the season. During several recent seasons, anecdotal data and short-term observations have suggested strong coho runs during October, while the weir counts in August and September have indicated very poor seasons.

The committee decided to reevaluate the Buskin River Coho Salmon SEG using the percentile approach in more recent years where the estimate is more of an index than a total escapement figure. So the percentile approach was used for the timeframe 2006 to 2025 time, and the majority of the run was— when the majority of the run was estimated due to high water conditions. The committee findings are to modify from an SEG with a goal range of 4,700 to 9,600 to an SEG considered to be an index with a goal range of 2,500 to 6,000 fish.

Passaic Jack River Coho Salmon. The current lower bound SEG, 1,200 fish, was adopted in 2011. It was based on the percentile approach and is counted via foot survey. Pssack Shack River Coho Salmon index counts have been difficult to obtain with foot surveys as accessibility to the watershed can be limited. To more accurately estimate total escapement in the Pssack Shack River, the department began conducting drone surveys in 2017.

A comparison of foot surveys to drone counts have shown that drone estimates are more effective at detecting higher and lower abundances, and thus a transition to a drone-based goal estimated with percentile approach will more accurately reflect escapement and be less prone to habitat changes in the Passaic-Shack watershed and less dependent on weather conditions in attaining accurate estimates. The Passaic-Shack River Coho Salmon Run using drone counts was examined with the percentile approach, um, 2017 to 2025. The committee findings are to change the lower bound SEG of 1,200 fish to an SEG range of 1,500 to 4,500 fish using drone counts for Passaicheck River Coho Salmon. While this is an increase in the number, the old lower bound SEG of 1,200 fish using the foot survey enumerated a small proportion of the run, and the new SEG represents more of the actual run size.

So in summary, the Escapement Goal Committee reviewed 21 escapement goals for the Kodiak Management Area. The committee's findings are to update the Buskin sockeye salmon BEG and the Buskin and Passagiac River coho salmon SEGs. A report containing the details of the escapement goal analyses will be published prior to the January 2027 Kodiak regulatory meeting, and an oral presentation will also be provided. Uh, so, so that's the end of the escapement goal part, and I'll be moving into the stock of concern. Um, if there's any questions, pause and make sure there's any questions on the escapement goals.

Seeing none, please move— go ahead.

All right, uh, Kodiak and management area stocks of concern. At this time, I will now present the department's recommendations for stock, stock of concern designations for the Kodiak Management Area. I will ask that you refer to page 4 of the stock of concern memo, which will be found in RC3. The table lists all stocks evaluated for stock of concern status and also summarizes recent escapement estimates relative to the established goal, established goals in effect at the time of the assessment. The shaded gray cells indicate escapements that did not meet the applicable goal.

Following the 2026 salmon season, the department assessed all 21 stocks with formal escapement goals for the potential of stock of concern designation. There are currently 2 stocks designated as stocks of concern in Kodiak: Eyakulik River and Karlik River king salmon. The department recommends maintaining the stock of management concern designation for both Eyakulik River king salmon and Karlik River king salmon.

No other salmon stocks in the Kodiak Management Area are recommended for stock of concern designation. As you can see on page 4 of the stock of concern memo, each of the stocks for which a listing is being recommended meets the criteria to be listed as a stock of concern under the chronic inability definition within the policy for the management of sustainable fisheries, where chronic inability is defined as the continuing or anticipated inability to meet escapement thresholds over a 4- to 5-year period, which is approximately the generation time of most salmon species. And this was also pointed out in the previous presentation. At the January 2027 Kodiak regulatory meeting, written and oral presentations on stock status for Eyakulik and Karlik River king salmon stocks will be formally presented. That concludes my summary of the Kodiak Management Area stock of concern, and we would be happy to address any questions that you may have at this time.

Thanks. Member Irwin, and then I have a question. Yeah, thank you very much. Through the chair, um, grateful to see the continuation of the, uh, the two Chinook stock of concern designations because those numbers are really poor. Since the— since they were designated a stock of concern, I haven't had a chance, unfortunately, to review any old action plans that were created or any— any— understand any management decisions that have been made prior.

What management actions have you guys been taking since the designation to support this stock's rehabilitation?

For the record, James Jackson, Western Region Management Coordinator. So Karlik was designated as a stock concern in, I believe, 2011. And since then, it's had a variety of different, you know, king salmon conservation measures that have been taken. Lately, at the last meeting, we approved closing the sport fishery on the drainage, closing the subsistence fishery on the drainage. Closing the inner Karlik section until we think that the king salmon or the sockeye salmon escapement goal is going to be exceeded, and non-retention in seine gear in June and July.

But I have to say— oh, right, and also the— that wasn't until this year. Yeah, so after we saw the severe declines in the king salmon stocks in '23 and '24, In '25, by emergency order, we also initiated several other restrictions, one of those being closing inner Karluk, closing outer Karluk until the 15th of July. We also closed the Northwest Kodiak District and the Southwest Afognak section of the Afognak District until the Karluk early-run escapement goal was exceeded. In neither of those years was it ever exceeded, so it was just basically closed. And then we also closed by emergency order the marine sport fishery.

Thank you very much. Um, go ahead, Commissioner. King salmon to raise in the, in the Kodiak Hatchery system as a way to build a restoration program for that. Um, unfortunately, we were able to not collect the desired 25 female king salmon from the river down there, but we got, I think, 5 or 6, or I can't remember what the exact number was, but those have been taken to the hatchery. They've been spawned with, with a multitude of male king salmon.

And hopefully we're going to find out from that whether or not we can successfully rear these fish and, and actually get a restoration program built around it. So we're looking beyond the box of just hatchery now in terms of trying to rebuild these two, the Eyakulik and Karlaik, moving forward. Thanks. So kind of on the hatchery point, but not just the hatchery point, just generally speaking, I mean, I saw a lot of reports this year of just a lot of pinks in the Karluk? And does that have, you know, a deleterious effect on the kings generally and in terms of the habitat and spawning quality and spawning area quality?

I think we've determined one of the primary factors affecting kings in the Karluk is probably temperatures. And if we can remove the impact on freshwater survival of eggs and of of fry before they become small stage by putting them in a hatchery, we're hopefully going to find some success there. But you're right there, maybe with the number of pinks, you know, on the reds, there could be those kinds of competitions. But if those competitions were in fact present, like water temperatures, a hatchery program may alleviate some of those issues. It'll be interesting to see.

But I just want to look— we're very concerned about doing this hatchery program correctly. We want to make sure we're maintaining genetic standards moving forward. We don't want to We don't want this to become the Columbia River down there. We want to keep this thing, you know, wild stocks. But at this point in time, I authorized 5 rather than the desired 25 just to figure out whether we can successfully rear these in the hatchery at this point in time.

Thank you. I'd be really interested in seeing how that performs over time. Member Chamberlain. Thank you, Madam Chair and Commissioner. To the point on hatcheries, looking at other species of fish, one of the things we see is And I want to look at like where these, where these fish are going to be released.

Do we anticipate them mixing with the wild stocks as far as reproduction when they come back? Are they going to be spawning in the same beds? One of the reasons I'm concerned on that is, you know, there are studies with other species showing reduced survival rate of secondary generations, offspring of hatchery fish, I don't know, and I don't have the background on this to know if that transfers over to Chinook. But seeing as I think they're held for significantly longer than Chum and Pink, that difference or genetic difference may be more pronounced in the survival. I don't know.

But focusing on the department's genetics policy, are we going to be allowing those hatchery stocks to mix with wild stocks? And to that end, how are we— what are we doing to protect the genetic diversity of the wild stocks? Well, hopefully next year we'll be more successful at finding king salmon than finding 5 or 6. So this is just a test stage going forward. And I talked a lot to our geneticists.

I think they would much rather have me kill these 5 that we took and not, not spawn them. But from my perspective, we can learn a lot from just raising these and figuring out how we can get a hatchery program built. 100% Of them will be marked at some point in time in the future when these things return. They're going to return over 2 or 3 years because they spend alternate times in the ocean. It's going to be multiple year class.

We'll know whether or not they're, they're on the spawning bed. If we build a weir, we'll be able to take those out of the out of the return if we want. But again, it's one life cycle at this point in time, and best I could tell, one, one life cycle is not going to destroy the genetics in this system. So to me, it was worth the risk of getting these things and learning our experience and getting them handled, figuring out if we can successfully rear them in a hatchery and successfully get them back without having a significant genetic, genetic impact.

Thank you, Commissioner. Yeah, and so I just want a little more elaboration. You know, as you referenced the Columbia River, one of the things we see is, you know, hatcheries turn into the Ozambic, where you're— once you're on it, you're on it. And I want to make sure, you know, we don't run into those problems. And do we plan on going up to 25 next year, or in maintaining that, because what I want to look at is, you know, when you've got a returning stock of, you know, in '24 and '25, you had double-digit returns.

And so 5 salmon returning is, you know, and I think, and I'd have to cycle back through the department's genetics policy, 1.5% statistically significant. So if you're taking 5 fish out of a return of, you know, this last year's 308, so that's a little better, but not a whole lot. How are we making sure— what are we doing to make sure we're not doing long-term damage? I know there's studies showing, you know, there are benefits to short-term hatcheries for restoration purposes, and how are we— what are we doing to isolate ourselves into that that those studies that show that, or align ourselves with those studies that show the beneficial purposes without falling into, you know, having ozembic fish. Yeah, I think you're right on the right track.

I think over time we want to abide by the genetics policy. We do not want to end up in this being a hatchery stock of fish. But at this point in time, the benefit of trying to figure out whether we can even do that kind of a restoration program I wanted to see whether we could do that with 5 fish. Again, I don't see long-term genetic impacts from a single year of that. But over time, if we're successful in rearing these fish and being able to get them to a release stage and we see that survival from these fish come back higher than, than the rate of natural fish, we're going to learn something from that.

And then hopefully we'll, we'll learn from that, applying the genetics policy, getting the minimum numbers that they require moving forward.

Sorry, very quick question. Do we have an anticipated return rate? You know, when you're looking at the Yukon River, you're getting less than 1 per 1,000 or 2 per 1,000. And I know there's science saying you want about 4 per 1,000. Where does the juice become worth the squeeze on this hatchery?

I'm not sure, but I right now, I'm looking for juice at all. So, so just testing this out is worth it, worth the squeeze at this point in time in my eyes.

Mr. Wood. Okay, thank you. So, this plan's been in play for a long time. Carla, Carla Kulik, you've gone everything you can to, to, to, you know, go through the checklist. What's wrong with these rivers?

Is it interception by other fisheries? You've done everything you can to this point to keep that from happening. The fish aren't coming back. Are there fish even straying back? And when you look, and for the first time we're mentioning water temperatures, which I really appreciate.

And is the department doing this water temperature testing? Is DEC doing this testing? Like, I'm just trying to get a sense of like, when there are certain rivers that start not even having fish returning to them, like ones that do when the dams are moved, they stray right back in, right? Because it's a healthy river. If you don't even have that with wild fish, what are the other reasons?

And so what other things are you looking at?

Uh, excuse me, uh, Birch Foster Fishing Game. Through the chair, Mr. Wood, um, yeah, the commissioner pointed out the water temperatures. One of the things, um, that the department is doing, and also outside entities, are monitoring the water on Karlik River, for instance. And, um, we have We have found that specifically to the last 4 years of returns, the 2019 and 2020 July air temperatures, and then resulting in, resulted in very high water temperatures, over 20 degrees Celsius in Karlik River during the spawning time of the kings. And so, And so that's data we're collecting.

Now that, of course, is, you know, it's speculation. But we're pretty sure that that has a major impact on the last 4 years of returns. Water levels are the difference. Yeah, and also during that time period with high water temperatures was low water.

My last question. I appreciate that, and the fact that that's being looked at. And is there history, long-term history, dating back into the dirt of there ever being this kind of fluctuation in the returns of just, say, salmon in the Karlaq or Eyakulik? Yeah, through the chair, Mr. Wood.

So we only have the water temperatures on the Karlaq River back to about 2015. But we also have a data set for Kodiak air temperature that goes back to about 1913. And so we have over 100 years of July air temperatures. And we also saw the highest July air temperatures in Kodiak in 2019 and '20, the highest in the over-100-year data set that we have. So, so we have a pretty good idea that these kind of water temperatures have, have really not, not been present in the Karlik River, at least for the past 100 years.

Thank you.

Mr. Carpenter. Thank you. Look, I give you guys a lot of credit. You guys are trying everything to put these kings in the river, and I appreciate that.

One of the things that I've been thinking about, when you talk about historic water temperature levels and then you got low water combined, you know, from year to year at the same time, when you put a bunch of sockeye or a bunch of pink salmon in the Karlik, before you know the king escapement, and if these fish are really being stressed that much How big of an impact are these big sockeye escapements or big pink salmon escapements having on the— because you're having to manage a certain way to put these kings or try and get these kings in the river, are we having a bunch of dropouts in the river because of the high stress that this, you know, big population of sockeye or pinks are having? And is that like is that having an impact in river before the fish can even make it to the lake?

Um, yeah, Bruce Foster, Fishing Game, through the chair, Mr. Carpenter. Um, so, so the point you bring up is, is a good one because Ayukuluk and Karlik are, are massive watersheds, and it's an ecosystem of large sockeye runs, pink salmon runs, coho runs. And I guess one thing about Karlik in general and Eyakulik is that the kings, they spawn in the main stem of the river, while all the early runs and the late runs for Karlik and Eyakulik, they go up the main stem and they go all the way to the lake and they hang out in the lake and they spawn in tributaries to the lake and they spawn in the Alaska Shoals. So they're not spawning in the same areas.

But that's not true for pink salmon, and I think James wanted to cover something there. Yeah, James Jackson, Western Region Management Coordinator. If you think back, like Birch was saying here, is the kings spawn in August in the mainstem of the river, but that's also where the pink salmon mostly spawn as well. And they usually typically spawn in August, and that's when we get the majority of our pink salmon escapement. And if you think back to 2020, that was one of those years where we had really warm water conditions, really warm air conditions, or air temperatures.

We also had low water, and then we also escaped 3.2 million pinks. And that's not an aerial survey, that's a count past a weir. So it's actually a pretty accurate estimate. And at that point, you start getting into low oxygen conditions. We see that in a lot of other systems.

I think about the Buskin. The Buskin has the same problem. They had the same problem this year when we were trying to get, you know, silvers up the river and there was 230,000 pinks up there. Those coho didn't want to go up there. And so if you're a king salmon in the mainstem of the Karlik River and there's 2 to 3 million pinks and it's really warm out and there's low water, that's not a good, you know, look for the Karlik kings.

Thank you. Quick question for you. In terms of our Kodiak regulatory meeting, are we going to be reviewing the action plans for both the Karluk and the Eyakulik? We will be. Okay, great.

I'd like to switch gears, if we can, to Karluk River early and late-run sockeye salmon. And obviously, my attention was drawn to the performance, I think, of the early run in the last 3 years. And my question is, given all these kind of conditions, that you just described, particularly for the Karluk, do you— and you have a weir there, so you've got good numbers— do you have a model for determining the overlap periods between the early and the late runs?

Madam Chair, I would not say we have a model for Karluk.

They're temporally separated by, by about 2 or 3 weeks, and there's no overlap between the early and late runs. So you have no fish, no sockeye coming into the Karla Bush for a 2-3 week period? Very few. Okay, that's helpful. Lucky you.

Right on. Okay, any other questions? Miss Irwin. Madam Chair, I move the board adopt the department recommendations for Kodiak stock of concern designations.

Second. Any additional board discussions?

Any opposition? Hearing none, I don't think we need a roll call. Thank you. Okay, let's go ahead and move on to Upper Cook Inlet. We're going to push through a little bit.

Good afternoon, my name is Nick Dakovich, the Region 2 Research Coordinator for Sport Fish, and as Kyle mentioned, I'll be presenting the Upper Cook Inlet escapement goal review findings and stock of concern recommendations. First, please refer to the Upper Cook Inlet Escapement Goal memo. On page 6, you'll find a table summarizing the 32 existing escapement goals for Upper Cook Inlet. The table identifies the goal type, the year each goal was adopted, and recent escapement performance relative to the established goal. Based on the department's review of these goals in preparation for this Board of Fisheries cycle, The department recommends no change to escapement goals for any King, Chum, Pink, or Coho salmon stocks.

Updating the Kasilof River sockeye salmon biological escapement goal to a range of 200,000 to 350,000 and discontinuing the Packer Creek sockeye salmon sustainable escapement goal. Additionally, the department extended the review process to consider alternative methods for our integrated hatchery stocks, the Nilchik River and the Lower Cook Inlet Management Area, and Crooked Creek and Upper Cook Inlet. In lieu of reading to you the escapement goal memo in its entirety, I will focus today on the substantive work done by the committee, which includes the goals for Crooked Creek, King Salmon, the Kasilof River, and Packers Creek sockeye salmon.

Crooked Creek King Salmon. The committee recommended no change to the current SEG of 700 to 1,400 natural origin King Salmon based on information available at the time of review. Crooked Creek King Salmon are managed as an integrated hatchery program where hatchery production is integrated with naturally spawning fish and hatchery-origin adults may contribute to spawning escapement as well as provide sport fishing opportunity. Currently, hatchery-produced fish that spawn in the wild do not count towards achieving the SEG. Alternative approaches to developing an escapement goal were discussed, including size-based goals and incorporating hatchery-origin fish contributing to the spawning escapement.

The committee needed more time and analysis on these alternative approaches before recommending any possible change to the goal.

Kasilof River sockeye salmon. The current sonar-based BEG range of 140,000 to 320,000 fish for Kasilof River sockeye salmon was established in 2020. For this review, the committee updated the escapement time series, incorporated brood table production estimates through 2018, and reevaluated escapement and recruitment data used in prior analyses. Model parameter estimates indicate an increase in the escapement that is expected to maximize yield compared to the previous analysis. The committee's findings are to update the Kasilof River sockeye salmon BEG to a range of 200,000 to 350,000 fish.

Packers Creek sockeye salmon. The current SEG of 15,000 to 30,000 for Packers Creek sockeye salmon was established in 2008. Packers Creek sockeye salmon are no longer assessed with no plans to assess in the future. The project lacks funding to coordinate operating the video weir on a consistent basis. The project has experienced chronic technical issues that prevent staff from enumerating the entire run.

The committee's findings are to discontinue the Packers Creek sockeye salmon escapement goal.

In summary, the Escapement Goal Committee reviewed 32 salmon escapement goals for the Upper Cook Inlet Management Area, and the committee's findings are to update the Kasilof River sockeye BEG and discontinue the escapement goal for Packers Creek sockeye. A report containing details of the escapement goal analyses will be published prior to the March 2027 Upper Cook Inlet regulatory meeting, and an oral presentation will also be provided. In addition, stock status reports for the Susitna River and Kenai River king salmon stocks will be presented. With that, I'll pause for any questions on the escapement goal part. Thank you.

Any questions? Seeing none, please continue to the SOC. Okay.

At this time, I'll now present the department's recommendations for stock of concern designations for the Upper Cook Inlet Management Area.

I will ask that you now refer to page 7 of the Stock of Concern memo for Upper Cook Inlet. This table lists all stocks evaluated for Stock of Concern status and also summarizes recent escapement estimates relative to the established goals or management objectives in effect at the time of assessment. Shaded gray cells indicate escapements that did not meet the applicable goal. Following the 2026 season, the department assessed all salmon stocks with formal escapement goals for potential Stock of Concern designations.

There are currently 5 king stocks designated as Stocks of Management Concern in Upper Cook Inlet: Alexander Creek, Ch'uwitna River, East Side Susitna River, Kenai River Late Run, and Theodore River. None of these stocks meet delisting criteria at this time as returns continue to be poor.

The department is recommending 8 additional king stocks be listed as a stock of management concern. Those are Campbell Creek, the Chulitna River with an L, Crooked Creek, Deschka River, Kenai River Early Run, Little Susitna River, Talkeetna River, and the Yetna River. In addition to these king salmon stocks of concern, the department is also recommending that Little Susitna River coho salmon be listed as a stock of management Concern. The weir counts have been below the lower bound of the SEG in 3 of the past 5 years, and continued low returns are anticipated.

As you can see on page 7 of the Stock of Concern memo, each of the stocks for which a listing is being recommended meet the criteria to be listed as a Stock of Concern under the chronic inability definition within the policy for the management of sustainable salmon fisheries, where chronic inability is defined as the continuing or anticipated inability to meet escapement thresholds over a 4- to 5-year period, which is approximately the generation time of most salmon species. That concludes my summary of the Upper Cook Inlet stock of concern. Kyle and I are happy to address any questions you may have at this time.

Thank you. Ms. Irwin. Thank you. I have a couple of questions related to the 2023 escapement goal review. So maybe I'll hold my question for a moment and see if you guys want to pull that up.

It's going to be on page 21, Table 3.

That'd be the 2023.

I think it's the report. Uh, Mr. Aaron, are you referring to the escapement goal report for the 2023 meeting? Review of salmon escapement goals in Upper Cook Inlet 2023. Authors McKinley, Dukovich.

No, Fisheries Manuscript Number 24-01. Thank you. McKinley Erickson, Jack Erickson. Yeah, that's the report. No, be under written reports.

Could you repeat the page please? Page 21, Table 3. It's loading. Okay, while it's loading, I'll go ahead and— and the purpose why I'm bringing that up and asking this question is because there's multiple places within Table 1 of the memo that have no counts or N/A, which differentiates from page 21 of the 2023 review. And so I was just curious about that.

For example, for the Deschutes River Coho Salmon, It provides in the review a number 5,638, and in the memo it has no count for that year.

Am I, am I just confused? I want to make sure that I'm not misreading anything.

Alaska River, yeah, for 20— okay, 2022.

Yeah, I think I got your answer for that question. Um, for the purposes of, um, the tables that we put out for this meeting right now, um, we did not— that was a recent escapement, and that one is listed as— is it footnoted in this table?

Yeah, that, that one was, uh, if it wasn't, it should have been. That's an incomplete count. So for the purposes of making decisions, like if it's a stock of concern or, or something like that, like that, that was— that we determined that that count was— that was incomplete. Okay, I just— that's interesting because other portions of Table 1 in the memo have a B next to them footnote. And if you flip it over, B says incomplete survey.

So I'm just curious as to why there is a number but it's incomplete in the review, and then it's excluded from our view in the memo. For the record, Kyle Gatt, acting research coordinator, South Central. So over the last 2 years, we have been trying to clean up these tables and make it more clear as to how these numbers are actually used. So the big distinction you're going to notice is that NA value versus an NS value, which means no survey. And then, then there was another NA value which historically meant no aerial survey or no assessment.

And so we have been trying to move away from— there's a point to which an escapement estimate may be used to assess whether you met the goal or not. Um, and in that case, we would indicate that it was an incomplete count where that count may be used to determine whether we met the goal or not, but should not be used in order to inform an escamotage update, for example, in the percentile-based approach. Okay, I understand that. And the last thing I want to do is argue right now on record with you, but I do just want to clarify this. In Table 1 of the memo, footnotes B indicate incomplete counts.

In the review, footnote E indicates incomplete counts. You have incomplete counts in Table 1 of the memo, but there are incomplete counts from the 2023 review that you did not carry over into the memo. For example, the Deschka River Coho 2020, 2021, 2022 all had incomplete counts in the review, but there it says no count on the table in the memo. Additionally, on the Little Susitna River for coho, in 2022 you put N/A as if there was no assessment, yet in the 2023 review that number was 3,162 with an incomplete count. I'm just seeing a lot of inconsistencies, and I have no idea how to analyze this data right now because of this.

Yeah, I, I hear you on those, and you know, I take responsibility for some of those. In the context of the stock concerned, the Little Sioux Sydnawear, for example, has been wrought with problems. Like, it was blowing out, like, super early. So sometimes you're making a judgment call, and we have these discussions internally all the time. Like, when do we include a number or not include a number?

So I can see what you're doing by referencing the 2023 report, and I just want to assure you that we're not trying to hide anything or anything like that. It's just that those counts, when you go back and look at them, those, the little susitna weir would blow out like early. We've lost that weir in those years where it was just basically a twisted mass of metal. And those counts are, we don't really know what they were. In contrast to say the 2023 count where we did include that, I know I looked at this one for the purposes of these memos and we were at about 85% of historic run timing at that point.

So for our purposes here, when we're evaluating is a stock of concern against the bottom end of the goal of 9,200, like there's no projection scenario there where you're even getting close. So it's sort of context dependent of what some of the numbers that we did put into this memo. Okay, so for example, Campbell Creek King Salmon in 2021 has a small B next to it. In your memo, which means that it was an incomplete count. However, was that close enough to— that was close enough to the lower end of the escapement range for you, or far enough into the run for you to feel confident in that?

And that's why you kept that incomplete count number in, but not for like Deschutes River Coho?

Yeah, yeah, okay, fair.

Any other discussions Mr. Carpenter. Yeah, thank you.

Um, Little Sioux Coho.

Little Sioux Coho are obviously hard to enumerate.

If the board designates this a stock of concern, you're going to have to come up with an action plan. If they're hard to enumerate, And very rarely does it seem like you can enumerate them very well. How will this stock ever find its way out of this designation if the enumeration process is so poor? Uh, Mr. Carpenter, I think I need to clarify something. Um, we did move that weir to a new location last year, and we moved it upstream, which is let's see, roughly 4 or 5 miles upstream of the other, of the old location.

And we're hopeful that those problems are going to go away. It's much shallower and it has withstood some really high water so far. So fingers crossed we've fixed that problem. We've invested in it and we've moved that weir. So I'm hopeful that we will get complete counts more often going forward.

Well, I mean, that's good to hear. I mean, hopefully that does work because this has kind of been a problem for a long time. And I guess, so my question is, what'd you say, 6.5 miles, I think is about what you moved it. How much spawning habitat is below that or that are not going to be counted? What percentage of the overall run?

We don't know that exactly, but most of the spawning occurs even above the Parks Highway Bridge. In fact, we used to count them there. Up, up that high. So it, um, we think that most of the spawning occurs, um, much further up in the drainage, but we do concede that there might be some small amount of spawning between the two weir locations, and we don't really have a good handle on that. But it is our opinion that the majority of spawning happens well above both weir sites.

Okay, and then I had a question on, if I can, Madam Chair, on the Chilitna On the king salmon designation, that's a pretty turbid type system. I'm assuming that you're using— I'm not sure exactly how much of that system where the spawning occurs can you actually get a decent count on. Yeah, I could get you the information based on past radio tagging studies, like how what the percentage is, possibly, if we had enough tags going up there to parse that out. I can't tell you that off the top of my head right now, but I'd be happy to get that to you. But we only count the clear sections of there.

So there's some clear sections, I think it's of the East Fork, where we count. So I would consider the Chulitna aerial index count here is an index of the entire system, but it's been consistently counted that way in the same stretch of river since 1990. 1979. So basically what you're saying is, is that the portion of the Chilitna, the East Fork I believe is what you said, that's clear enough to do an aerial survey is a fair representation of what you think the overall index is? Yeah, and consistent one.

So, okay, thanks.

Um, I guess just kind of to build on the two previous members' questions. You know, I'm looking at Table 1 in the memo, and there's more hashtags on this table than I usually see in terms of dashes where there isn't information available to us.

Um, unless I'm— unless these are different goals I'm looking at this, but either way, the point being is that Given the trouble that the department has had with enumeration in the Susitna area and the wide sort of swath of stock of concern designation that the department is recommending How does the department propose to get at more consistent or better numbers or enumerations across the salmon species in the Susitna?

What is, what is, what is the issue? Is it a lack of budget? Because, you know, the other issue is that this is where a large center of the state's population resides. So, I don't know if it's an allocation of budgetary resources. I don't know what the issue is, but I'm curious what that is because it's going to become really important part of the conversation moving forward, especially in terms of getting these stock of concerns out of these designations.

Uh, Madam Chair, just in regard to your comment about the um, the dash marks. So you'll notice that for many of these stocks there are two lines. I get it, I see what—. So you—. Different goals.

If you shift those so that the lines with numbers align, it's, it's a goal change. So that, that's why you see the dashes. Yeah, that's fair. I got that, Commissioner. So the second question is a larger question.

What are we going to do about Coho and Cook Inlet?

It's challenging to measure coho. It just truly is. They come in in the fall, they come in over an extended period of time. We talk about it a lot internally. Are we going to invest?

Where are we going to invest our resources? Little Sioux has always been one of the places we count northern Cook Inlet, but that river just flash floods and it's just a bear to count. We're trying a new site upriver on the Deshka you know, is inconsistent at best. It's just hard to hold a weir in that site and get an accurate count. Other places we have coho assessments, we do kotowara tagging of juveniles, we look at full returns in the Taku River, for instance, but that's millions of dollars, you know, to try to get that program.

And keeping the sonar in the Kenai River is not gonna, it's kind of a, you know, how much longer you're gonna extend it and what proportion of the count you're counting. It's not because we're not thinking about it, not because we're not trying. And believe me, if we can figure out a way to do it better and we can do it in a way, we'll probably go to the legislature and ask for some money for it. But right now we just don't have the right tool in the toolbox right now to get an accurate count on that rear. And we're trying to look at the current index streams, but I can tell you I'm not confident that the DESCA is going to ever give us a consistent count moving forward in time.

So, but the Little Sioux is our best probability we're moving that site. Yeah, I mean, I guess this is just my opportunity to kind of talk about it a little bit because it's frustrating and I'm sure it's frustrating for you guys as well. And I appreciate where you're coming from with the challenges and I hope that sometime in the relatively near future we can come up with the tool or a better tool because, you know, Upper Cook Inlet has historically been, you know, the source of a lot of allocation fights. And I don't see that changing, especially given the stock of concern designations. And there has to be a real concerted effort to get the board and the public and the department better numbers to, you know, continue to either justify the continued listing or the delisting, and certainly I mean, hopefully the question marks that plague this, the Upper Cook Inlet.

I'll just leave it at that. Yeah. And we were concerned enough about coho just in general this year and our inability to count Northern District coho. And we understood the board's concerns about that from the, you know, the proposal that never got approved by law this last year. So We basically implemented that structure largely to try to pass more coals through the Central District to get them north this year.

So we're taking action to try to, try to address that in the absence of real scientific information. But we're concerned enough that we're taking those steps and precautionarily putting them in place. Well, thank you. And I know it's expensive and that's a big problem. And but again, Um, looking at sort of the population densities and, and whatnot, um, I hope that the department is able to bring forth a budget that reflects the need.

Mr. Owen. Oh, Mr. Wood. All right, I'll try to be succinct with some of my questions. Um, I I wanted to start with Little Sioux. Um, it is the cornerstone of management is escapement.

So what is your confidence in the numbers that you have for the escapement in the Little Sioux over the— over the— this— over history, before moving the weir, after moving the weir, with all the blowouts, dot dot dot? What is your confidence that these numbers that you're generating are worth, you know, dedicating a stock of concern?

I'll take a stab at that, Mr. Wood, through the chair. I think Miss Irwin's question kind of got to, got to it a little bit. I spent some time poring over all the run timing data and looking at the weir counts, daily counts, and calculating how complete the counts were and should we include them or not. Because when we come up with a, um, when we, when we count a fish run, there's like, it's always context dependent, right? Like, you could enumerate an escapement and you could be an incomplete count, and you could count, um, only half of the run, like up to the midpoint, but you made the bottom end of your goal.

So for a management perspective, that's one thing, right? So that's that's a context of the number. So you might want to say, yeah, we met the escapement goal and we justified some management actions on it. In this case, we want to say, did we meet the goal or not? And because we lost the weir, say, in 2022 so early, in the context of that question, I wouldn't have any confidence in using that data.

So we removed it, right? And in 2023, we took a careful look at it and I said, you know what, we were 85% of the way there. I'll use that one as an example. Alaska, for example, we counted 3,500 fish by 85th historic percent of the run, which is tricky with coho because the run timing fluctuates so much. But then you'd like look at all the projection scenarios and say, well, would we have made 9,200?

And none of them— we would have had to seen the unpredictable would have had to have happened, right? We would have had to have seen 6,000 fish come through in September or something like that, which we've never seen.

So I feel that the information that we've given you to make decisions on stock of concern designation have been carefully vetted. Okay. And as far as our confidence going forward, I think we got at it with the weir. Like, I have better— I'm hopeful that we're going to have better numbers going forward on Little Sioux. Okay.

I trust you and I understand the difficulty. Are you going to use this number and extrapolate the Little Sioux to the rest of the Matsu Valley?

No. Okay. I would not recommend doing that. That's, coming up with coho index streams is really tough because they tend to not track with each other and abundance, annual abundance year to year fluctuates too much between systems. Okay, I thank you.

Um, a coho stock of concern is unprecedented in the state. This will be the first, and, um, especially on the Little Sioux, those numbers have to add up to make sure that this is justified to do this in this place for the first time, because it's a political wedge from the E.Z. Through the Northern District right up into the sport fishery. And so I just, I support it, but the numbers have got to justify it, and I, I believe they probably do.

Um, I, the, I think there's a lot of other factors environmentally rather than just allocation bleeding into Little Sioux, and I hope in the action plan and all that, that's addressed. Because it's just not interception. We know this, and I think the plan has to reflect that and, um, and a way out of this. And, and even if that means trying to figure out how to measure, like, spend the money to measure the numbers better, or whatever it is, because that little Sioux comes out of Hatcher Pass, you know, it drains everybody's backyard now. And God knows we know the issues that are happening in the Mat-Su with water quality and all that stuff.

Okay, okay, that's on Little Sioux. The other ones, the king salmon ones in the Susitna River, I've— we've always, you know, I've always had a problem with using Deshka as a kind of the stream to designate all the rest of it on because it just is a groundwater-fed swampy iron river that's hotter hell now. Okay, it does not reflect the rest of the, the Alaska Range drainage rivers, which now the Yentna, the Chulitna, and the Talkeetna River you're adding to this. And it begs my question, why didn't you add the Susitna River all the way up to and beyond Devil's Canyon to encompass Indian River, Portage Creek? Because 'Cause God knows that those are very well-producing rivers too, and I see it.

And so I just, so I'm asking that question. The other thing is, is the index streams on the Chilitna, if you're just looking at the Middle Fork and the East Fork, that's, whoa, dude. I mean, this, yes. I mean, this is an area the size of West Virginia. On the Talkeetna River, it used to at least be Prairie Creek.

But these rivers are flooded as cray— as wicked now. And the ability to even see the old clear water streams are super difficult. And the enumeration you're giving us is aerial surveys.

How are you going to reflect this in an action plan?

That's tough. I mean, I— the— to the Chulitna point, I mean, you're right that if we were to try to enumerate the entire Chulitna River, like, I'm not sure how we would do it, like a wheel-to-wheel mark recapture or something like that. Those cost— a wheel-to-wheel mark recapture on rivers that big are well over $500,000 a year, right? My best answer to that is that we've been flying those surveys at least consistently for what they're worth, and they're just an index, and We try to be very careful about when we include those too. How was, what were the counting conditions like?

If they weren't poor, if they were poor, we throw it out. And it is just a small subset. I think I misspoke. I think you're right. I think it is the Middle Fork.

I think I misspoke and said the East Fork, but the index area is the same, right? And it's a small component of it. The argument would be the same for, like, we didn't discuss it, what we're proposing on that we're going to do on Coho in Kodiak, right, is that we're, because of changing environmental conditions and changing runtime, we can't assess the whole run, so we're only taking a snapshot of it.

My argument would be that that's better than doing nothing at all on the Chulitna. And as far as the streams above that, Indian Portage and that, I think were you asking in terms of like stock of concern, why those aren't listed? I mean, the stock of concern criteria is we do that on stocks with escapement goals, right? It's relative to goals. We don't have escapement goals on those stocks.

So we fly them once in a while, but it's not a consistent assessment. Okay. I support it all. Okay. I get it.

But we just came out of a stock of concern for Sockeye. That we were in forever. And the department has managed this like super conservatively since then, and I appreciate that. But you just look upriver, like what you're seeing in terms of coho in the Little Sioux compared to the rest of the river, it varies greatly.

And being at the mouth of the Sioux in June and July and being upriver the rest of my life, You see it.

And it is not reflected in these escapement numbers for the whole Susitna River drainage for coho. Okay? Where I fish in the, whatever. So the only last thing I want to say, Theodore River, 500 is your low point. There's more seals at the mouth of this than there are the lower end of escapement for Theodore River.

I know you can't manage federal wildlife, but it's a gauntlet. So good luck with the Theodore.

Mr. Owen. Madam Chair, I move the board adopt the department's recommendations for stock of concern designations for the Upper Cook Inlet. I second that and ask for unanimous consent.

Hearing no objections, so moved. Thank you, guys. Appreciate it. We made it through the staff reports and presentations. Mr. Commissioner, I just, I just want to thank staff.

I attend these meetings and the amount of work that goes into these presentations in terms of over a year to get you to this point of the escapement goal review and the stock concern, it's a lot of work and these guys need to be congratulated on the amount of work. So I want to thank them on the record. Thank you. I mean, they're very clearly well informed and appreciate it.

Okay, I'd like to push through and see if we can't get through the NPFMC update and the FSB update. I hope everybody's bladders are doing okay. So we'll go ahead and invite you to the table, Carla.

Karla, I, I, we have, um, we, I believe we have your report, and so I don't know if it's your intent to read us the report. Okay, good.

Okay, perfect. Whenever you're ready. Okay, thank you. Um, yeah, for the record, my name is Karla Bush. I'm I guess you got—.

You got slides.

Oh, I guess we'll stand by for your slides to get loaded. It was there and then it wasn't.

All right, I think we're ready. Go ahead, please. Yes, for the record, my name is Karla Bush. I'm the Extended Jurisdiction Program Manager with the Division of Commercial Fisheries. There is a copy of my written report in your binders under RC3, and I think we're working on getting the written one posted for the public.

So Beginning. Just an overview slide here. I'm going to provide an update on Bering Sea Aleutian Islands crab, Gulf of Alaska Tanner crab protections, pelagic trawl gear performance standard, salmon bycatch, herring bycatch, and then go over a new terminology that's being used in the council that may impact some of our Pacific cod in other states. GHL fisheries. Beginning with Bering Sea Aleutian Islands crab.

So the fishery management plan for Bering Sea king and Tanner crab establishes a cooperative state-federal management structure that delegates most of the management to the state. This year, the council established annual harvest specifications for Bristol Bay red king crab, Bering Sea Tanner crab, Bering Sea snow crab, Aleutian Islands golden king crab, and Norton Sound red king crab. Crab. There are a few other smaller stocks that we set harvest specifications for, but these are the, the 5 main ones that we do annually. The federal harvest specification includes setting an overfishing limit, or an OFL, and an acceptable biological catch limit, also known as the ABC.

The department decides whether or not the fisheries can open based on our state harvest strategies. Developed by the board, and the department sets a total allowable catch, or TAC, for the open fisheries so that all removals remain below that upper limit, which is the, the ABC. We don't want to go over that, and that prevents us from going over an OFL.

This map here shows the bottom temperature maps from the annual NOAA Fisheries Bottom Trawl Survey. I'm showing it here because bottom water temperature is an important oceanographic feature that's, that's measured on the annual NOAA Bottom Trawls Survey. And what they're measuring here is the cold pool, which is an area where the bottom temperatures are less than or equal to 2 degrees, shown in shades of blue on these maps here. The cold pool is formed when the sea ice melts, and it creates a dense, cold ocean water that sinks to the bottom. And the cold pool is important because the location of it and how far it extends into the Bering Sea has positive correlations for crab.

It creates a barrier for Arctic— well, it's good for Arctic species like snow crab and acts as a thermal barrier that protects juvenile and adult crab from some of the major groundfish predators like Pacific cod and pollock. So this year on the survey, they saw the largest cold pool that they have in the past 5 years with the most eastern extent of the cold pool since 2012. So it's a good indication when it comes to crab. Karla, can I have you pause for just a second while we catch up and make sure that your slides are available online for the public to see? I'm so sorry.

That's okay.

You're good to go. Okay. All right. Thank you.

Thank you. Go ahead, Karla. It's not advancing.

I was using these and it wasn't advancing.

I can use that. Yep. Okay. Yeah, so do this. You grab your mouse too if you need it.

It's not advancing.

Okay, all right, we got it. Free zoom in here. This graph here shows Bristol Bay red king crab survey abundance by size and sex. We have males on the left and females on the right, starting with 1979 at the bottom, and so those top rows are where we are in the current time period. So the estimated mature male and female abundances remain near historic lows for Bristol Bay red king crab, though we have seen some positive trends since 2021.

The bottom line here is for 2026, the estimated mature female abundance and effective spawning biomass are both above the thresholds in the state harvest strategy, and the department announced a TAC of 3.41 million pounds for this coming season, which is a 27% increase from the previous year. Bering Sea tanner crab, here we have males on the east, males east of 166 degrees west longitude on the left, and males west of 166 degrees longitude on the right there.

And, and that's because we manage Tanner crab separately east and west of that line. In the survey this past summer, the abundance of large male Tanner crab, so those above 125 5mm carapace width increased 205% from the previous year's survey in the east and increased 230% in the west. And that was the highest level observed in the time series in the western area. Mature female abundance decreased slightly in the western area and increased a little bit in the eastern area. The department announced a tag of 4.9 million pounds in the east area.

And 27.2 million pounds in the western area for this coming season. That combined tag of 32.1 million pounds is 185% increase from the previous season.

Moving now to snow crab. Here we have males on the left, females on the right. Following the collapse of the snow crab stock in 2020, National Marine Fisheries Service determined the stock was an overfished Alaska was in an overfished status and implemented the council's recommended rebuilding plan in 2023. As you know, the fishery was closed for the 2022-23 and 2023-24 seasons and has since opened at a reduced scale. The current stock is estimated to be at 75% of the biomass at maximum sustained yield, so it's no longer in an overfished condition.

It's considered overfished if its biomass is less than half of MSY. So we're at 75%. However, it's not considered fully rebuilt until the biomass is at or above that, that MSY biomass. The survey this summer showed that over 96% of the males that were mature were smaller than the industry preferred size, which is 4 inches, equivalent to 101 mm. And based on the results of the survey, the estimated spawning biomass is above the thresholds in the state harvest strategy, and the tag— attack was announced of 5.1 million pounds, which is a 45% decrease from the previous season.

And this map here shows the abundance of Tanner, Snow, and hybrid crab. Snow and Tanner crab can can mate and create hybrids. The graph here shows the proportion, or the relative abundance, of Tanner crab in the east in dark green, Tanner crab in the west in light green, true snow crab in yellow, and then these hybrid crab in kind of an orangey color. And the hybrid crab continue to be present in high abundances, and while most size and sex categories of hybrids decreased from 2025, the industry preferred males, so 4 inches or greater, were observed at a time series high. Most hybrid crab are considered snow crab by regulation, but neither the snow crab nor Tanner crab stock assessments account for those hybrids.

The graph here I already went over. The council has encouraged— has continued to encourage collaboration between researchers, managers, harvesters, and processors to identify opportunities for increased hybrid crab harvest without negative impacts to snow or Tanner crab stocks. And as a conservation measure this season, the department announced that vessels targeting Tanner crab can retain incidentally caught snow crab, IFQ or CDQ, up to 100% of the weight of Tanner crab on board. So while they're Tanner crab fishing, if they come across any snow crab or snow crab hybrids, they can fully retain those as long as they have the IFQ or CDQ to cover those. Any questions on Bering Sea crab?

I'll just keep going, and if there are questions, you can stop me. I'm going to move now to Gulf of Alaska Tanner crab protection measures. This is an issue that the council has been working on for a few years now. The map here shows the location of crab protection areas that are closed to non-pelagic trawl around Kodiak Island. And the council is currently considering options to establish a new fixed area closure for groundfish fisheries off the east side of Kodiak to protect Tanner crab in the area of Barnabus Gully, which is sort of on the southeastern side of Kodiak there.

The Barnabus Gully is an area of high productivity for many groundfish species. And it has consistently contained a high proportion of the total estimated Tanner crab abundance in the Kodiak, in the Kodiak District. The council is also considering revisions to the existing crab closure areas, notably the Type 3 areas, which are shown in solid blue on this map, and the Marmot Flats area, which is a Type 1 closure in the light blue hatched area on the northeast side of Kodiak. Most of the existing crab closure areas were implemented in the late 1980s to protect red king crab. The Type I closures are year-round, the Type II are seasonal closures, and the Type III are recruitment event closures that are triggered when there is a substantial increase in female red king crab.

None of those Type III closures have been triggered since they were implemented. The Marmot Bay Tanner crab protection area, which you can see just out on the northeast there, sort of in an orange color, was established as a non-pelagic trawl gear closure in 2014. So these maps here provide more detail on the areas under consideration for the current action. On the left is the Barnabas Gully area on the east side of Kodiak. The black line indicates the 3-mile state water zone that is closed to bottom trawling.

The area in pink kind of just outside of state waters there, is a Type II closure. So it's seasonally closed from February 15th to June 15th. And there are 3 options for a new Tanner crab protection area. The first one is the outlines of one of the statistical areas. It's outlined in blue there.

Option 2 is an area that encompasses the northern part of Barnabas Gully and is outlined in on that map in gray. And then Option 3, which is outlined in orange, is a further refinement of Option 2 and includes areas of high Tanner crab densities but excludes areas that are important to flatfish fisheries where fewer Tanner crab are found. Uh, the Council is also exploring options for, uh, the new closure to be either year-round or seasonal, uh, when Tanner crab are molting and mating and when they are most most vulnerable to interactions with fishing gear. The map on the right here shows a portion of the existing crab closure areas near the city of Kodiak, and for the existing closures, the council is considering modifying the Marmot Flats area by reopening the eastern portion. So the areas sort of in the east outlined in purple, um, surveys indicate that there are very few Tanner or red king crab found in the Marmot Flats area.

And the portion that would remain closed is that portion adjacent to state waters, which we understand is important to maintain migration pathways for crab from the inshore bays.

Moving next to pelagic trawl gear performance standard. In June this year, the council requested a discussion paper to assess viable and enforceable regulatory mechanisms to reduce bottom contact of pelagic trawl gear in areas that are currently closed to non-pelagic trawl gear or bottom gear in the Bering Sea, Aleutian Islands, and Gulf of Alaska. The purpose of this action is to reduce the uncertainty associated with unobserved crab mortality and to continually improve upon existing fishing practices in light of depressed red king crab populations and changing ecosystem conditions. Information that was requested in the discussion paper will be used to support potential development of new management measures to reduce bottom contact by pelagic trawl. These options include whether a maximum bottom contact rate based on the best available information is feasible and whether we can regulate that at the vessel, the sector, or even the cooperative level.

The feasibility of implementing an area swept limit at either a vessel, sector, or cooperative level and whether there are verifiable pelagic trawl gear modifications, new technologies, or operational standards that should be considered. The council reaffirmed, um, that the fishing effects model be updated with refined bottom contact estimates. The peer-reviewed fishing effects model estimates the impact of pelagic trawl gear on the seafloor and is used by the council to assess the effects of fishing on essential fish habitats in Alaska. Results from the most recent EFH 5-year review concluded that habitat disturbances within core EFH, Essential Fish Habitat areas, for the managed crab and groundfish species is not affecting any stock in ways that are more than minimal or temporary. The cumulative effects of fishing are estimated to impact less than 5% of the total EFH in the Bering Sea, Aleutian Islands, and Gulf of Alaska for all gear types.

However, uncertainty exists regarding the impacts of unobserved crab mortality due to gear interactions, and research on this issue has been limited. So the council's also requesting— the Bering Sea has also requested that the Bering Sea pollock fleet continue to develop discrete area closures, and an example of that is shown in the map on the right here. This is in an area in the Red King Crab Savings Area, which is an area mostly closed to non-pelagic trawl gear. Just the bottom strip there in, in green on the map, that area is open to non-pelagic trawl gear in years when there's a red king crab fishery. But if the red king crab fishery is closed, the whole area, including that bottom strip, are closed to non-pelagic trawl.

So the council's asked the, the Pollock fleet to develop some in-season closures of this area. These voluntary closure areas were first enacted this A season, so January, February, March. The map here shows the portion of the Red King Crab Savings Area that was closed to the inshore and mothership sectors. A very similar area closure was established by the Ketcher Processor. Sector.

So the council anticipates that the pollock fleet will continue to use available survey and fisheries information to identify and avoid fishing in areas where Bristol Bay king crab are likely to occur while still maintaining the highest priority on Chinook salmon avoidance.

Salmon bycatch. The council's taken several actions to minimize Chinook and chum salmon bycatch in the federal groundfish fisheries. Chinook salmon bycatch is limited by hard caps in both the Bering Sea and Aleutian Islands and Gulf of Alaska, and if a sector reaches their salmon bycatch limit, the fishery is subject to the limit is closed. Additionally, federal regulations require the Bering Sea pollock fishery to operate under avoidance plans for Chinook and chum salmon that provide additional incentives to avoid salmon at all times. And to help minimize salmon bycatch.

Full retention of all salmon bycatch on pollock vessels is required, both in the Bering Sea and the Gulf, to ensure that bycatch accounting is accurate and to enable genetic sampling. Genetic samples are taken from Chinook salmon in both the Bering Sea and the Gulf to estimate the proportion of bycatch from individual salmon stock groups. Chum salmon samples are primarily taken in the Bering Sea because very little chum salmon bycatch occurs in the Gulf. The council receives annual genetic reports from bycatch samples taken in the groundfish fisheries and also receives annual reports from the Bering Sea Pollock Fishery Cooperatives on fleet performance under the salmon avoidance plans.

When considering the impacts of bycatch on, on specific salmon stocks, it's important to note that bycatch is one of several factors affecting the number of adults returning to Alaska River systems. The number of Chinook or chum salmon caught as bycatch is larger than the number of adults that would have returned to Alaska rivers because the bycatch is primarily composed of immature fish, which of course are subject to predation and other types of mortality before maturing and returning to the freshwater systems. Both Chinook and chum salmon from a given brood year mature and return at multiple ages. Chinook salmon are predominantly, when they're taken as bycatch, predominantly age 3 or age 4. But they range from 3 to 7-year-olds.

And chum salmon range in age from 2 to 7 years and are predominantly aged 3 to 5. The graph here shows Bering Sea Chinook salmon bycatch by stock group from 2015 to 2025, which is the most recent information that we have. At the very bottom are those from the Middle Yukon stock group in black, In red are the Upper Yukon stock group. In yellow are the coastal western Alaska salmon, Chinook salmon. So that's from Kotzebue all the way down to Bristol Bay.

In blue are North Alaska Peninsula and then all other stocks in gray on top. In 2025, a total of 19,797 Chinook salmon were taken as bycatch in the Bering Sea pollock fishery. And through October this year, a total of 13,478 have been taken as bycatch. While stock composition estimates for 2024 were initially delayed due to the federal government shutdown, the council did receive the updates from both 2024 and 2025 in June this year. The stock composition results show that on average, 82% of the annual Chinook salmon bycatch originates from Alaska river systems flowing into the Bering Sea.

And the largest contributions were from the Kuskokwim, that coastal western Alaska group, as you can see in yellow, which compromised about 49% of the bycatch in 2024 and 63% in 2025. The combined Alaska and Canadian Yukon River stocks on the Yukon River, so those black and red bars, accounted for just over 1% of the Chinook salmon bycatch in 2024 and 7.3% in 2025.

Moving now to the Gulf of Alaska Chinook salmon. In the Gulf of Alaska, all of the trawl fisheries operate under Chinook salmon bycatch caps. Primarily though, it's the pollock fishery that intercepts Chinook salmon, other trawl fisheries for flatfish, rockfish, and Pacific cod also have some Chinook salmon bycatch.

The total limit for the Pollock fishery is 25,000 fish, and that's apportioned between the Western Gulf at 6,684 fish and the Central Gulf at 18,316 fish. In 2025, the total Chinook salmon bycatch in the Gulf in the pollock fishery was just over 13,000 fish. Through October this year, a total of 19— just over 19,000 have been taken as bycatch. Stock compositions for the Gulf over the past 5 years are shown in this pie chart. Approximately 47% of the bycatch is comprised of British Columbia stocks, followed by West Coast US at about 29%.

Northeast Gulf of Alaska combined with Southeast Alaska represents about 18% of the bycatch. And the Northwest Gulf, which is Chignik, Kodiak, Upper Cook Inlet to Prince William Sound, including the Copper River system, comprised about 5% of the total bycatch. These stock composition estimates have remained fairly consistent in the Gulf. We haven't seen the same sort of swings that we see in the Bering Sea and are very similar to the long-term average, which is about 45% BC, 33% US West Coast, 16% Southeast and Northwest or Northeast Gulf, and about 6% for the Northwest Gulf and Copper River.

Moving next to chum salmon bycatch in the Bering Sea, nearly all the chum salmon occurs during the pollock B season. So that's the one that opens June 10th every year. In 2025, an estimated 151,000 chum salmon were caught as bycatch in the Bering Sea pollock fishery. This figure here shows, I think on the bottom in black are the western Alaska chum salmon, in red are the upper and middle Yukon chum salmon, in yellow southwest Alaska, so the peninsula area, and then the eastern Gulf Pacific Northwest in blue, Southeast Asia in dark gray, and Northeast Asia in light gray. Um, based on stock composition estimates, about 4.5% of the chum salmon bycatch originated from western Alaska and the Yukon River.

About 1.5% was from stock groups in southwest Alaska, 44% from the eastern Gulf of Alaska and the Pacific Northwest, and over 50% is typically Asian stocks, primarily from Russia and Japan. Through October this year, a total of 143,226 chum salmon have been caught in the Bering Sea pollock fishery.

This year in June, the council took final action to recommend management measures focused on minimizing western Alaska chum salmon bycatch while maintaining priority of the current Chinook salmon bycatch avoidance objectives. This included recommendations to establish a western Alaska chum salmon bycatch limit in a corridor area and require additional avoidance measures through the Pollock industry salmon bycatch avoidance plans to further minimize bycatch of western Alaska chum salmon stocks in the Bering Sea pollock fishery. So the council's preferred alternative recommends a bycatch limit of 45,000 western Alaska chum salmon within the corridor shown in red in the figure on the slide. This corridor includes 40 Fish and Game statistical areas north of Unimak Pass. Establishing a chum salmon bycatch limit specifically for western Alaska chum salmon was important because, as I just mentioned, a majority of the chum salmon taken as bycatch are not from western Alaska.

Based on the annual genetic stock composition data, they're mostly Russian and Asian hatchery fish. The western Alaska bycatch limit and corridor were designed in response to information in the analysis and public comment that the overall limit on chum salmon bycatch— if you have an overall limit for all chum salmon, that may likely not reduce specifically western Alaska chum salmon bycatch, and it risked increasing Chinook salmon bycatch by delaying the pollock fishery into later into the bee season when those Chinook salmon rates begin to increase. So the statistical areas included in the corridor encompass an area where the highest proportion and numbers of Western Alaska chum salmon bycatch occur. All Western Alaska chum salmon caught as bycatch in the corridor count towards the limit during a critical migration period for Western Alaska chum salmon that extends from the beginning of the B season, June 10th, until the end of August. Vessels will use genetic stock composition data from previous seasons and newly available in-season genetic data from Bristol Bay Science and Research Institute to try and avoid reaching the limit.

That limit is divided among the 4 pollock fishing sectors. 71% Goes to the inshore sector that deliver—catcher vessels that deliver to shoreside processors, 9.8% to the CDQ fishery, 9.7% to catcher vessels that deliver to motherships, and 9.5% to catcher processors. If a sector reaches its portion of the corridor cap, it has to close at least 50% of those stat areas for the remainder of that fishing period until the end of August. Highest, and the closure must include those 4 statistical areas marked with an X. Those areas have consistently had high numbers of western, of western Alaska chum salmon bycatch.

And so if a sector reaches its portion of the limit but fails to implement the closure as specified, then the entire closure is closed to them for the following year for the entire period. So that's the stick, I guess. The Western Alaska chum salmon bycatch limit and corridor closure will not be in effect following a year when more than 3.8 million summer chum salmon and 1 point— roughly 4 million fall chum salmon return to the Yukon River. And this is based on the preliminary postseason run reconstruction estimate that's provided by Fish and Game. This measure was included by the council to recognize that both the limit and the corridor may be constraining for the pollock fishery if western Alaska chum salmon stocks recover to historically high abundance.

So those thresholds are based on historically high abundances of chum salmon in the Yukon River. The council's recommendation also included several changes to the pollock industry's salmon avoidance plans. These changes require those plans to incorporate genetic information into the in-season chum avoidance measures. They have these ongoing rolling hotspot closures in season to move the fleet away from areas of high Chinook and western Alaska bycatch. Increase transparency in reporting and accountability by assuring that Alaska Native tribes, tribally authorized consortia and fish commissions, and salmon users have access to the bycatch reports in an easily usable format.

The council's recommendation must be implemented by the National Marine Fisheries Service, and based on current staffing and resources, they anticipate those rules will be in place prior to the 2028 B season.

Very briefly on herring, management measures for herring bycatch that apply to the Bering Sea groundfish trawl fisheries have remained static since they were first implemented in 1991. They're set at 1% of the mature biomass of Pacific herring in the Bering Sea, and if any fishery reaches their limit, it triggers closure of specific herring savings areas.

The herring savings areas are based on herring migration data from the 1980s that may no longer reflect the current seasonal distribution of herring. And in recent years, Pollock fishery participants have encountered herring at different rates, times, and locations than historically occurred, and these changes have constrained the fleet's ability to meet requirements to minimize salmon bycatch. In October last year, the council initiated an action to consider increasing the herring bycatch limit to provide additional flexibility for the Pollock fleet to adapt to these changing conditions, and to ensure that the salmon bycatch avoidance efforts are effective.

In October this year, the council heard from the National Marine Fisheries Service that federal staff are exploring alternative approaches for estimating the biomass of herring. Currently, they rely on Fish and Game information that has become somewhat static in recent years. We haven't been able to do the same suite of herring surveys, and so it's based on an average that's getting pretty old. So the National Marine Fisheries Service is working on a potential alternative approach for estimating herring in the Bering Sea, and we expect to hear back from them at an upcoming council meeting. And we'll likely take up this herring bycatch issue sometime next year as well.

Finally, we have a new acronym. Yay! Biologically informed recommended distributions. So beginning with the current assessment cycle, the council has adopted new terminology for— and this is for subarea apportionments of the acceptable biological catch, or ABC. We now refer to these subarea apportionments of an ABC as biologically informed recommended distributions, or BIRDS.

The impetus for this change is to clearly distinguish between a true ABC and a subarea apportionment of that ABC. And that's because under the Magnuson-Stevens Act, the ABC is a scientific calculation of a fishery sustainable harvest level that accounts for the uncertainty of the, of the overfishing, of the overfishing limit. These ABCs, or what are also known as annual catch limits, were established in 2020 2006 under the Magnuson-Stevens Act reauthorization. And there are specific guidelines for specifying these ABCs, or Annual Catch Limits, and certain things that happen if you exceed an ACL or an ABC. Whereas a subarea apportionment, or now called a BRD, is a management tool that adds an extra layer of precaution to account for uncertainty in stock structure and to reduce the risk of localized depletion.

So we have this new term BRD, and to improve consistency, the department may be seeking a delegation from the board to make some corresponding terminology changes in state regulations. So for example, in the Gulf Pacific cod fisheries, we set the Chignik, the Kodiak, the South Alaska Peninsula GHLs for Pacific cod Alaska, based on the acceptable biological catch of Pacific cod in the Gulf. Those are actually sub-area apportionments. So now on the Fed side, they're going to be BRDs, but in certain sections of our regs, we're still calling them ABCs. So just some background on that.

And with that, I'll take any questions. XYZ. Okay, any questions for Karla?

Just real quickly, I just want to make sure that I heard a couple things. Like, you said that the, um, the run reconstruction numbers that I guess inform whether or not that those chum bycatch rules are in effect are ADF&G run reconstructions for in-river numbers. Using— you're just using the in-river numbers that would trigger those? Correct, Madam Chair. Um, so for the Bering Sea Chinook salmon bycatch limits, we use a postseason run reconstruction estimate.

And if it's not above a threshold for Chinook of 250,000, that's based on a 3-system index, the Pollock fishery operates under a lower Chinook salmon bycatch limit and performance standard. For this chum one, it's a similar postseason run reconstruction. For the Yukon River summer chum and fall chum, and if abundance is above that threshold, this chum salmon corridor and limit would not be in place. So I guess my question is, is I think you made reference, at least in respect to the chum, about in-river. So when you're talking about a run reconstruction, that's everything.

So what is, what is the trigger? Is it in-river numbers, or is it, you know, everything that's caught plus the escapement? What are you using to trigger a post—. Yeah, post-in— thank you.

I think it's just that preliminary post-season run reconstruction estimate. I think it's the forecast that we give the National Marine Fisheries Service every year and they base it based on that forecast. If we're underneath that trigger, it triggers the action. So everything? Yes.

Yeah, it's not in Revver numbers. Yes. Okay, thank you.

All right, I don't see any other questions. Thank you, Karla. I just want to say that one of my most interesting months of the year is October because it is, it sets the crab quotas, and this last couple years has been incredibly challenging with hybrid crab. I never thought in my life that I would see crab that can mate either with Tanner crab or with snow crab, and they can successfully mate with either one of those as a hybrid crab. So this is really a challenge moving forward.

It's a crab orgy. Yeah. Okay. Let's close out with the Federal Subsistence Board, please.

Thank you, Madam Chair. For the record, Brian Ebelaker. I'm currently the acting state liaison for OSM, and I will keep this very short. I only have a couple of points to update you with. So way back in 2025, the Secretaries of Interior and Agriculture initiated a targeted program review of the Federal Subsistence Management Program.

The Department of Interior gathered public input through several public meetings and online submissions, and around 1,800 comments were received and are currently being evaluated. However, there is no set timeline for completion of the review, but departmental leadership has indicated that they would like to move things forward in the next few months. The federal subsistence regulations regarding the harvest of wildlife have finally been published in the Federal Register, nearly 4 months late, as of yesterday. OSM staff has worked endlessly to push the regulatory amendments through the review process. Alaska, Alaska, Alaska, Alaska, Alaska, Alaska.

Regulations are updated on the Federal Subsistence Management Program website, and hard copy versions of the regulation booklets will be available shortly at land management offices. The Federal Subsistence Board has acted on 14 wildlife special action requests so far in 2026. 6 Of those that were approved are currently enacted, while 2 are still pending. 6 Of these actions were requests to implement the delayed regulations adopted by the board at the regulatory meeting in April. Uh, Fisheries Regulatory Board meeting will occur February 2nd through the 5th, 2027, here in Anchorage.

The board will consider 8 fisheries proposals and 10 closure reviews. They will also take action on several deferred wildlife proposals and wildlife special action requests. And finally, a call for wildlife proposals for the 2028-2030 Wildlife cycle will be opening in early 2027. Uh, kept my word, kept it short. Thank you very much.

We appreciate you. Thank you. Any questions?

Seeing none, thanks for your report today. Okay, we ran a little over because I know it was a long day. Um, we are going to pause here for the day. We're going to reconvene tomorrow morning at 8:30 to complete sort of the board's administrative housekeeping, and then we'll get into agenda change requests consideration. So we will see you tomorrow morning at 8:30.

Thank you.