May 17, 2009
Sunday

Dear Commissioner Lloyd (Alaska Department of Fish & Game):

We are very concerned with the decision by the Board of Fish (Board) to open the commercial Dungeness crab fishery in Districts 1 and 2 of Registration Area A from June 15 to August 15 (summer season).

In short, we strongly disagree with the way the Board went about approving the opening of the summer season, we are concerned for the health of the resource, and we take seriously any assumption that this action will receive the required funding from the legislature. Unless and until these issues can be sorted out, the summer season should not be opened.

We've talked with concerned citizens who took the time to attend the Board meetings in Petersburg. Many left the meeting after the proposal to open the summer season had been voted down, thinking the issue and the meeting were wrapped up. However, the summer season proposal was brought back up at the last hour and passed.

At the very least, this action erodes the public's confidence in a fair, open and transparent Board process.

The summer season in Districts 1 and 2 has been closed for many years, due in part because this is the primary molt period for males. Data suggests that up to 59% of males caught in the summer are 'soft-shell' and not marketable. Even more disturbing, the mortality rate of handling soft-shelled crabs has been estimated up to 50%, reducing profits and putting more pressure on the resource.

It is troubling that Fish and Game would be complicit in Board decisions that fly in the face of your consistent theme of managing fisheries on a science-based, conservative approach. Has recent research or data suggested that summer soft-shell deadloss will be reduced or eliminated with the new summer opening? Do you feel confident in the stock assessments you possess to assure sustainability of the resource? What condition will the resource be in three years from now? Are we sacrificing generations of personal use opportunity and winter commercial landings for one summer commercial harvest season?

We are also very disturbed that the Board can take action which appears to assume legislative appropriation support.

Do you have the funding available to open this fishery at the tail end of FY08? Are you going to have to come to the legislature with a ratification for FY08 and a supplemental for FY09?

We are considering legislation that would require the ADF&G to provide fiscal notes detailing the costs to the state for proposals before the Board. In addition, when any new fishery is created or Board action taken that requires additional state funding, implementation should wait until the Department goes to the legislature and gets approval for the increased funding.

Because of the concerns outlined above, we believe opening of the commercial Dungeness summer season in Districts 1 and 2 should be reconsidered. In the event you are forced to open this fishery we demand the most conservative approach in management be taken to protect the resource.

Sincerely,

Representative Kyle Johansen,
House Majority Leader

Representative Bill Thomas, Chair
House Finance ADF&G Subcommittee

Cc

Governor Sarah Palin
Representative Mike Hawker
Representative Bill Stoltze
Senator Bert Stedman
Senator Lyman Hoffman

Received May 15, 2008 - Published May 17, 2009

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