http://www.boards.adfg.state.ak.us/fish ... 008-24.pdfLink to BoF ADFG staff comments
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Ocean Gold
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Link to BoF ADFG staff comments
Before you read to many relax with a strong drink
http://www.boards.adfg.state.ak.us/fish ... 008-24.pdf
http://www.boards.adfg.state.ak.us/fish ... 008-24.pdf
Re: Link to BoF ADFG staff comments
I see what you mean Ed. This is outrageous, I am going in to talk to the sport fish staff on Monday.
Re: Link to BoF ADFG staff comments
It was late last night when I first read the staff comments on proposal 286 and 287 to redefine the possession limit definition for SE Alaska to include preserved fish until returning to your domicile. Here is the staff comment on proposal 286 that I consider outrageous.
“……it is unable to determine how such a regulation could be successfully monitored and enforced.”
SEAFA and Jeff Farvour, of ALFA, have put together an impressive list of states and countries where the fish and game and enforcement staff have figured out how to monitor and enforce this kind of regulation. For the sport fish staff in Alaska to claim they can't figure it out is to admit that they are not up to their job. The leadership of the Sport Fish Division who are dictating this kind of position need to be replaced.
I have served on the Board of Fisheries for a short time. I went through the training for Board members. The Alaska system gives the Board of Fisheries great authority in developing policies and regulations for managing our fisheries. Part of the success of our fisheries management system in Alaska is that the system gives the fish & game staff great latitude and responsibility in carrying out the policies and regulations determined by the Board of Fisheries. It does not give the staff the authority to defy, resist, or otherwise try to manipulate the Board of Fisheries by claiming they couldn't figure out how to monitor and enforce a proposed regulation that numerous other states and countries have successfully accomplished.
This is beyond outrageous, it is insubordinate by the sport fish division to the Board of Fisheries (insubordinate implies failure or refusal to recognize or submit to the authority of a superior) and needs to be dealt with by the Commissioner and if Commissioner Lloyd is not up to the task then by the Governor. The reason I make the strong statement that this is insubordinate (and I carefully considered this word) is that the sport fish staff is claiming that if the Board of Fisheries adopted this proposal they are "unable to determine how such a regulation could be successfully monitored and enforced.”
In the culture of the Alaska Board of Fisheries one of the key decision points in adopting regulations is whether they can be evaluated (monitored) for effectiveness, and whether they are enforceable. I have spent hours at advisory committee, task force, and various board meetings carefully considering words and working with enforcement and fish and game staff to be sure proposals were legally correct and enforceable. I helped write proposal 286. (I probably have had more individual proposals and proposals I have written for various groups adopted by the Board of Fisheries over the last 30 years than any other citizen not employed by Fish & Game.) I consulted with knowledgeable fish & game staff about the wording on proposal 286 as we wrote it. We looked up regulations in other states. The word "domicile" is defined in Alaska regulations.
The Board of Fisheries thought this proposal had enough merit to appoint a committee to work on it between cycles. If there is enough conservation concern to have possession limits at all then there is is corresponding justification that the possession limits include preserved fish. Modern freezing technology has improved and changed the playing field. Management and regulators need to consider adapting the regulatory environment to account for these changes. For the sport fish division staff to claim they are "unable to determine how such a regulation could be successfully monitored and enforced" is absolutely unacceptable. We need staff who are both more cognizant of their place in the management structure and more adaptable to change.
What do you think? Lets get some comment going on this issue.
“……it is unable to determine how such a regulation could be successfully monitored and enforced.”
SEAFA and Jeff Farvour, of ALFA, have put together an impressive list of states and countries where the fish and game and enforcement staff have figured out how to monitor and enforce this kind of regulation. For the sport fish staff in Alaska to claim they can't figure it out is to admit that they are not up to their job. The leadership of the Sport Fish Division who are dictating this kind of position need to be replaced.
I have served on the Board of Fisheries for a short time. I went through the training for Board members. The Alaska system gives the Board of Fisheries great authority in developing policies and regulations for managing our fisheries. Part of the success of our fisheries management system in Alaska is that the system gives the fish & game staff great latitude and responsibility in carrying out the policies and regulations determined by the Board of Fisheries. It does not give the staff the authority to defy, resist, or otherwise try to manipulate the Board of Fisheries by claiming they couldn't figure out how to monitor and enforce a proposed regulation that numerous other states and countries have successfully accomplished.
This is beyond outrageous, it is insubordinate by the sport fish division to the Board of Fisheries (insubordinate implies failure or refusal to recognize or submit to the authority of a superior) and needs to be dealt with by the Commissioner and if Commissioner Lloyd is not up to the task then by the Governor. The reason I make the strong statement that this is insubordinate (and I carefully considered this word) is that the sport fish staff is claiming that if the Board of Fisheries adopted this proposal they are "unable to determine how such a regulation could be successfully monitored and enforced.”
In the culture of the Alaska Board of Fisheries one of the key decision points in adopting regulations is whether they can be evaluated (monitored) for effectiveness, and whether they are enforceable. I have spent hours at advisory committee, task force, and various board meetings carefully considering words and working with enforcement and fish and game staff to be sure proposals were legally correct and enforceable. I helped write proposal 286. (I probably have had more individual proposals and proposals I have written for various groups adopted by the Board of Fisheries over the last 30 years than any other citizen not employed by Fish & Game.) I consulted with knowledgeable fish & game staff about the wording on proposal 286 as we wrote it. We looked up regulations in other states. The word "domicile" is defined in Alaska regulations.
The Board of Fisheries thought this proposal had enough merit to appoint a committee to work on it between cycles. If there is enough conservation concern to have possession limits at all then there is is corresponding justification that the possession limits include preserved fish. Modern freezing technology has improved and changed the playing field. Management and regulators need to consider adapting the regulatory environment to account for these changes. For the sport fish division staff to claim they are "unable to determine how such a regulation could be successfully monitored and enforced" is absolutely unacceptable. We need staff who are both more cognizant of their place in the management structure and more adaptable to change.
What do you think? Lets get some comment going on this issue.