RE: Katmai Service Providers comments to the Katmai Backcountry Management PlanApril 17, 2022Katmai Service Providers, Inc currently has 65 active participating business members that all hold a Commercial Use Authorization permits for Katmai National Park and Preserve and/or the Alagnak Wild Scenic River issued by the National Park Service. We are submitting this comment on behalf of all 65 members. We are addressing the 4 main topics in your presentation. We will leave it to individual operations to answer your specific questions you asked as each operator might have some unique points of view.The timeframe that the National Park Service request for comment on scoping for the opinions regarding a Back Country Management Plan of Commercial Use Authorization permit holders is not adequate. The topic of a wide sweeping all-encompassing management plan that has large affects regarding access and activity requires careful understanding and scrutiny. We appreciate the Park Service willingness to listen and take into account our concerns, however we request a 6 month extension for the comment period. We were given basically 1 month to absorb the details, which we still need more of regarding the purpose and ramification of implementing a plan such as proposed, and then develop our opinions is much too short of a timeframe. The Park Service request for comment on the BCMP also coincides with the CUA meetings and new issues with the Brooks River corridor management. Thus there is not really adequate time for the public comment.Regarding NPS identified key issues:Impacts of Concentrated Visitor Use on Wilderness and Backcountry Areas
For the BCMP planning process to be effective, the public and commercial operators need to be assured that the visitor use data is accurate. The BCMP newsletter statement that there are “over 40,000 visitor use days in a short season” can be incorrectly interpreted as Backcountry use. It appears that the Park is combining backcountry visitor numbers from the Brooks River Development area and Lake Camp boat launch which are both identified as “Front Country”. The NPS “Visitor Use In Katmai” document at https://www.nps.gov/articles/visitor-use.htm shows that visitor use at Brooks is high and increasing and that use in the backcountry has been stable, and in some cases, declining. That document states “the number of visitor use days reported by businesses operating in the Katmai Nat’l Park and Preserve has fluctuated between 25,000 and 37,000 per year, with a sharp decrease in 2020…” The BCMP newsletter statement of “over 40,000 visitor use days” requires clarification as it does not square with reported numbers. Clear and accurate Backcountry visitor use numbers in the Park and Preserve are essential to the success of the BCMP process.
Increasing visitor numbers at Brooks seems to be driving management concerns about increased use in the rest of Katmai Park. Promotion of Brooks by the bear cams and the Fat Bear Contest have drawn more attention and increased visitation to Brooks. If the Park is concerned about increasing use in the backcountry, the BCMP needs to be sensitive to the effect of modern info technology and online content attracting visitors to the wilderness.The visitor days in the Moraine Creek drainage were flat and consistent from 2011 through 2015 at about 3,500 visitor use days. The number dropped significantly during 2016 to 2018 to about 2,500 before a single season increase to 4,000. With 4,000 visitors spread over a 75-day period (July, August, and part of September) averages 53 people per day. This is not a large number of users of an area inside the Preserve that has over 20 miles of traditionally used waters for fishing and bear viewing.An example of proactive measures without limiting access is as follows: Hallo Bay received its most visitors in 2015. At that time Katmai Service Providers sponsored pre-season operator meetings encouraging consistent field practices such as utilizing consistent routes, slowing down and sitting down, merging groups to avoid stress when near bears, agreed time of day limits on some parts of the meadows, and spreading out commercial use to other locations.Although some locations such as Moraine Creek/Crosswind Lake receive increased visitor use during July and August to bear view and sport fish, the quality of the experience remains very high. We are able to provide a safe and enjoyable experience for our visitors while accessing these parts of the Preserve. We do not believe limiting use or creating a concession program is necessary and encourage the Park to continue to allow access as is currently managed. We have concerns about the wording in the presentation that stated: “Motorized vehicles and equipment, as well as mechanical transport use in the wilderness, will be limited to the minimum necessary authorized activities.” This needs clarification – is it boats, airplanes, generators, or other?We currently do not support a limitation on number or timing of aircraft accessing sites in the backcountry. If limitations are considered as BCMP options, there must be a clearly defined process addressing such items as: visitor use data, historical use by CUAs, and seasonal use patterns, etc.
Human-Wildlife Interactions and Potential Conflict. The Katmai bear population is one of the healthiest and best protected bear populations in the world. These lands are ours to utilize and enjoy. Visitors to the Katmai backcountry will continue to have interactions at some extent with bears. The BCMP Newsletter states, “Increasing visitation may affect animal physiology and behavior, movement patterns, compromise overall wildlife health, and diminish visitor safety.” Our responsibility as users and managers is to promote visitor behavior and field practices that avoid negative interactions while we enjoy the wilderness. We can all generally agree with that goal, but how NPS staff at Brooks and commercial operators in the backcountry achieve that goal are sometimes significantly different. We believe that the excellent history of operators in Katmai backcountry via the CUA permit process shows that guided activities are safe and have a very low impact.We can be sensitive to bears’ needs without unnecessarily restricting the use of good judgement in the field. Recognizing the value of best practices and the challenge of learning the necessary field skills, KSP initiated an enhanced guide training program in 2018 that emphasized safety, interactions with bears and interaction with different user groups. This online program and along with a test at the end is a valuable and useful tool we encourage Park to recognize and implement. Daily survival is what a bear is working to achieve and Katmai is the best habitat in the world. Overemphasis on access restrictions based on the premise that human interaction with bears might affect the bears physiology and behavior is unwarranted. Commercial operators have and continue to operate in a manner that has as minimal impact as possible while safely viewing, studying, and enjoying the bears of Katmai. It is in our best interest to ensure that the habitat remains intact, healthy, and that our human footprint is as minimal as possible. The only way to have a “zero” impact is to shut down access completely. The continued record returns of salmon to the rivers of Katmai ensures the bear population is extremely healthy and with 4.13 million acres of land they have massive habitat to roam. We would like to see the park do more visitor use studies such as the Park service's 3 year study in Geographic Harbor & Hallo Bay (Troy Hamon) and the Tom Smith & Steve Partridge study at Hallo Bay in 1998/1999/2001. If the Park Service has additional study results available such as information from the recent 3 year collar study which focused on the bear human interactions on the third year and information on the study in Katmai Bay that the public can access the supporting data available on a resource page on the Backcountry Management site. A section on Anilca would be valuable. We feel good accurate data is critical in forming the management plan and going forward for future planning. It is critical to assemble our best data to keep an eye on things going forward.Thousands of people visit the Katmai backcountry annually with no problems even though there is a wide spectrum of possible interactions with wildlife, and potential for hazardous or neutral interactions, largely depending on experience level and choices made by people. Negative incidents can be reduced by providing the public with easily accessible information and education on best practices before they go to the field. Online video material focused on backcountry visitor activities might be useful, similar to the Brooks orientation materials. The risk here is that doing so might inadvertently attract more inexperienced people to the backcountry. KSP recognizes that CUA's deliver the largest percentage of people to the backcountry therefor we and our clients have a responsibility to employ practices that minimize negative impacts.Management of Commercial Services as Visitor Demand Increases. Is the Park looking to limit the number of Commercial Use Authorization permits it issues? KSP does not support changing Katmai commercial use management to a park wide concessions system or limited use approach. We think the CUA program has been successful and is appropriate, uncomplicated, and accessible for new operators. The current use numbers do not show a need to progress to a Concessions system. The current Commercial Use Authorization permit requirement and compliance with the Compendium and Park Specific Stipulations has some flaws but there is no need to add further limitations on access or burdensome regulations. There is no evidence we are aware of where there has been degradation of habitat from human access anywhere in the backcountry. We are strongly against Park managers closing areas without warning (for example, closures at Brooks without notice) – it is disruptive to businesses and their clients. If site closure is contemplated as an appropriate management tool in the BCMP. At locations where the BCMP indicates that use levels require a management action be taken, we recommend developing a Site Specific Protocol.The existing Site Specific Protocol in Geographic Harbor addressed the issue of increasing visitor use in a high bear-use area by utilizing an existing management tool. It provides for more predictable and consistent human behavior which clearly benefits the bears. As evidenced by the Geographic protocol area, sites with high bear use and high visitor use can be successfully managed for the benefit of both bears and humans.Challenges for Managing Wilderness and Backcountry Areas with Limited Staff across Millions of Acres and ANILCA Wilderness Complexities
From the Park presentation: “The plan is needed to safeguard wilderness character, address the effect of concentrated and increasing visitation, and to provide guidance and direction for managing commercial and private visitor use.” If the BCMP continues to use the current management approach (CUA for commercial operators) in Katmai National Park and Preserve and the Alagnak Wild and Scenic River, while including enhanced education tools (such as online access to best bear viewing practices) these planning goals will be satisfied. In areas the Park Service can't police, commercial operators with high professional standards can assist the park in maintaining good field practices by visitors. KSP Guide Excellence Program as well as the Hallo Bay pre-season meetings among operators visiting Hallo Bay which were initiated by KSP to reduce visitor impact on wildlife and increase cooperation among commercial users. These are some of the goals stated in the back country management plan. Utilizing KSP and the tools we have is encouraged. Not only are Katmai Service Provider members are engaged and very active with regards to protecting the habitat and resources that we depend upon for the success of our business, but we are also operators that have a passion for what we do and the place we operate. We are caretakers of the land and water, and we see it as our responsibility to protect it while at the same time utilizing the resource and bringing people to this region. We would be the first ones to tell you if we felt there was a serious problem with managing the resource under the present format.
Thank you,
Katmai Service Providers, Inc KSP Members
The following is the letter I sent over to the Governor. Will let you know if I get any feedback.
Brian Kraft
April 7, 2020
Governor Mike Dunleavy, The Katmai Service Providers, Inc is comprised of 62 businesses that operate throughout Katmai National Park as well as the Greater Bristol Bay region. We are owners of air taxis, lodges, guide services, and Eco tourism companies that help contribute over $300M a year into state revenue. We work closely with the Superintendent of the Park to help guide policy and long-term vision for the region with regards to sustainable healthy businesses. Our membership is comprised of small businesses that generally do not carry forward large amounts of capital. We are all grappling with the COVID-19 situation that has sickened many, taken lives, and crippled the economy. We are keenly aware of the concerns that many people and tribal entities have expressed with regards to the commercial fishery that takes place in Bristol Bay. We are also aware of the impact that an outbreak of COVID-19 could have in a small community that has a large influx of people in a very short period of time. It is crucial for your office to understand the vast difference between the commercial fishery and its impact on local communities versus the sport fishing and tourism-based businesses that also operate in the Katmai / Bristol Bay region. The Commercial fishery of Bristol Bay requires a massive labor force that arrives into the region in large numbers very quickly. Some of that labor force will begin to arrive in the coming weeks with large pushes of labor arriving by late May. There is also a tremendous lead time in preparation for the season by the canneries and support businesses. Additionally, the Commercial season is actually quite short in duration from Mid-June to Mid-July and cannot be put on pause nor delayed. The fish are going to arrive when nature dictates and once they are out of the ocean there is lost economic opportunity for the commercial fleet. Thus, it makes the commercial industry an “All or Nothing” scenario. It is not like they can delay the season to mid-July. If they do not have everything in place when the fish arrive the season will be a bust. The interaction of the imported workforce into the local communities is quite overwhelming and it is understandable that the communities of Dillingham, King Salmon, and NakNek are very concerned about this pending surge of people. Compared to the Tourism based industries such as bear viewing, sport fishing lodges, air taxi’s, and photography tours, where we can delay the start of our season and still have somewhat of a successful season. Additionally, the physical preparation needed to “open” these businesses is minimal with most being able to open for business within days. The biggest difference is for the most part many of our businesses can operate without ever impacting or interacting within any of the larger communities such as King Salmon, NakNek, Dillingham, Iliamna. Nor would we need to interact in any of the smaller villages in the region. Where interaction is necessary there can be protocols put in place and easilyadhered to since you are not looking at thousands of people moving into a region at a time but rather a few people potentially moving through as they make their way to a lodge or some other remote location.The lodges themselves are self-contained operations and can virtually eliminate any interaction with any of the villages. The air taxi’s with bear viewers and photographers transport people to the most remote parts of the Park and have no interaction with Bristol Bay communities. We are not callously approaching this situation and all of our businesses are making plans and looking at protocols to operate safely. We are hopeful that rapid testing becomes available that would allow testing to be done on travelers prior to making their way to a lodge or to the region. This would greatly improve confidence and allow for a testing protocol to ensure safe operations. As far as the concerns of the commercial fishery opening and requests for your office to shut down the Bristol Bay commercial fishery, we want to make sure you take a calculated specific approach with regards to our business sector and if warranted, consider incremental steps as we approach the season opener of June 8. We urge you to look at alternatives to a complete closure for the entire season at any one point in time and urge your office to take a wait and see approach as we get closer to our season. It is a fast-moving fluid situation and new data is becoming available each day. There are breakthroughs in testing procedures as well as potential remedies for COVID that would make it acceptable to safely openbusinesses throughout the country. It is difficult at this point in time now to predict what things will look like in June let alone July, August, or September. I am available for any questions or discussions. Thank you for your time and attention to our situation.
Brian KraftPresidentKatmai Service Provider’s, Inc.907-227-8719Brian@fishasl.com
I heard back from Senator Murkowski’s office regarding our concerns with the shortcomings with the PPP loan program. Ann Roberston has been very responsive and I suggest all our members reach out to her to request funding for summer seasonal operations. Here email is:
Ann_robertson@murkowski.senate.gov
For reference here below are suggestions that have been made to her and would be good for others to send similar requests:
Allow summer seasonal businesses to take 2019 total payroll and divide that number by 4 to arrive at a monthly average and multiply by 2.5 (this encompasses the bulk of seasonal business payroll). This will cover a large portion of anticipated payroll and allow small businesses to keep employees even when revenue is down.
Support modifications to existing loans through refinancing or gapping payments with short term funding through the SBA to apply payments towards. So the SBA would provide 12 months’ worth the amount of an existing business loan that a company already has. This SBA funding would be at a 5 year term at 1% with no prepayment penalty.
Regional funding for tourism based operations if seasons are canceled or impacted due to COVID-19 that would be granted at 40% of the average for the last three years revenue. For instance a company has an average of $1,000,000 in revenue for the last three years. The company would receive a grant for $400,000. Or if it had to be a SBA loan it could be paid back at a favorable rate similar to the PPP. This money would be used for existing business operations and covering expenses to make sure we are able to progress and open for business in 2021.
The attachment on this e-mail is a good PDF that shows the different loans available to small businesses and what the differences are.
Brian Kraft-PresidentKatmai Service Providers KSP Members
The following is the letter I sent over to the Governor. Will let you know if I get any feedback. Brian Kraft
April 7, 2020
Governor Mike Dunleavy, The Katmai Service Providers, Inc is comprised of 62 businesses that operate throughout Katmai National Park as well as the Greater Bristol Bay region. We are owners of air taxis, lodges, guide services, and Ecotourism companies that help contribute over $300M a year into state revenue. We work closely with the Superintendent of the Park to help guide policy and long-term vision for the region with regards to sustainable healthy businesses. Our membership is comprised of small businesses that generally do notcarry forward large amounts of capital. We are all grappling with the COVID-19 situation that has sickened many, taken lives, and crippled the economy. We are keenly aware of the concerns that many people and tribal entities have expressed with regards to the commercial fishery that takes place in Bristol Bay. We are also aware of the impact that an outbreak of COVID-19 could have in a small community that has a large influx of people in a very short period of time. It is crucial for your office to understand the vast difference between the commercial fishery and its impact on local communities versus the sport fishing and tourism-based businesses that also operate in the Katmai / Bristol Bay region. The Commercial fishery of Bristol Bay requires a massive labor force that arrives into the region in large numbers very quickly. Some of that labor force will begin to arrive in the coming weeks with large pushes of labor arriving by late May. There is also a tremendous lead time in preparation for the season by the canneries and support businesses. Additionally, the Commercial season is actually quite short in duration from Mid-June to Mid-July and cannot be put on pause nor delayed. The fish are going to arrivewh en nature dictates and once they are out of the ocean there is lost economic opportunity for the commercial fleet. Thus, it makes the commercial industry an “All or Nothing” scenario. It is not like they can delay the season to mid-July. If they do not have everything in place when the fish arrive the season will be a bust. The interaction of the imported workforce into the local communities is quite overwhelming and it is understandable that the communities of Dillingham, King Salmon, and NakNek are very concerned about this pending surge of people. Compared to the Tourism based industries such as bear viewing, sport fishing lodges, air taxi’s, and photography tours, where we can delay the start of our season and still have somewhat of a successful season. Additionally, the physical preparation needed to “open” these businesses is minimal with most being able to open for business within days. The biggest difference is for the most part many of our businesses can operate without ever impacting or interacting within any of the larger communities such as King Salmon, NakNek, Dillingham, Iliamna. Nor would we need to interact in any of the smaller villages in the region. Where interaction is necessary there can be protocols put in place and easily adhered to since you are not looking at thousands of people moving into a region at a time but rather a few people potentially moving through as they make their way to a lodge or some other remote location. The lodges themselves are self-contained operations and can virtually eliminate any interaction with any of the villages. The air taxi’s with bear viewers and photographers transport people to the most remote parts of the Park and have no interaction with Bristol Bay communities. We are not callously approaching this situation and all of our businesses are making plans and looking at protocols to operate safely. We are hopeful that rapid testing becomes available that would allow testing to be done on travelers prior to making their way to a lodge or to the region. This would greatly improve confidence and allow for a testing protocol to ensure safe operations. As far as the concerns of the commercial fishery opening and requests for your office to shut down the Bristol Bay commercial fishery, we want to make sure you take a calculated specific approach with regards to our business sector and if warranted, consider incremental steps as we approach the season opener of June 8. We urge you to look at alternatives to a complete closure for the entire season at any one point in time and urge your office to take a wait and see approach as we get closer to our season. It is a fast-moving fluid situation and new data is becoming available each day. There are breakthroughs in testing procedures as well as potential remedies for COVID that would make it acceptable to safely open businesses throughout the country. It is difficult at this point in time now to predict what things will look like in June let alone July, August, or September. I am available for any questions or discussions.Thank you for your time and attention to our situation..
Brian KraftPresidentKatmai Service Provider’s, Inc.907-227-8719Brian@fishasl.com
I heard back from Senator Murkowski’s office regarding our concerns with the shortcomings with the PPP loan program. Ann Roberston has been very responsive and I suggest all our members reach out to her to request funding for summer seasonal operations. Here email is:
Ann_robertson@murkowski.senate.gov
For reference here below are suggestions that have been made to her and would be good for others to send similar requests:
Allow summer seasonal businesses to take 2019 total payroll and divide that number by 4 to arrive at a monthly average and multiply by 2.5 (this encompasses the bulk of seasonal business payroll). This will cover a large portion of anticipated payroll and allow small businesses to keep employees even when revenue is down.
Support modifications to existing loans through refinancing or gapping payments with short term funding through the SBA to apply payments towards. So the SBA would provide 12 months’ worth the amount of an existing business loan that a company already has. This SBA funding would be at a 5 year term at 1% with no prepayment penalty.
Regional funding for tourism based operations if seasons are canceled or impacted due to COVID-19 that would be granted at 40% of the average for the last three years revenue. For instance a company has an average of $1,000,000 in revenue for the last three years. The company would receive a grant for $400,000. Or if it had to be a SBA loan it could be paid back at a favorable rate similar to the PPP. This money would be used for existing business operations and covering expenses to make sure we are able to progress and open for business in 2021.
The attachment on this e-mail is a good PDF that shows the different loans available to small businesses and what the differences are.
Brian Kraft-PresidentKatmai Service ProvidersToday I spoke to my State of AK House representative today, Laddie Shaw in Juneau, and relayed the message that all operators in Bristol Bay –KSP members—are starting to feel the pinch with real and potential cancelations. I informed him of the huge upfront expenses our businesses have in preparation for the season and that this money is spent from clients deposits that are now asking for refunds. I asked the he have the Governor declare a state of emergency for Alaska and the Bristol Bay Sport and Commercial fisheries ahead of the season so that we can prepare and get in line as there will be many businesses doing the same thing. I relayed the message that we understand that the airline and cruise ship industries need a bail out but that it is the small business owner in Alaska that fuels the local economy and we will need help. I encourage all Alaskans that do business in Katmai/Bristol Bay to call their reps in Juneau and tell them we need help. Tell them we want access to SBA zero or low interest loans to get us through this crisis. If you do not live in Alaska yet operate in the Katmai/Bristol Bay area, contact Representative Bryce Edgmon (he reps Bristol Bay and Speaker of the House) and tell him your business that brings economic benefit to the region will need help. Representative.Bryce.Edgmon@akleg.gov Or by phone at 800-898-4451 To all Katmai Service Provider members-
I wanted to take a moment to write to all of you to express hopes for all to have a safe and profitable season. The COVID-19 virus has put both of those in jeopardy. Although the season opener of June 8 is 83 days from the writing of this email and many trips happen in July, August, or September, my company is starting to receive cancelation inquires. Although I am an optimist and hope we get this thing under control in the next month, I believe it is prudent that we all start to prepare for what would be a catastrophic event to our businesses with massive cancelations if the virus persists. Katmai Service Providers has proven over the years to be a valuable and strong organization when speaking to decision makers. Strength is in numbers. To that end, I began discussions with the Commercial fishing industry and Bristol Bay Economic Development Corp in an effort to collectively pool our influence on our delegation to provide a financial relief package that is Bristol Bay centric. I would be embarking on this effort on behalf of Katmai Service Provider members. The idea being that we show the importance of making all tourism and commercial fishing businesses that will be severely affected financially stable. Although it is appropriate to bail out the airlines and cruise industries that are hurting, we, the small business owners and our employees that depend upon our ability to pay them, will be the hardest hit.
Let me know if you have any questions or opinions on this.
Thank you,
Brian KraftPresident –Katmai Service Providers, INC
For the BCMP planning process to be effective, the public and commercial operators need to be assured that the visitor use data is accurate. The BCMP newsletter statement that there are “over 40,000 visitor use days in a short season” can be incorrectly interpreted as Backcountry use. It appears that the Park is combining backcountry visitor numbers from the Brooks River Development area and Lake Camp boat launch which are both identified as “Front Country”. The NPS “Visitor Use In Katmai” document at https://www.nps.gov/articles/visitor-use.htm shows that visitor use at Brooks is high and increasing and that use in the backcountry has been stable, and in some cases, declining. That document states “the number of visitor use days reported by businesses operating in the Katmai Nat’l Park and Preserve has fluctuated between 25,000 and 37,000 per year, with a sharp decrease in 2020…” The BCMP newsletter statement of “over 40,000 visitor use days” requires clarification as it does not square with reported numbers. Clear and accurate Backcountry visitor use numbers in the Park and Preserve are essential to the success of the BCMP process.
Increasing visitor numbers at Brooks seems to be driving management concerns about increased use in the rest of Katmai Park. Promotion of Brooks by the bear cams and the Fat Bear Contest have drawn more attention and increased visitation to Brooks. If the Park is concerned about increasing use in the backcountry, the BCMP needs to be sensitive to the effect of modern info technology and online content attracting visitors to the wilderness.The visitor days in the Moraine Creek drainage were flat and consistent from 2011 through 2015 at about 3,500 visitor use days. The number dropped significantly during 2016 to 2018 to about 2,500 before a single season increase to 4,000. With 4,000 visitors spread over a 75-day period (July, August, and part of September) averages 53 people per day. This is not a large number of users of an area inside the Preserve that has over 20 miles of traditionally used waters for fishing and bear viewing.An example of proactive measures without limiting access is as follows: Hallo Bay received its most visitors in 2015. At that time Katmai Service Providers sponsored pre-season operator meetings encouraging consistent field practices such as utilizing consistent routes, slowing down and sitting down, merging groups to avoid stress when near bears, agreed time of day limits on some parts of the meadows, and spreading out commercial use to other locations.Although some locations such as Moraine Creek/Crosswind Lake receive increased visitor use during July and August to bear view and sport fish, the quality of the experience remains very high. We are able to provide a safe and enjoyable experience for our visitors while accessing these parts of the Preserve. We do not believe limiting use or creating a concession program is necessary and encourage the Park to continue to allow access as is currently managed. We have concerns about the wording in the presentation that stated: “Motorized vehicles and equipment, as well as mechanical transport use in the wilderness, will be limited to the minimum necessary authorized activities.” This needs clarification – is it boats, airplanes, generators, or other?We currently do not support a limitation on number or timing of aircraft accessing sites in the backcountry. If limitations are considered as BCMP options, there must be a clearly defined process addressing such items as: visitor use data, historical use by CUAs, and seasonal use patterns, etc.
Human-Wildlife Interactions and Potential Conflict. The Katmai bear population is one of the healthiest and best protected bear populations in the world. These lands are ours to utilize and enjoy. Visitors to the Katmai backcountry will continue to have interactions at some extent with bears. The BCMP Newsletter states, “Increasing visitation may affect animal physiology and behavior, movement patterns, compromise overall wildlife health, and diminish visitor safety.” Our responsibility as users and managers is to promote visitor behavior and field practices that avoid negative interactions while we enjoy the wilderness. We can all generally agree with that goal, but how NPS staff at Brooks and commercial operators in the backcountry achieve that goal are sometimes significantly different. We believe that the excellent history of operators in Katmai backcountry via the CUA permit process shows that guided activities are safe and have a very low impact.We can be sensitive to bears’ needs without unnecessarily restricting the use of good judgement in the field. Recognizing the value of best practices and the challenge of learning the necessary field skills, KSP initiated an enhanced guide training program in 2018 that emphasized safety, interactions with bears and interaction with different user groups. This online program and along with a test at the end is a valuable and useful tool we encourage Park to recognize and implement. Daily survival is what a bear is working to achieve and Katmai is the best habitat in the world. Overemphasis on access restrictions based on the premise that human interaction with bears might affect the bears physiology and behavior is unwarranted. Commercial operators have and continue to operate in a manner that has as minimal impact as possible while safely viewing, studying, and enjoying the bears of Katmai. It is in our best interest to ensure that the habitat remains intact, healthy, and that our human footprint is as minimal as possible. The only way to have a “zero” impact is to shut down access completely. The continued record returns of salmon to the rivers of Katmai ensures the bear population is extremely healthy and with 4.13 million acres of land they have massive habitat to roam. We would like to see the park do more visitor use studies such as the Park service's 3 year study in Geographic Harbor & Hallo Bay (Troy Hamon) and the Tom Smith & Steve Partridge study at Hallo Bay in 1998/1999/2001. If the Park Service has additional study results available such as information from the recent 3 year collar study which focused on the bear human interactions on the third year and information on the study in Katmai Bay that the public can access the supporting data available on a resource page on the Backcountry Management site. A section on Anilca would be valuable. We feel good accurate data is critical in forming the management plan and going forward for future planning. It is critical to assemble our best data to keep an eye on things going forward.Thousands of people visit the Katmai backcountry annually with no problems even though there is a wide spectrum of possible interactions with wildlife, and potential for hazardous or neutral interactions, largely depending on experience level and choices made by people. Negative incidents can be reduced by providing the public with easily accessible information and education on best practices before they go to the field. Online video material focused on backcountry visitor activities might be useful, similar to the Brooks orientation materials. The risk here is that doing so might inadvertently attract more inexperienced people to the backcountry. KSP recognizes that CUA's deliver the largest percentage of people to the backcountry therefor we and our clients have a responsibility to employ practices that minimize negative impacts.Management of Commercial Services as Visitor Demand Increases. Is the Park looking to limit the number of Commercial Use Authorization permits it issues? KSP does not support changing Katmai commercial use management to a park wide concessions system or limited use approach. We think the CUA program has been successful and is appropriate, uncomplicated, and accessible for new operators. The current use numbers do not show a need to progress to a Concessions system. The current Commercial Use Authorization permit requirement and compliance with the Compendium and Park Specific Stipulations has some flaws but there is no need to add further limitations on access or burdensome regulations. There is no evidence we are aware of where there has been degradation of habitat from human access anywhere in the backcountry. We are strongly against Park managers closing areas without warning (for example, closures at Brooks without notice) – it is disruptive to businesses and their clients. If site closure is contemplated as an appropriate management tool in the BCMP. At locations where the BCMP indicates that use levels require a management action be taken, we recommend developing a Site Specific Protocol.The existing Site Specific Protocol in Geographic Harbor addressed the issue of increasing visitor use in a high bear-use area by utilizing an existing management tool. It provides for more predictable and consistent human behavior which clearly benefits the bears. As evidenced by the Geographic protocol area, sites with high bear use and high visitor use can be successfully managed for the benefit of both bears and humans.Challenges for Managing Wilderness and Backcountry Areas with Limited Staff across Millions of Acres and ANILCA Wilderness Complexities
From the Park presentation: “The plan is needed to safeguard wilderness character, address the effect of concentrated and increasing visitation, and to provide guidance and direction for managing commercial and private visitor use.” If the BCMP continues to use the current management approach (CUA for commercial operators) in Katmai National Park and Preserve and the Alagnak Wild and Scenic River, while including enhanced education tools (such as online access to best bear viewing practices) these planning goals will be satisfied. In areas the Park Service can't police, commercial operators with high professional standards can assist the park in maintaining good field practices by visitors. KSP Guide Excellence Program as well as the Hallo Bay pre-season meetings among operators visiting Hallo Bay which were initiated by KSP to reduce visitor impact on wildlife and increase cooperation among commercial users. These are some of the goals stated in the back country management plan. Utilizing KSP and the tools we have is encouraged. Not only are Katmai Service Provider members are engaged and very active with regards to protecting the habitat and resources that we depend upon for the success of our business, but we are also operators that have a passion for what we do and the place we operate. We are caretakers of the land and water, and we see it as our responsibility to protect it while at the same time utilizing the resource and bringing people to this region. We would be the first ones to tell you if we felt there was a serious problem with managing the resource under the present format.
Thank you,
Katmai Service Providers, Inc KSP Members
The following is the letter I sent over to the Governor. Will let you know if I get any feedback.
Brian Kraft
April 7, 2020
Governor Mike Dunleavy, The Katmai Service Providers, Inc is comprised of 62 businesses that operate throughout Katmai National Park as well as the Greater Bristol Bay region. We are owners of air taxis, lodges, guide services, and Eco tourism companies that help contribute over $300M a year into state revenue. We work closely with the Superintendent of the Park to help guide policy and long-term vision for the region with regards to sustainable healthy businesses. Our membership is comprised of small businesses that generally do not carry forward large amounts of capital. We are all grappling with the COVID-19 situation that has sickened many, taken lives, and crippled the economy. We are keenly aware of the concerns that many people and tribal entities have expressed with regards to the commercial fishery that takes place in Bristol Bay. We are also aware of the impact that an outbreak of COVID-19 could have in a small community that has a large influx of people in a very short period of time. It is crucial for your office to understand the vast difference between the commercial fishery and its impact on local communities versus the sport fishing and tourism-based businesses that also operate in the Katmai / Bristol Bay region. The Commercial fishery of Bristol Bay requires a massive labor force that arrives into the region in large numbers very quickly. Some of that labor force will begin to arrive in the coming weeks with large pushes of labor arriving by late May. There is also a tremendous lead time in preparation for the season by the canneries and support businesses. Additionally, the Commercial season is actually quite short in duration from Mid-June to Mid-July and cannot be put on pause nor delayed. The fish are going to arrive when nature dictates and once they are out of the ocean there is lost economic opportunity for the commercial fleet. Thus, it makes the commercial industry an “All or Nothing” scenario. It is not like they can delay the season to mid-July. If they do not have everything in place when the fish arrive the season will be a bust. The interaction of the imported workforce into the local communities is quite overwhelming and it is understandable that the communities of Dillingham, King Salmon, and NakNek are very concerned about this pending surge of people. Compared to the Tourism based industries such as bear viewing, sport fishing lodges, air taxi’s, and photography tours, where we can delay the start of our season and still have somewhat of a successful season. Additionally, the physical preparation needed to “open” these businesses is minimal with most being able to open for business within days. The biggest difference is for the most part many of our businesses can operate without ever impacting or interacting within any of the larger communities such as King Salmon, NakNek, Dillingham, Iliamna. Nor would we need to interact in any of the smaller villages in the region. Where interaction is necessary there can be protocols put in place and easilyadhered to since you are not looking at thousands of people moving into a region at a time but rather a few people potentially moving through as they make their way to a lodge or some other remote location.The lodges themselves are self-contained operations and can virtually eliminate any interaction with any of the villages. The air taxi’s with bear viewers and photographers transport people to the most remote parts of the Park and have no interaction with Bristol Bay communities. We are not callously approaching this situation and all of our businesses are making plans and looking at protocols to operate safely. We are hopeful that rapid testing becomes available that would allow testing to be done on travelers prior to making their way to a lodge or to the region. This would greatly improve confidence and allow for a testing protocol to ensure safe operations. As far as the concerns of the commercial fishery opening and requests for your office to shut down the Bristol Bay commercial fishery, we want to make sure you take a calculated specific approach with regards to our business sector and if warranted, consider incremental steps as we approach the season opener of June 8. We urge you to look at alternatives to a complete closure for the entire season at any one point in time and urge your office to take a wait and see approach as we get closer to our season. It is a fast-moving fluid situation and new data is becoming available each day. There are breakthroughs in testing procedures as well as potential remedies for COVID that would make it acceptable to safely openbusinesses throughout the country. It is difficult at this point in time now to predict what things will look like in June let alone July, August, or September. I am available for any questions or discussions. Thank you for your time and attention to our situation.
Brian KraftPresidentKatmai Service Provider’s, Inc.907-227-8719Brian@fishasl.com
I heard back from Senator Murkowski’s office regarding our concerns with the shortcomings with the PPP loan program. Ann Roberston has been very responsive and I suggest all our members reach out to her to request funding for summer seasonal operations. Here email is:
Ann_robertson@murkowski.senate.gov
For reference here below are suggestions that have been made to her and would be good for others to send similar requests:
Allow summer seasonal businesses to take 2019 total payroll and divide that number by 4 to arrive at a monthly average and multiply by 2.5 (this encompasses the bulk of seasonal business payroll). This will cover a large portion of anticipated payroll and allow small businesses to keep employees even when revenue is down.
Support modifications to existing loans through refinancing or gapping payments with short term funding through the SBA to apply payments towards. So the SBA would provide 12 months’ worth the amount of an existing business loan that a company already has. This SBA funding would be at a 5 year term at 1% with no prepayment penalty.
Regional funding for tourism based operations if seasons are canceled or impacted due to COVID-19 that would be granted at 40% of the average for the last three years revenue. For instance a company has an average of $1,000,000 in revenue for the last three years. The company would receive a grant for $400,000. Or if it had to be a SBA loan it could be paid back at a favorable rate similar to the PPP. This money would be used for existing business operations and covering expenses to make sure we are able to progress and open for business in 2021.
The attachment on this e-mail is a good PDF that shows the different loans available to small businesses and what the differences are.
Brian Kraft-PresidentKatmai Service Providers KSP Members
The following is the letter I sent over to the Governor. Will let you know if I get any feedback. Brian Kraft
April 7, 2020
Governor Mike Dunleavy, The Katmai Service Providers, Inc is comprised of 62 businesses that operate throughout Katmai National Park as well as the Greater Bristol Bay region. We are owners of air taxis, lodges, guide services, and Ecotourism companies that help contribute over $300M a year into state revenue. We work closely with the Superintendent of the Park to help guide policy and long-term vision for the region with regards to sustainable healthy businesses. Our membership is comprised of small businesses that generally do notcarry forward large amounts of capital. We are all grappling with the COVID-19 situation that has sickened many, taken lives, and crippled the economy. We are keenly aware of the concerns that many people and tribal entities have expressed with regards to the commercial fishery that takes place in Bristol Bay. We are also aware of the impact that an outbreak of COVID-19 could have in a small community that has a large influx of people in a very short period of time. It is crucial for your office to understand the vast difference between the commercial fishery and its impact on local communities versus the sport fishing and tourism-based businesses that also operate in the Katmai / Bristol Bay region. The Commercial fishery of Bristol Bay requires a massive labor force that arrives into the region in large numbers very quickly. Some of that labor force will begin to arrive in the coming weeks with large pushes of labor arriving by late May. There is also a tremendous lead time in preparation for the season by the canneries and support businesses. Additionally, the Commercial season is actually quite short in duration from Mid-June to Mid-July and cannot be put on pause nor delayed. The fish are going to arrivewh en nature dictates and once they are out of the ocean there is lost economic opportunity for the commercial fleet. Thus, it makes the commercial industry an “All or Nothing” scenario. It is not like they can delay the season to mid-July. If they do not have everything in place when the fish arrive the season will be a bust. The interaction of the imported workforce into the local communities is quite overwhelming and it is understandable that the communities of Dillingham, King Salmon, and NakNek are very concerned about this pending surge of people. Compared to the Tourism based industries such as bear viewing, sport fishing lodges, air taxi’s, and photography tours, where we can delay the start of our season and still have somewhat of a successful season. Additionally, the physical preparation needed to “open” these businesses is minimal with most being able to open for business within days. The biggest difference is for the most part many of our businesses can operate without ever impacting or interacting within any of the larger communities such as King Salmon, NakNek, Dillingham, Iliamna. Nor would we need to interact in any of the smaller villages in the region. Where interaction is necessary there can be protocols put in place and easily adhered to since you are not looking at thousands of people moving into a region at a time but rather a few people potentially moving through as they make their way to a lodge or some other remote location. The lodges themselves are self-contained operations and can virtually eliminate any interaction with any of the villages. The air taxi’s with bear viewers and photographers transport people to the most remote parts of the Park and have no interaction with Bristol Bay communities. We are not callously approaching this situation and all of our businesses are making plans and looking at protocols to operate safely. We are hopeful that rapid testing becomes available that would allow testing to be done on travelers prior to making their way to a lodge or to the region. This would greatly improve confidence and allow for a testing protocol to ensure safe operations. As far as the concerns of the commercial fishery opening and requests for your office to shut down the Bristol Bay commercial fishery, we want to make sure you take a calculated specific approach with regards to our business sector and if warranted, consider incremental steps as we approach the season opener of June 8. We urge you to look at alternatives to a complete closure for the entire season at any one point in time and urge your office to take a wait and see approach as we get closer to our season. It is a fast-moving fluid situation and new data is becoming available each day. There are breakthroughs in testing procedures as well as potential remedies for COVID that would make it acceptable to safely open businesses throughout the country. It is difficult at this point in time now to predict what things will look like in June let alone July, August, or September. I am available for any questions or discussions.Thank you for your time and attention to our situation..
Brian KraftPresidentKatmai Service Provider’s, Inc.907-227-8719Brian@fishasl.com
I heard back from Senator Murkowski’s office regarding our concerns with the shortcomings with the PPP loan program. Ann Roberston has been very responsive and I suggest all our members reach out to her to request funding for summer seasonal operations. Here email is:
Ann_robertson@murkowski.senate.gov
For reference here below are suggestions that have been made to her and would be good for others to send similar requests:
Allow summer seasonal businesses to take 2019 total payroll and divide that number by 4 to arrive at a monthly average and multiply by 2.5 (this encompasses the bulk of seasonal business payroll). This will cover a large portion of anticipated payroll and allow small businesses to keep employees even when revenue is down.
Support modifications to existing loans through refinancing or gapping payments with short term funding through the SBA to apply payments towards. So the SBA would provide 12 months’ worth the amount of an existing business loan that a company already has. This SBA funding would be at a 5 year term at 1% with no prepayment penalty.
Regional funding for tourism based operations if seasons are canceled or impacted due to COVID-19 that would be granted at 40% of the average for the last three years revenue. For instance a company has an average of $1,000,000 in revenue for the last three years. The company would receive a grant for $400,000. Or if it had to be a SBA loan it could be paid back at a favorable rate similar to the PPP. This money would be used for existing business operations and covering expenses to make sure we are able to progress and open for business in 2021.
The attachment on this e-mail is a good PDF that shows the different loans available to small businesses and what the differences are.
Brian Kraft-PresidentKatmai Service ProvidersToday I spoke to my State of AK House representative today, Laddie Shaw in Juneau, and relayed the message that all operators in Bristol Bay –KSP members—are starting to feel the pinch with real and potential cancelations. I informed him of the huge upfront expenses our businesses have in preparation for the season and that this money is spent from clients deposits that are now asking for refunds. I asked the he have the Governor declare a state of emergency for Alaska and the Bristol Bay Sport and Commercial fisheries ahead of the season so that we can prepare and get in line as there will be many businesses doing the same thing. I relayed the message that we understand that the airline and cruise ship industries need a bail out but that it is the small business owner in Alaska that fuels the local economy and we will need help. I encourage all Alaskans that do business in Katmai/Bristol Bay to call their reps in Juneau and tell them we need help. Tell them we want access to SBA zero or low interest loans to get us through this crisis. If you do not live in Alaska yet operate in the Katmai/Bristol Bay area, contact Representative Bryce Edgmon (he reps Bristol Bay and Speaker of the House) and tell him your business that brings economic benefit to the region will need help. Representative.Bryce.Edgmon@akleg.gov Or by phone at 800-898-4451 To all Katmai Service Provider members-
I wanted to take a moment to write to all of you to express hopes for all to have a safe and profitable season. The COVID-19 virus has put both of those in jeopardy. Although the season opener of June 8 is 83 days from the writing of this email and many trips happen in July, August, or September, my company is starting to receive cancelation inquires. Although I am an optimist and hope we get this thing under control in the next month, I believe it is prudent that we all start to prepare for what would be a catastrophic event to our businesses with massive cancelations if the virus persists. Katmai Service Providers has proven over the years to be a valuable and strong organization when speaking to decision makers. Strength is in numbers. To that end, I began discussions with the Commercial fishing industry and Bristol Bay Economic Development Corp in an effort to collectively pool our influence on our delegation to provide a financial relief package that is Bristol Bay centric. I would be embarking on this effort on behalf of Katmai Service Provider members. The idea being that we show the importance of making all tourism and commercial fishing businesses that will be severely affected financially stable. Although it is appropriate to bail out the airlines and cruise industries that are hurting, we, the small business owners and our employees that depend upon our ability to pay them, will be the hardest hit.
Let me know if you have any questions or opinions on this.
Thank you,
Brian KraftPresident –Katmai Service Providers, INC