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Home My WebLink About2022-07-26 Council Packet - Special MeetingKenai City Council - Special Meeting Page 1 of 1 July 26, 2022 Kenai City Council - Special Meeting July 26, 2022 ꟷ 6:00 PM Kenai City Council Chambers 210 Fidalgo Avenue, Kenai, Alaska **Telephonic/Virtual Information Below** www.kenai.city Agenda A. CALL TO ORDER 1. Pledge of Allegiance 2. Roll Call 3. Agenda Approval B. PUBLIC HEARING 1. Resolution No. 2022-57 - Requesting the State of Alaska Commissioner of Fish and Game Allow the East Side Set Net Fishery Additional Opportunity to Harvest Sockeye Salmon During the 2022 Season. (Vice Mayor Glendening, Council Members Knackstedt, Pettey, Winger, Baisden and Sounart) C. NEW BUSINESS – None. D. PUBLIC COMMENT (Public comment limited to three (3) minutes per speaker; thirty (30) minutes aggregated) E. EXECUTIVE SESSION – None. F. ADJOURNMENT The agenda and supporting documents are posted on the City’s website at www.kenai.city. Copies of resolutions and ordinances are available at the City Clerk’s Office or outside the Council Chamber prior to the meeting. For additional information, please contact the City Clerk’s Office at 907-283-8231. Join Zoom Meeting OR https://us02web.zoom.us/j/83327435902 Dial In: (253) 215-8782 or (301) 715-8592 Meeting ID: 833 2743 5902 Passcode: 841223 Meeting ID: 833 2743 5902 Passcode: 841223 Page 1 Sponsored by: Vice Mayor Glendening, Council Members Knackstedt, Pettey, Winger, Baisden and Sounart New Text Underlined; [DELETED TEXT BRACKETED] CITY OF KENAI RESOLUTION NO. 2022-57 A RESOLUTION REQUESTING THE STATE OF ALASKA COMMISSIONER OF FISH AND GAME ALLOW THE EAST SIDE SETNET FISHERY ADDITIONAL OPPORTUNITY TO HARVEST SOCKEYE SALMON DURING THE 2022 SEASON. WHEREAS, the City of Kenai benefits from well-managed salmon runs as a central part of its economy and quality of life; and, WHEREAS, all user groups within the City: sport; personal use; subsistence and commercial benefit from healthy sustainable runs in the Kenai River; and, WHEREAS, the City supports the implementation of fisheries regulations based on sound science and research-based biology intended to achieve a maximum sustainable yield providing for the highest possible number of returning salmon and greatest opportunity for all user groups; and, WHEREAS, sockeye salmon runs in both the Kenai and Kasilof Rivers are currently projected to exceed escapement goals; and, WHEREAS, personal use fishermen, sport fishermen, and the commercial drift fleet are all currently permitted to harvest sockeye salmon with expanded opportunities including sport fish limits of six per day and 24 hour a day personal use opportunities; and, WHEREAS, in-river guides also have opportunities to guide clients for sockeye salmon; and, WHEREAS, the only user group currently denied any opportunity to harvest sockeye salmon are the East Side Setnet fisheries participants; and, WHEREAS, there are over 400 East Side Setnet Permit holders in the Upper Cook Inlet, with close to 90 percent Alaska Residents and approximately 80 percent of those Alaskans residing on the Kenai Peninsula Borough; and, WHEREAS, the East Side Setnet fishery has a long history in the City of Kenai preceding Statehood; and, WHEREAS, the East Side Setnet fishery provides direct employment opportunities, is a critical business component of local seafood processors and supports numerous other local businesses through its activities; and, WHEREAS, in 2021, more than one million sockeye in excess of escapement goals entered the Kenai River resulting in economic opportunity costs estimated to be $80 million dollars; and, WHEREAS, the current late run king salmon return in the Kenai River is projected to meet escapement goals within an allowable margin of error using the Alaska Department of Fish and Game timing scenarios if the run is two days or more late; and, Page 2 Resolution No. 2022-57 Page 2 of 2 New Text Underlined; [DELETED TEXT BRACKETED] WHEREAS, Department of Fish and Game harvest data shows that only 32 late run Kenai River large king salmon were harvested in the East Side Setnet fishery through July 14, 2022 representing a very small fraction of a percent of needed escapement; and, WHEREAS, while all user groups are targeting sockeye, all incidentally catch king salmon while conducting their fisheries; and, WHEREAS, allowing all other user groups to continue to harvest sockeye with increased fishing opportunities while completely prohibiting the East Side Setnet fishery to harvest sockeye is inequitable, does not appear to be scientifically based, will result in economic disaster for some East Side Fishermen and negatively impacts the economy of the City of Kenai. NOW, THEREFORE, BE IT RESOLVED BY THE COUNCIL OF THE CITY OF KENAI, ALASKA: Section 1. That the City Council of Kenai requests the Commissioner of the Alaska Department of Fish and Game to authorize further sockeye salmon fishing opportunity for the East Side Setnet fishery during the 2022 season. Section 2. That a copy of this Resolution be forwarded to the State of Alaska Commissioner of Fish and Game, all members of the Board of Fish and Governor Mike Dunleavy. Section 3. That this Resolution takes effect immediately upon passage. PASSED BY THE COUNCIL OF THE CITY OF KENAI, ALASKA, THIS 26TH DAY OF JULY, 2022. ___________________________________ ___________________________________ Jim Glendening, Vice Mayor Henry Knackstedt, Council Member ___________________________________ ___________________________________ Glenese Pettey, Council Member Teea Winger, Council Member ___________________________________ ___________________________________ James Baisden, Council Member Deborah Sounart, Council Member ATTEST: ___________________________________ Michelle M. Saner, MMC, City Clerk Page 3 Kenai Penins ula Fislt er111 e11 's Association Emuri11g IM Susuunab/111)• of 011r Fl5lrtf)' Rnouru~ July 20, 2022 4)961 Kalifom<Ay B~ach Road • Suite F • Sol1/0111n, ,1/as Aa 99669...f276 (907) 161-1'91 • Fa..: (907) 161-1898 • E Mail: tp/~ nlnJtn.ntt P RESS R E L EASE The Kenai Peninsula Fishermen's Association (KPFA), is a non-profit 501(c) (6) commercial fisheries advocacy trade group representing Cook lnlel (Cl) fishing fami l ies since 1954. KPFA 's mission is "E n surin g the S u s taina b ili ty of Our Fis h ery R eso urces." Our goal is to continue to strengthen our fishing community and to promote the economic stability of the Cook l nle1 Setnet Fishery. KPFA primarily represents salmon setnet pem1i1 holders on the East Side of Cook Inlet. Tbe geographical area of the fishery reaches from the soutb at Nini.lch.ik to Boulder Point in the north , spanning more than 60 miles a long Cook Lnlct's Eastside. The sa lmon harvested by the East Side Setnet Fishery originate a lmost exclusively in the Kasilof and Kenai River systems. Some 440 limited entry permit holders, each one a small businessperson, fish for sahnon in this area and are primarily Alaska residents. Eighty-six percent of the permit holders are Alaska residents , and eighty percent of those Alaskans live locally on the Kenai Peninsu la. Our correspondence today is to express the Kenai Peninsula Fishermen's Association's extreme concern for the recent action by the Alaska Department of Fish and Game (ADFG) to close the Kenai River to king salmon fishing. This action immediately c losed the doors oftbe businesses of more than 400 families who work in th e Upper Cook Inl et Sernet fishery! Revenue s from these bu s inesses not on ly suppo rt their fi shing families, but also trickle down to a web of loca l businesses, including fish processors, fish tenders, truck drivers, mechanics , wel ders, fuel sellers, boat builders, and gear, grocery and Page 4 hardware stores . among many others. T h e Jos s of the fi s hery wi ll do irreparable harm not only to the fishermen who will lose their live li hoods but also to the Kenai Peninsula's economy and food security. The nearly identical fishery closure th at cook place las t year e li minated an estimated 80 m illion dollars that would have c irculated into the local Kenai Peninsula economy. Of a ll the user groups who harvest s almon in Cook lnlet -sport anglers, dip-ne tters, drift gill netters, s ub s istence fishermen , and professional guides, once again 011/y the Eas t S ide setnet famil y busine sses have been pulled from the water and forced to shutter their businesses. The ADFG is cit ing k ing conservat ion to justify this closure. Their actions are guaranteeing ye1 another economic dis aster for the East Side setne tters. To take an action that imposes such dire circumstances on only these fi shermen, one would think that the setne tters' harvest must severel y impact the nm. This is not true! To date, the total number of k ing salmon harvested by setne tters fishing on the 60 miles of beach from Ninilc hik to Boulder Point is a to ta l of32 large Late Run Kenai Kings. Those 32 k ing salmon represent 0 .2% of the king run. So, under the direction of Governor Mike !Dunlea vy 's Fish and Game Commiss io ner, the Alaska Department of Fish and Game is closing the Kenai Ri ver to king salmon fishing and sending a century- o ld sector of the Kenai Peninsu la 's economy in to economic collapse while putting more than 99 percent of the rentming large late run Kenai kings in to the river. For the pas t few days, the king numbers have been increasing. F ish and Game Commissioner Doug V incent-Lang bas sta ted that he will reopen the East S ide Setnet fi s hery if the department projects mee ting the 2020 Board of Fish impos ed Optimum Escapement Goal (OEG) of 15,000 Late Run Kenai River Large kings. The commissioner bas the auth ority to open the fi shery in emergency like this yet he refuses, c iting fear of a lawsuit. \Vhile be waits to confirm that the OEG will be me t, there is certain hann coming to thos e natal rivers where the kings and sockeye rear. The Peninsula's sockeye salmon population is being put in jeopardy. To date, the Kasilof Ri ver is projected to reach 761 ,000 returning sockeye, which is 441 ,000 s ockeye over the upper end of the escapement goal and is on track to no t replace itself. Commiss ioner Doug Vincent-Lang is w illing to devas tate fu ture sockeye return s for 0.2% of the king run! The biological escapement goal for Kasilof R iver sockeye Page 5 salmon of 140,000 to 320,000 has been exceeded! Additionally, the Kenai Ri ver is currently on track to exceed its sockeye goals if setnetters are kept on the beach. These nuniti\1e actions are endangering future socke\'C runs for ALL us.ers. \Ve believe in managing our fishery to the scientific biological goals set forth by the Alaska Department of Fish and Game which is a Sustainable Escapement Goal (SEG) of 13,500 late run Kenai Ri ver large kings. Wh il e the department waits to make the call on the nin strength based on the Board of Fisheries imposed seemingly unattainable OEG of 15 ,000 large Kings, 400 family fishing businesses w ill be waiting on the bea ch asking to be allowed to harvest their target species of sockeye. The eagerly ant icipated order to fi sh this season will provide much needed economic re lief and social well -being for their fam ilies and will also prov ide relief from the certain catas trophic sockeye over escapements in to rhe Kasilof and Kenai Rivers. The setnet fishery cannot survive w ithout meaningful fishing oppormnity. It 's sad that Governor Dunleavy hangs his hat on Alaska being open for business, w hile he continues to close a 140-year-old fi shery year after year. His actions speak louder than words! The Kenai Peninsula Fishermen's Association Board of Direc tors Page 6 JULY 26, 2022 CITY COUNCIL SPECIAL MEETING ADDITIONAL MATERIAL/REVISIONS REQUESTED ADDITIONS TO THE PACKET: ACTION ITEM REQUESTED BY Add to item B.1 Resolution No. 2022-57 • Public Comment City Clerk Padgett 855 Ames Road Kenai, Alaska 99611 Monday, July 25, 2022 City of Kenai Planning & Zoning Department 210 Fidalgo Avenue Kenai, AK 99611 RE: Resolution No. 2022-57 I would like to go on record as encouraging the City of Kenai to not pass Resolution No. 2022-57 related to fishery management. Fishery Management has finally progressed to include paired restr ictions related to Kenai River King Salmon. Kenai River King Salmon have suffered for years, and the State of Alaska Board of Fish has implemented measures that might provide hope for a continued July King Salmon run. I appreciate the complexity of the issue and am concerned about the political influence on biological issues. Given the Board of Fish position on the side of King Salmon conservation, I recommend that the City of Kenai support the Board of Fish decision. I am not anti-set net, simply pro King Salmon. Sincerely, Mack E. Padgett 907/350-2103 My name is Brian Koski. I am a lifelong Alaska resident and east side set netter. My Family has deep roots in the Kasilof area. My Grandparents and father homestead in the late 50’s and 60’s in clam gulch. We have had our set net site on K-Beach road sense 1967. This is a family operation. There has always been three generations fishing our nets since I was born. I am concerned with how ADF&G has managed this years Kasilof River run. I am distressed that with the current level of escapement into the river this will damage future runs for all user groups. I have never seen in my life 125K up the river in one day nor have my parents. They are projecting 900K+ in the Kasilof river. That is our entire run! The Kasilof river is a very small system compared to the Kenai River. It can not handle this much pressure. I fear this will result in the system crashing. This is all over a few large Kenai Chinook, from the Kenai River an entirely different river system. Brian Marston, Cook Inlet Commercial Fishing Manager, informed me that he is managing for a weak stock (Kenai river Chinook). There is no definition in 5 AAC 39.222 or 223, NOAA, North Pacific Management Counsel for weak stock management. I have reached out to the commissioner several times. The Commissioner has the authority to open up the Kasilof set net sites. I feel this is a politically motivated move on the Commissioner’s part. I feel that he is not upholding the duties of the office of ADF&G and is being negligent in his decisions. ADF&G is not being good stewards of this natural resource. I am urgently asking you to take a deeper look into this matter. People of all user groups are losing trust in the Department of Fish and Game. Upper Cook inlet ESSN Sockeye and Chinook Harvest My name is Brian Koski. I am a lifelong Alaska resident and east side set netter. My Family has deep roots in the Kasilof area. My Grandparents and father homestead in the late S0 1 s and 60 1s in clam gulch. We have had our set net site on K-Beach road sense 1967. This is a family operation. There has always been three generations fishing our nets since I was born. I am concerned with how ADF&G has managed this years Kasilof River run. I am distressed that with the current level of escapement into the river this will damage future runs for all user groups. I have never seen in my life 125K up the river in one day nor have my parents. They are projecting 900K+ in the Kasilof river. That is our entire run! The Kasilof river is a very small system compared to the Kenai River. It can not handle this much pressure. I fear this will result in the system crashing. This is all over a few large Kenai Chinook, from the Kenai River an entirely different river system. Brian Marston, Cook Inlet Commercial Fishing Manager, informed me that he is managing for a weak stock (Kenai river Chinook). There is no definition in 5 AAC 39.222 or 223, NOAA, North Pacific Management Counsel for weak stock management. I have reached out to the commissioner several times. The Commissioner has the authority to open up the Kasilof set net sites. I feel this is a politically motivated move on the Commissioner 1 s part. I feel that he is not upholding the duties of the office of ADF&G and is being negligent in his decisions. ADF&G is not being good stewards of this natural resource. I am urgently asking you to take a deeper look into this matter. People of all user groups are losing trust in the Department of Fish and Game. I have included data from the last 10 years for you to review. Kasilof Sockeye Escapement Goals 140,000-320,000 BEG Kenai River Sockeye goal 1, 100,000-1,400,000 In-river goa I Kenai River Late Chinook Goal (large Goal) 15,000-30,000 OEG 800000 700000 600000 500000 400000 300000 200000 100000 0 I I I I Kasilof In-river Escapement 140,000-320,000 1983-2022 1983 1984 1985 1986 1987 1988 1989 1990 19911992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 Current problem in the east side set net (ESSN) fishery is that the large chinook goal goes against 5 AAC 39. 222 (c) (2) C and D. (C) salmon escapement goal ranges should allow for uncertainty associated with measurement techniques, observed variability in the salmon stock measured, changes in climatic and oceanographic conditions, and varying abundance within related populations of the salmon stock measured; (D) salmon escapement should be managed in a manner to maintain genetic and phenotypic characteristics of the stock by assuring appropriate geographic and temporal distribution of spawners as well as consideration of size range, sex ratio, and other population attributes; The Current Kenai River Chinook goal isn't counting all sizes of chinook that pass by the sonar. On July 17, 2022, they closed the river to sport fishing for Chinook. ADF&G issued emergency order 2-KS-1-53-22. With this closure the ESSN are shut down until further notice. The Commissioner has the authority to open or close any fishery. 5 AAC 21.363 (e) (e) Notwithstanding any other provision of this chapter, it is the intent of the board that, while in most circumstances the department will adhere to the management plans in this chapter, no provision within a specific management plan is intended to limit the commissioner's use of emergency order authority under AS 16.05.060 to achieve established escapement goals for the management plans as the primary management objective. For the purpose of this subsection, "escapement goals" includes inriver goal, biological escapement goal, sustainable escapement goal, and optimal escapement goal as defined in 5 AAC 39.222 The commissioner has several options in the Kasilof district to open fishing with little large Kenai chinook harvest. Kasilof district 600' Kasilof district Yz half mile Kasilof district During 2015-2016 a genetic study was done with the whole ESSN fishery. In 2015they fished the Kasilof district 600' 5 times. We caught 88674 sockeye and 32 large Kenai chinook harvested. 600' Ninilchik Coho South K beach 15-Jul 7571 4908 7117 19-Jul 13636 6228 7907 21-Jul 9079 4346 8134 28-Jul 7091 2875 2833 31-Jul 2822 1989 2138 Total 19596 27771 21559 12799 6949 88674 sockeye Chinook toal 15-Jul 19596 35 19-Jul 27771 so 21-Jul 21559 49 28-Jul 12799 23 31-Jul 6949 9 166 Out of 166 harvested chinook 32 are Kenai river large chinooks. Eastside Set Gillnet Chinook Salmon Harvest Composition in Upper Cook Inlet, Alaska, 2016, Including Large Fish Harvest for 2015 and 2016 https:Uwww.adfg.alaska.gov/FedAidPDFs/F 0517-50.pdf PAGE 36 Kasilof River Escapement and Harvest In the Kasi lof District Kenai Chinook Escapement 2013-2022 Currently the Optimal Escapement goal is 15,000-30,000 Large chinook greater 75cm In 2018 the goal was BEG 13,500-27,500 large Chinook greater than 75cm 2013 was 15,000-30,000 All Size goal. Kasilof River and Kenai River All size Chinook Harvest in ESSN Ci) c: 0 .§. :E Q) > ~ +: c: G> .... 0 Q, Maximum Sustainable Yield for the Kasilof River co <O ~ N 0 0 1 Kenai River 2 3 4 I.() 0 0 0 0 .0 0 .2 Trial Spawning Abundance (millions) Kasilof River 0 .4 0 .6 0 .8 Figure 14 . imulatcd potcnlial yield for the autorcgrc i c Ricker model aero a range of trial spa\ ning abundan e . The red line indicate the m dian cxpcctation. \ hile the dark and light shaded region indicate the 50 0: and 95 % credible interval for predictions . Da hed line de cribc predicted . m y and MSY for each tock . -If) c 0 E - Maximum Sustainable Yield for the Kenai River. Kenai River Kasilof River co 0 <O 0 N "" 0 N 0 0 0 0 0 1 2 3 4 0 .0 0.2 0.4 0 .6 0.8 1.0 Trial Spawning Abundance (millions) Figure 10 . Simulated potential icld for the brood car i ntcra c lion Ricker (mai n cffecl \'crs ion model acros a ran g e of trial spawning abundance . The red line i ndicate the median expectation . while the dark and light haded region indicate the O'k and 95 'k c redible i nlcr al s for prediction . Da hed line de cribe predicted Sm y and MSY for each lock . 2012 UPPER COOK INLET COMMERCIAL SALMON FISHERY SEASON SUMMARY https:/fwww.adfg.alaska.gov/static/applications/dcfnewsrelease/237160620.pdf Upper Cook Inlet Commercial Fisheries Annual Management Report, 2012 https://www.adfg.alaska .gov/FedAidPDFs/FMR13-21.pdf Upper Cook Inlet Commercial Fisheries Annual Management Report, 2013 https:ljwww.adfg.alaska.gov/FedAidPDFs/FMR13-49.pdf Upper Cook Inlet Commercial Fisheries Annual Management Report, 2014 https:/fwww.adfg.alaska.gov/FedAidPDFs/FMR15-20.pdf Upper Cook Inlet Commercial Fisheries Annual Management Report, 2015 https://www.adfg.alaska.gov/FedAidPDFs/FMR16-14.pdf Upper Cook Inlet Commercial Fisheries Annual Management Report, 2016 https://www.adfg.alaska.gov/FedAidPDFs/FMR17-05.pdf Upper Cook Inlet Commercial Fisheries Annual Management Report, 2017 https:ljwww.adfg.alaska.gov/FedAidPDFs/FMR18-10.pdf Upper Cook Inlet Commercial Fisheries Annual Management Report, 2018 https://www.adfg.alaska .gov/FedAidPDFs/FMR19-25.pdf Upper Cook Inlet Commercial Fisheries Annual Management Report, 2019 https://www.adfg.alaska.gov/FedAidPDFs/FMR21-26.pdf 2020 Upper Cook Inlet Commercial Salmon Fishery Season Summary https:ljwww.adfg.alaska.gov/static/applications/dcfnewsrelease/1231395611.pdf 2021 Upper Cook Inlet Commercial Salmon Fishery Season Summary https://www.adfg.al a ska. gov I st a ti c/appl i cations/ dcfn ewsrel ease/134666865 7. pdf References Eastside Set Gill net Chinook Salmon Harvest Composition in Upper Cook Inlet, Alaska, 2016, Including Large Fish Harvest for 2015 and 2016 https://www.adfg.alaska.gov/FedAidPDFs/FDS17-50.pdf Pages 58-59 show in late july we don't catch that many large Kenai Kings Exploration of Overcompensation and the Spawning Abundance Producing Maximum Sustainable Yield for Upper Cook Inlet Sockeye Salmon Stocks https:ljmeetings.npfmc.org/CommentReview/DownloadFil e?p=5671087c-4793-461a-8c25-856f1776987c.pdf&fi leName=D2%20(SSC%20Review)%200vercompensation%20analysis.pdf From:Naomi Daigle To:City_Council Subject:Comment on tonight’s meeting Date:Tuesday, July 26, 2022 5:45:29 PM CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking links, especially from unknown senders. Public Comment for the City Council meeting on July 26, 2022. My name is Naomi Daigle. I grew up in Kenai. The beaches by the river were my stomping grounds. I return to share my young sons with my parents who still reside here. I married a commercial fisherman from Homer and together for over a decade we have owned permits on the East Side. We have seen the abundance of the sockeye run, faced the weather of Cook Inlet, appreciated the beauty of the Kenai kings, endured the despair we all faced at their decreased numbers, and withstood the seeming endless discouragement the East Side Setnetters face with gear limits, gear restrictions, and closures. In the winter my family lives in Homer where my husband runs a boatbuilding business and I care for our small children. It is financially difficult to own a set net operation and not be permitted to fish. On a year with low kenai king abundance our sites catch few to no kings. I support this resolution. Thank you to all who brought this together. Sincerely, Naomi Daigle Sent from my iPhone Kenai City Council - Special Meeting Page 1 of 1 July 26, 2022 Kenai City Council - Special Meeting July 26, 2022 ꟷ 6:00 PM Kenai City Council Chambers 210 Fidalgo Avenue, Kenai, Alaska **Telephonic/Virtual Information Below** www.kenai.city Action Agenda A. CALL TO ORDER 1. Pledge of Allegiance 2. Roll Call 3. Agenda Approval B. PUBLIC HEARING 1. ADOPTED AS AMENDED UNANIMOUSLY. Resolution No. 2022-57 - Requesting the State of Alaska Commissioner of Fish and Game Allow the East Side Set Net Fishery Additional Opportunity to Harvest Sockeye Salmon During the 2022 Season. (Vice Mayor Glendening, Council Members Knackstedt, Pettey, Winger, Baisden and Sounart) C. NEW BUSINESS – None. D. PUBLIC COMMENT (Public comment limited to three (3) minutes per speaker; thirty (30) minutes aggregated) E. EXECUTIVE SESSION – None. F. ADJOURNMENT The agenda and supporting documents are posted on the City’s website at www.kenai.city. Copies of resolutions and ordinances are available at the City Clerk’s Office or outside the Council Chamber prior to the meeting. For additional information, please contact the City Clerk’s Office at 907-283-8231. Join Zoom Meeting OR https://us02web.zoom.us/j/83327435902 Dial In: (253) 215-8782 or (301) 715-8592 Meeting ID: 833 2743 5902 Passcode: 841223 Meeting ID: 833 2743 5902 Passcode: 841223