Barry’s letter states clearly that NMFS will be reinitiating consultation under ESA for the PFMC fisheries, pursuant to the impacts on SRKW’s. They’ve been operating under a biological opinion written in 2009. A 10-year old bi-op is not likely to be very useful, given the new information on SRKW’s.

WFC knows this. That’s why they filed their Notice of Intent to sue. In my view, they have NMFS ‘over a barrel’.

The new bi-op from NMFS will get a lot of attention from WFC, and everyone else. My sense is that NPFMC (Alaska) is operating under the same 2009 bi-op as PFMC. Therefore, as goes PFMC, so goes NPFMC.

That is, the new bi-op will likely cover Chinook fisheries under both PFMC and NPFMC. The impacts from the various Chinook fisheries would need to be factored into the overall impacts to SRKW’s. A bi-op from NMFS must have a comprehensive analysis of all these fisheries, including those in BC (under the PST). If NMFS tries to “piecemeal it”, WFC will tear them limb-from-limb in court. And rightfully so.

The question now is whether, and to what extent, will 2019 Chinook fisheries be constrained by measures intended to help SRKW? I wasn’t able to get to all the PFMC discussions this past week, and weekend, in Vancouver, WA, so I’m not sure. But I’ll check.

My sense is that NMFS cannot escape imposing measures in 2019 to conserve Chinook (likely fall Chinook stocks) in the short-term while a new bi-op is being written. The troll fishery folks are likely facing more constraints in 2019, and perhaps beyond. And I would not be surprised to see recreational angling constraints as well, to the extent those fisheries occur in saltwater.