While all for increased transparency and broader local inputs for all users in the NOF this focus of lawsuits for relief from this continued reduction in recreational angler opportunities complete ignores the two underlying factors that are limit fishing; especially mixed stock fisheries.

The first is the question whether fishing represent a legitimate use of the underlying stock productivity of individual salmon stocks? And if so what portion of that historic Chinook productivity should go to fishing rather than to support other uses of that productivity (logging, development, agriculture etc.)? 50%, 20%, 10%?

The second is the continued decline in the status of PS Chinook and the resulting declining allowable impacts associated with fishing. In every status review of PS Chinook since their ESA listing has consistently found that the 3 major population parameters considered in the status of those populations; abundances, productivity and diversity, have consistently declined. Given the failure of recovery efforts it can not be a surprise that NOAA looks to lower allowable impacts associate with fishing.

In recent years the Stillaguamish Chinook has been one of the stocks limiting PS fishing; especially in mixed stock areas. When one considers the answers to my above questions it is clear why the Stillaguamish Chinook has been such limiting stock.

For the Stillaguamish that once supported and estimated 40,000 Chinook portion of that productivity reserved for fishing is now less than 1% and if one considers public input for society (letters to the editor, input at various public meetings, etc.) we have determined that is too much and should be reduced further. To 0.0%?

Back envelope calculations seem to indicate for the Stillaguamish during the 1960s and early 1970s wild Chinook runs were in the 4,000 range. In the late 1970s through 1980s in the 1,500 to 2,000 range. From 1990 to 2009 run reconstructions should that in spite of average escapements of 1,500 spawners the average run-size (number adults that would return without any fishing) was less than 1,000 (933). Looking at fishing rates and escapements for the period 2010 to 2016 the average wild run likely fell to less than 600. In 2018 the total escapement of wild Chinook in the Stillaguamish was 117 fish (likely run size of less 160 fish). During those same periods Southern US (SUS) fishing rates fell from more than 50% to 35% to 21% to 15% to last year 8% but populations continue to fall.

Folks maybe able to win the court case battle but the harsh reality the war for stocks like the Stillaguamish has all ready been lost and other stocks are sure to follow. The end of mixed stock fishing is in sight with more and more of the fishing be forced to terminal areas with less critical wild stocks. The last 50 years have clearly demonstrated that we as a society do not have the political will for meaningful restoration and will also opt for ending fishing before taking other painful actions.

Curt