As a rule this is reasonable but fails to bring forth agency actions that if did not create the Fall Chinook impacts most certainly exacerbated it. Summerrun and Winter Steelhead smolt are planted at miles Dam Fish trap 50, 7400 line bridge 30, White Bridge 16, Industrial Intake 11, Black Creek 8. The reach of the river below Industrial Intake at mile 11 has substantial public access and the further upstream one goes access is greatly reduced. Logically the vast majority of the Summerrun Steelhead would be planted at river miles 8 and 11 but in 2019 only 19000 smolt were planted with an additional 16250 at mile 16. The upper reaches of the river with the least amount of public access received 29900. By utilizing the upper reaches planting sites to service a small portion of the angling community reduces the overall public angling quality. This is a short sighted rational as the returning adults will continue to work their way upstream but the fishes natural behavior is to return to the areas planted and stage up for some time before slowly working their way upstream. By planting the Summerrun Steelhead smolts at river miles 8 and 11 greater angler access and harvest would be achieved yet still create angler opportunity upstream be it later in the season.

Genetic cross breeding with the hatchery Summerrun Steelhead is not an issue as the Wynoochee River, or any other stream in the Chehalis Basin, does not have a native or composite natural Summerrun Steelhead stock. Genetic cross over is not a concern as Summer Steelhead run spawn first part of December, while Wynoochee Winter Steelhead start spawning late January. Also after many years of Summerrun Steelhead plants fishers seldom catch an unmarked Steelhead in the Summerrun Steelhead season. Simply put the Summerrun Steelhead stock utilized by the Aberdeen Lake Hatchery is many generations away from natural spawning and has a very low to zero success rate spawning in the river naturally.

This a excellent example of good intensions gone wrong with very viable hatchery program then requiring a rule that addresses it which in this case was a small percentage of anglers harassing Fall Chinook. The rule referenced prior is appropriate but the failure to address the short comings of the hatchery planting sites compounds the problem. It is the planting site selection that created the problem by creating the expanded opportunity in the upstream reaches where the ability to monitor and enforce regulations is the most difficult.

Example 3: The Wynoochee Winter Steelhead program is a mitigation production required for the Wynoochee Dam. Brood are taken at the trap and transported to Aberdeen Lake Hatchery, held & spawned, fry reared to smolt, then planted into the Wynoochee River at river miles Dam Fish trap 50, 7400 line bridge 30, White Bridge 16, Industrial Intake 11, Black Creek 8. Due to facility limitations the mitigation does not utilize 100% native but rather the early returning composite portion heavily influenced by years of mitigation production. The mitigation Winter Steelhead do crossbreed with the natural composite and remaining portion of the Native Wynoochee Winter Steelhead run.

The use of the release sites are perfect examples of agency efforts to produce substantial angler opportunity gone wrong. Genetic considerations should require that all the Wynoochee Mitigation Winter Steelhead be released at the Dam Fish trap at mile 50 so that the returning adults can be captured at the trap and prevented from interbreeding with the natural Winter Steelhead population. In 2019 43,000 Winter Steelhead smolt were released at mile 50 Fish Trap with the remaining 89,150 smolt dispersed at the planting sites downstream. While creating angling opportunity to what degree is questionable. If released at mile 50 the fish would all pass through the lower reaches but not stage up which does reduce angler harvest somewhat.

Examples 2 and 3 are stark examples of agency actions that in the desire to achieve angler opportunity directed toward specific reaches of the river and a small portion of the angling public also created and exacerbated the need for a rule to protect another species. That by doing this creates genetic concerns within the Wynoochee Winter Steelhead natural population that are not acceptable.

Example4: Rules can create opportunity In many areas of the state opportunities exist for the for smaller quality fisheries. The process WDF&W utilizes inhibits the development of these fisheries as WDF&W focus is on large fisheries with many anglers compressed into a very narrow time frame. A prime example of this is the East Fork Satsop River. The Satsop River trout and salmon fisheries are well established with salmon limited to the mainstem to the closure line at Schafer State Park which is located at river mile 11. From River mile 11 to river mile 17.5 near Bingham Creek Hatchery the following game fish rules apply but the river is closed to salmon angling except for a 400 ft reach below the hatchery which anglers with disabilities can utilize.

From bridge at Schafer State Park upstream to 400' below Bingham Creek Hatchery dam (329)
ALL SPECIES TROUT Sat. before Memorial Day- Oct. 31
Aug. 16-Oct. 31 Night closure. Single-point barbless hooks required.
Statewide min. size/daily limit, except cutthroat trout and wild
Rainbow trout: min. size 14".
OTHER GAME FISH Sat. before Memorial Day- Oct. 31 Statewide min. size/daily limit.

The opportunity here is that a specialized fishery fly salmon fishery that can be created that is low risk and caters to a limited segment of angling community. As a general rule this would be something that most anglers should not support with good cause. The difference is the East Fork Satsop is very rural, has a private road open to the public that parallels the river, private residences are few and scattered, and river flows through timber land, and has a substantial hatchery Coho run that returns to Bingham Hatchery. Simply put an angler is going to hike to the river to fish or utilize a small pontoon craft to float down stream which would be an adventure in itself. One of the casualties of the population growth in Washington State is rural quality isolated fisheries. Not wilderness but something as close as one can get that requires substantial effort and is very rewarding to those who undertake such endeavors. The East Fork Satsop concept is lacking data but data would not show the Coho harvested are hatchery Coho just a few miles from being clubbed in the head, thrown in a tote, and shipped out as surplus at Bingham Hatchery.

For Law Enforcement abuse by the angling public is a concern for some agency staff but frankly is unwarranted. Snagging with a fly rod is not very productive and those who do poach would have difficulty claiming a treble hook with two ounces of lead attached is fly fishing. Another issue would be spawning Chinook which are present but are fully staged up and holding or spawning. They can be encountered by a fly fisher but seldom as bait is normally needed. Bait normally used to catch Chinook in the reaches below Schafer Park is roe, shrimp, combinations of both, plugs with a herring wrap or spinners. Another factor is the reality that fly fishers are more or less purist and of all the harvesters which includes commercial, recreational, and tribal fishers. The fly fishing portion of the angling public is the least prone to violating fishing or conservation rules. The added benefit is the average angler detest poachers and with cell phones have the ability to help Law Enforcement as more eyes on the water is a huge deterrent to poaching of salmon or game fish.

I'm sure another "concern" raised is more money will be needed for enforcement. It seems like every time changes that might liberalize things are considered enforcement costs come up as a fall back concern. This seems especially prevalent when co-managers are involved. To be able to counter that possibility, another area to get information (and based on previous requests unless the data collection/availability has been improved) would be to ask for the LE history on fishing tickets written/successfully prosecuted in the basin and what charges were filed (i.e. no license, illegal take to include snagging, out of season, illegal gear, species taken, etc.) and how many license suspensions have been handed out.

Over the years, it's been our impression that some in the Dept do not trust the sport angler and restrictions are a way to control what probably isn't happening. It's been our experience that most folks will try to do the right thing and if they make a mistake, it can be attributed to "being dumb in public" for not keeping up with the regulations, which isn't easy with the emergency closures/changes that are often dropped on folks. Somewhere around 60% of the cases are this kind. The "bad guys" can be broken down into two classes. Intentional (30%) and those with more of a commercial intent or just plain bad (10%). The 10% need to be removed from the field. The 30% will change their actions with appropriate handling. The 60% probably won't do the same thing again.

If WDF&W processes allowed a reasonable change that could implement a fly fishing area on the East Fork Satsop the best time frame would be October 15 to December 31. Coho bag limit to be determined and in the month of December would require release wild unclipped fish as this is the timing of the late timed wild Coho mixed with the hatchery late timed Coho. Chinook release under all circumstances.

Rules can be used to create opportunity where none exist at little or no cost and have substantial benefit. It is the failure of WDF&W to utilize its Advisers and knowledgeable members of the public that has limited the development of opportunities in many streams.

Example 5: Rules are angler opportunity, angler opportunity are rules, and both are driven by past decisions that the public is not aware of creating false expectations The Skookumchuck Dam and the mitigation required for the lost natural production is perfect example of what happens when WDF&W actions are implemented without public knowledge.

Built by a private power company its purpose was to be a source of water for the coal fired power plant near Centralia but it also provides substantial flood control to the downstream residents in the twin city area. In development of the mitigation required the view put forth within Washington Department of Game (WDG) and Washington Department of Fisheries (WDF), this was prior to the combing of the two agencies, that only Coho and Winter Steelhead were needed was the view that prevailed. WDF determined that Spring Chinook mitigation was not required as the augmented cooler water temperatures would create ideal spawning and rearing conditions producing adults for a vibrant recreational fishery. This would result in any hatchery supplementation of Spring Chinook not being needed in the future for harvest or conservation. One could argue the recent closure of the Chehalis River and up river tributaries for low Spring Chinook that this is not the outcome. Also the vast majority of the public were not aware then or now that this was the decision of WDF.

The two agencies then took two different approaches to mitigation. For Steelhead WDG had constructed a conditioning pond, visible in the photograph, and invested the remaining funds provided for mitigation in a out of the river basin facility to rear steelhead prodigy to near smolt and then place them in the conditioning pond for a period of time prior to release.

WFW utilized the Coho mitigation funds to build rearing ponds at what is now Bingham Hatchery on the East Fork of the Satsop. These ponds are located near the staff residences utilizing pumped water from the East Fork and were seldom used. Then in a bit of a book keeping gimmickry WDF included the Skookumchuck Coho mitigation into hatchery's existing production and released mitigation smolt from the facility into the East Fork of the Satsop. This method of producing the Skookumchuck Mitigation Coho went forward until the early 1990's
when a group of citizen advocates became aware of the requirement that the Coho mitigation be released above the Chehalis Tribal reservation located near Oakville. To resolve the issue rather than have it litigated the Deputy Director instead opted for a volunteer and agency partnership. The agency would release 100k at the Skookumchuck Rearing Pond, Onalaska School aquaculture program 52k on the Newaukum, and the remaining smolt from a volunteer operated site on 8 Creek in the upper Chehalis. This partnership continues to this day but some have expressed concerns that the release totals is short of 300k required by the mitigation agreement.

Example 6: How legislative intent and harvest opportunity, both non treaty and tribal, is limited or removed by WDF&W actions out of the public view effect Chehalis River harvest If one was to ask the average citizen what is the purpose of the Skookumchuck Hatchery most think it is part of mitigation for the dam and that is absolutely 100% incorrect. During the tenure of Governor Dan Evans a package of hatchery improvements and additions state wide was approved by the legislature. For the Chehalis Basin it provided for the additions of Satsop Springs on the East Fork Satsop and the Skookumchuck rearing ponds. Both had one defining characteristic, very low operating cost. Satsop Springs is spring fed and operated for a few years then was abandoned by WDF. In the late 1980's local volunteers rebuilt the facility and assumed operations that continue to the present time and are part of the Chehalis Basin Regional Fishery Enhancement Group's programs.

The Skookumchuck water source is the dam reservoir which is delivered to the hatchery via a pipeline. With a very low operating cost it is one of the premier salmon rearing facilities in Washington State.

It was not closed but rather WDF redirected the facilities production toward producing fish for South Puget Sound, primarily the Squaxin Net Pens. In recent years the facility has been modified and upgraded for some local production but is primarily producing salmon smolt for South Puget Sound. In 2018 WDFW transferred 1,650,000 eyed eggs SKYKOMISH R 07.0012 stock from Marblemount Hatchery, reared and shipped 810,000 smolt for South Sound Net Pens and 710,000 for the Squaxin Net Pens. After ocean harvest upper Chehalis River Coho releases return at approximately 2% of the smolt reaching adulthood. For Grays Harbor fishers this is a loss to Chehalis Basin of around 30,400 returning adults. If one considers the nearly 1,000,000 smolt reduction of Coho production at Bingham & Satsop Springs hatcheries which average 3% smolt to adult return to Grays Harbor, the loss of adults for harvest the grows to over 60,000 hatchery Coho adults in an average year.

In many meetings the word opportunity frequently used but the truth is opportunity without harvestable fish is a hike to the river or boat ride. Rules provide you the opportunity to pursue catching a salmon but if the fish available to catch have been drastically reduced without public knowledge it is betrayal of the public trust. In the Chehalis River the most likely target of recreational anger is tribal fisheries yet the tribal fisher has lost opportunity just as the recreational angler has. Rules can and are used by WDF&W to create false expectations of harvest opportunity as the citizen angler perceptions is based upon past success that may or may not represent the opportunities that presently exist.

Example 7: Actions & rules made in the past seldom keep current with change The Grays Harbor Bay fishery is an example rules made to address circumstances that existed at the time implemented but circumstances have changed over time. When WDF&W put in place the Grays Harbor Bay recreational fisheries the Humptulips hatchery production was vastly greater than at the present. It was not supposed to negatively affect traditional commercial or fresh water recreational fisheries only provide additional opportunity. To accomplish this the Humptulips River was separated from the Chehalis for the purpose of harvest management as escapement goals of one stream often restricted the other for harvest and by separating the two streams this issue was removed. It is our understanding that this action was taken without the co-managers concurrence and is not recognized to this day by the co-managers which still manage harvest within the aggregate of harvestable in both streams for harvest per the Boldt decision.

When the Humptulips hatchery was sited its primary purpose was to supplement the available ocean Coho harvest pool. The Humptulips River was a modest Coho producer that enters the bay separately from the mainstem Chehalis River. Lacking a weir straying was acceptable at the time as genetic damage was limited to this stock as it was a minor portion of the Chehalis Basin as a whole and hatchery straying was limited to the Humptulips River.

The implementation of the Hatchery Scientific Review Group ( HSRG ) created new standards for hatchery production and the Grays Harbor Management Policy ( GHMP ) created a frame work for harvest in the non treaty fisheries. These factors dramatically altered the reality of how harvest is to be managed presently than it was at the time the Grays Harbor Bay recreational fishery was implemented as now the Humptulips River was to be managed as a standalone stream rather than part of the Chehalis Basin. These actions dictated a reduction in hatchery Coho production to limit straying, budget cuts, and in recent years the investment in installation of Stevens Creek pipeline to better attract returning adults.

HSRG standards while well thought out often do not address hatchery and wild spawning populations in a pragmatic manner. With the substantial straying of hatchery Coho since the 1970's the Humptulips Coho natural population was simply a hatchery fish with a fin. Interbreeding between the hatchery and wild production resulted that genetically both were the same fish be it as stated prior one has a fin and the other is clipped. While HSRG objectives are admirable how they were applied in the Humptulips is questionable as to recovery of the natural production, which is driven by the decision to separate the Humptulips River from the rest of the Chehalis Basin to create a new rule for angler opportunity.

Coho are resilient creatures and when the time comes and the Humptulips hatchery ceases to operate within three generations the fish will sort themselves out and some level of natural production will be present be it genetically very similar or the same as the existing hatchery production. Natural selection processes, if harvest is managed properly, in 20 to 30 generations will create a true wild naturally produced Coho run in the Humptulips River is an absolute fact but at what cost? The only reason that the straying in the Humptulips River required such action was the separation by WDF&W staff of the two rivers to enable a recreational bay fishery. While this action can be viewed favorably or unfavorably it had little to do with the genetic health of the Humptulips Coho. That with the implementation of HSRG and the GHMP harvest guidelines WDF&W did little to nothing to address of the division of the two watersheds driven by the desire by past staff to create a recreational harvest opportunity in the bay.

The unintended consequences of this rule making exercise have been huge with the passing of time, some positive some not. The area in the bay adjacent to Westport has been permanently closed to the recreational angler to protect the Humptulips wild Coho which is in reality a hatchery Coho with a fin. The GHMP the area of the bay adjacent to the Humptulips River has a designated percentage of harvest impacts for both Coho and Chinook that is proportional with the fresh water angler and non treaty commercial fisher. From the Johns River mouth due North to the Brackenridge Tripod is the West boundary of what is now know as Area 3 that ends East or upstream, at the Highway 101 Bridge located in Aberdeen.

Edited by Rivrguy (08/13/19 10:34 AM)
Dazed and confused.............the fog is closing in