After the final NOF Grays Harbor I put in a formal objection to the Director and Commission. I am told the staff's position is being reconsidered.

April 19, 2020

Director Susewind,

I am writing as a Grays Harbor Adviser to formally object to a blatant violation of the Grays Harbor Management Policy (GHMP) for the 2020 Recreational seasons. I am objecting to the removal of Chum salmon from the Chehalis River freshwater bag limit which violates the GHMP. I request that your office review the information I am providing and reinstate Chum harvest for the full 2020 recreational season mandated by the GHMP. The two WDFW models I utilized are attached. I want to be clear my objections do not challenge Quinault Indian Nation's (the Nation) right to harvest or sharing between the Nation and WDFW (state) fisheries as that responsibility resides solely with WDFW staff dictated by numerous court decisions.

The GHMP is a conservation based management policy with clearly defined harvest sharing guidelines. Additionally a provision called 3/4 requiring three net free days a week to assure sharing for inland fishers, both Chehalis Tribe and recreational, and provides a safety net for the fish if the preseason forecast is wrong. The conservation objectives are reinforced by a conservation directive that if escapement is not met 3 out of 5 years on a salmon species state fishers are limited to a 5% impact of the run size of that salmon species; this is known as 3/5. With conservation built in Mr. Herrings action removing Chum from the freshwater bag limit is a totally irresponsible action and clear violation of the GHMP for the reasons I will outline.

Guidelines for state Chum salmon fisheries are:
Guiding Principles
7) In a manner consistent with conservation objectives, fishing opportunities will be fairly distributed across fishing areas and reflect the diverse interests of WDFW- managed fishers.
Chum Salmon
Subject to the adaptive management provisions of this policy, the Department will manage chum salmon fisheries consistent with the Guiding Principles and the following objectives:

1) Fisheries will be managed with the intent of achieving escapement goals for wild and hatchery chum salmon. In no case, shall WDFW-managed fisheries result in an impact of more than 5% of the return when the natural-origin adult return exceeds the spawner objective by less than 10%.

2) No fisheries directed at Chum salmon shall occur unless the adult Coho salmon return exceeds spawner objectives, or if Coho salmon impacts remain after Coho and Chinook salmon fisheries.

The 2020 aggregate preseason forecast for Chum agreed to by the Nation and state is 30324 natural and 2325 hatchery origin adults resulting in 5825 Chum available respectively for the Nation and State fisheries. The modeled 2020 harvest is 5076 for the Nation, 2564 for State commercial gillnets and 215 for fresh water recreational. The recreational harvest numbers reflect that as of Nov 1 Chum was removed from the recreational bag limit. The model also shows that if all fishers fished to the modeled harvest that 3025 Chum salmon remain not harvested in the states share and 749 in the Nation's share. When I objected to the recreational Nov. 1 closure in the Adviser ZOOM meeting Chad Herring responded that the suggested closure came from an Adviser and he personally had "concerns." Why an Adviser would advocate for violating the GHMP I have no idea but frankly Director Susewind that is an issue between yourself and the Adviser as you appoint all of us. Mr. Herring on the other hand is the Grays Harbor Harvest Policy person who reports to Mr. Warren, both are very familiar with the GHMP, and both clearly know Mr. Herring's actions violate the recreational sharing for harvest dictated by the GHMP.

To further clarify this issue as it relates conservation and harvest I would like to share the following data from the preseason forecast model which contains the history of Chum harvest and escapement. The five year recreational average 2014 / 2018 (2019 is not included as it is only an estimate in the model) recreational Chehalis River Chum harvest is 464. For the same years the Nations average catch was 8074 and state commercial 2824. The model also shows in 2014 and 2017 Grays Harbor failed to make Chum escapement and the recreational harvest was 491 and 523 for those years. The Nations harvest 10,266 and 5831 with State commercial harvest 2625 and 1979 for the same two years.

Simply put Director Susewind if Mr. Herring has "concerns" I assume those concerns revolve around escapement as no other issues were discussed. The harvest numbers clearly show that in Grays Harbor Chum harvest the recreational freshwater fisher has the least impacts and a full season bag limit including Chum would pose about zero chance of reducing the Chum returns below the required escapement goal. I request that WDFW reinstate Chum to the freshwater bag limit for the 2020 seasons and comply with the GHMP.

Sincerely,

Dave Hamilton

CC: WDFW Commission
GH Advisers
JT Austin Governor Inslee Senior Policy Advisor, Natural Resources & Environment