My comments on the WB policy debacle. I encourage everyone to write the commission. Feel free to use any of the ideas here that you can.


Dear Commissioners and Director,

I am writing to provide feedback on the ongoing Willapa bay salmon policy development process. I have followed the policy development process and management of Willapa bay fisheries for over 20 years and served as a WB recreational advisor in the past. As a recreational angler for salmon, I view the process through the prism of angler opportunity and have advocated for a policy that maximizes economic benefits while achieving the Fish and Wildlife Commission’s stated conservation goals.
As written the Willapa bay Salmon policy for chinook is an abject failure for many reasons:
• It fails to optimize the economic benefits of limited natural origin chinook impacts.
• It lacks basis in biological reality with overly optimistic escapement goals for chinook.
• It is predicated on false assumptions about hatchery functionality.
• It was formulated in the absence of a critical habitat evaluation of the Naselle and Willapa Rivers.
• It fails to implement an actual recreational priority, but rather eliminates recreational fishing.
While the veneer of conservation language in the policy document might suggest to naïve readers that strong conservation goals have been set, it has been clear from the outset that they are unattainable and have little basis in biological reality. For example, the data used to formulate the policy was mostly derived from a time prior to mass marking of hatchery chinook in WB hatcheries. So for instance, the data to derive realistic escapement goals was lacking at the outset. Likewise, despite repeated advisor requests for comparative quantitative habitat analysis, primary stream and contributing stream designations were made in the absence of contemporary habitat considerations. Furthermore, coded wire tag data clearly showing that the recreational catch was mostly composed of hatchery origin Forks Creek hatchery fish was disregarded counter to the state objectives of the policy of having a recreational priority. Taken together this lack of science driven decision making necessitates a full reconsidering of stream designations and revision of the policy to meet the Commission’s stated objectives for Willapa bay chinook management.
The consideration of what a meaningful recreational priority for chinook management might look like is also important because historically, Willapa bay had long been the top small boat marine chinook fishing destination in a state with very few remaining attractive chinook fishing destinations. While the policy has been successful in mitigating gear conflict, which is an aspect of recreational priority, it has done so at the expense of maintaining the one key hatchery stock (Fork’s Creek) making up the majority of marine. Unfortunately, the Naselle hatchery cannot produce adequate chinook returns to support any fishery commercial or recreational. Further, as production has been eliminated at Fork’s Creek, marine angler success has plummeted. Some Willapa bay advisors suggest that the recreational fleet can simply move south in the bay to follow the fish, but the fewer fish returning there are largely inaccessible to the recreational fleet due to intense weeds, navigational hazards, swift currents, shoals, and long runs from primitive launches exposed to strong winds. Combined with a relative isolation from marine infrastructure (harbors, launches, emergency services) these hazards will contribute to significant risk to the typical small boat angler and will dramatically decrease the accessibility and safety of the fishery.
To conclude, it is clear that nothing short of a full re-write of the Willapa Bay chinook policy is needed. If a recreational priority is to be an important piece of that revision, the primary stream designation should be shifted back to the Naselle River, which has superior chinook habitat, and hatchery chinook production restored at the Forks Creek hatchery which has superior production capacity for chinook.