I submitted comments yesterday to the draft coastal steelhead management plan. They might not have much impact, but it was cathartic at least. My comments are here if anyone is interested or can answer questions:

I’d like to start by thanking you for taking a science-based approach to planning for coastal steelhead seasons and working to ensure escapement goals are met, as well as taking steps to improve the transparency and communication with the public during planning. Please continue working with our co-managers to prioritize the health of our steelhead and temporarily halt harvest of wild steelhead when escapement goals are not on track to be met. This is far preferred to the refusal of the BC/Canadian government to protect steelhead runs for political reasons. Their approach has resulted in once-massive runs being on the brink of extinction, and of course complete sport-fishing closures which may never be lifted. It’s much better to make unpopular decisions now so we can have good steelhead runs in the future.

I do have several questions and concerns to raise with your draft of the plan, primarily on section 12.2 which lays out your process for escapement-based pre-season planning.

First, step two of the process says, “The portion of total allowable mortality for wild steelhead allotted to the recreational fishery is then determined by subtracting indirect impacts (i.e., poaching, and other fisheries, including fall coho and spring Chinook) from the total allowable mortality”. Are you including tribal in-river netting target steelhead in the “indirect impacts” number? Or should the first sentence say “The portion of total allowable mortality for wild steelhead allotted to the recreational and tribal fisheries is…” If you’re including tribal steelhead fisheries in the indirect portion, indirect is a misleading term, since there’s nothing which more directly impacts wild steelhead adult spawning numbers. I’d recommend you label it as “other impacts” instead. Regardless of how you label it, how are the allowable impacts being split between tribal and recreational users? I recommend it be split 50/50, per the Boldt decision. But I assume tribal fisheries will use foregone opportunity and harvest greater than 50% on systems with strong run predictions, rather than allowing returns to exceed minimum escapement.

Next, in step 7, what is included in “emergency fisheries regulations”? Are bait bans and single barbless hooks part of that, or are those considered normal, baseline regulations? I assume the no fishing out of boats and early closures (prior to the normal 31 March or 15 April dates) are considered an “emergency fisheries regulations”. The way this plan is written says that emergency regulations like these will only be implemented if the projected impacts from recreational fishing are enough to result in an under-escapement. I don’t think this was the case last year or will be this year on the Quillayute system, so I’m confused why the boat ban was still implemented last year and is being discussed this year.

Even though I usually hike in ONP for steelhead and am personally benefitted by guides and other anglers catching fewer steelhead downstream, I’m firmly against any ban of fishing from boats on any system the co-managers are harvesting steelhead. It doesn’t pass the common sense test that tribal fishers can legally kill hundreds or thousands of steelhead in gillnets, but sport fishers aren’t allowed to catch and release any steelhead out of a boat using a single barbless hook. Recent studies have shown steelhead catch and release mortality is significantly less than 10%, and the boat ban is not necessary and unfairly benefits certain user groups like fly fishers while punishing conventional fishers and those with disabilities or too old to wade and fish. Please use other alternatives to limit impact when necessary, and don’t give fishermen another reason for in-fighting with each other and being upset with WDFW by unfairly catering to special interest groups.

Step nine says “If multiple emergency actions enable fisheries impacts to remain within allowable limits, those options are presented to the public at Coastal Steelhead Townhall Meetings to gauge public preference.” This is a good start to collecting inputs, but it is insufficient and could be biased for a number of reasons. You might run out of time for everyone to state their opinion at the town hall, some people might not be comfortable speaking in that forum or might not be available, a vocal minority may show up in force and give you a skewed representation of what the general fishing population wants, and non-fishers could also attend and provide inputs on fisheries decisions. I suggest you do a poll or voting system and only allow license holders to take it, or at least have somewhere to submit written comments.

On a final note, will there ever be any studies or other action done to validate and adjust escapement goals for each system? You are being relatively agile with adjusting your pre-season and in-season plans based on the latest data, but it seems like escapement goals are fixed for all time. The current escapement goals for steelhead, as well as salmon, on coastal rivers are far lower than historic run sizes, even though rivers like the Queets and Hoh are largely protected and have excellent habitat. The assumptions made for river smolt carrying capacity when the escapements were set have not been adequately validated. The policy of maximum sustainable yield is a failure and continues to result in declining runs. It guarantees continued scarcity of runs by allowing co-managers to over-harvest. Managing to such low numbers is risky from a conservation standpoint, because there’s really no buffer or margin remaining in the event of over-harvest due to over-prediction of return sizes. In addition, SARs have declined since escapement numbers were set, so escapement should at a bare minimum be increased to offset for that. Failure to do that will result in continued downward trends in run size, unless SARs somehow improve back to where they were. Also, without working to increase the overall productivity of river systems by allowing many more salmon and steelhead to return, spawn and die in rivers, you will continually be one down cycle in the ocean away from being in dire conservation status. MSY doesn’t work. Even if court decisions currently force you to manage using MSY, we have far more science now than was available at the time of the decision, and as fisheries managers you should make a recommendation to re-visit that and try some better options to manage our irreplaceable anadromous runs. At least try it on one system and see what happens. If you can run a pathfinder program and it results in a healthier river and larger return numbers, and eventually more opportunities for tribal and sport harvest, other tribes will get on board.