I and several others put together our thoughts and objections to the 2023 NOF process and seasons. Few folks participated in the ZOOM portion or rather should I say spoke out. Bay fishers were more than happy to toss the inriver Rec under the bus for C&R bait fishing while praising the bay fishery which is the LARGEST C&R Chinook on the coast. Few Recs spoke and even less the inland inriver fishers but to be honest I am not sure it would have made a difference. WDFW has gone old school we are WDFW you are peons!


April 15, 2023

WDFW Commission
Director Susewind

Commissioners my name is Dave Hamilton and I wish to object to the manner WDFW Region 6 conducted the Grays Harbor NOF in 2023. When my 30 years as an WDFW enhancement volunteer ended at the request of others I turned my attention to harvest issues and I was shocked by Region 6’s conduct. WDFW Region 6 staff kept the public from Adviser meetings, refused to release the harvest models and meeting minutes or provide basic documentation. After several Public Document Requests failed I took legal action to get WDFW documents and the issue was settled out of court. WDFW then reformed the Grays Harbor NOF process and at Mr. Warren’s request I agreed to become a Grays Harbor Advisor, meetings became open to the public, harvest models made available to all, and soon after WDFW reformed Grays Harbor NOF the process to be more inclusive and the WDFW Commission adopted the Grays Harbor Policy (GHP).

Fast forward to 2023 and oh how things change. WDFW ended the use of Grays Harbor Advisors, public participation in the harvest NOF process is at an all-time low, and NOF negotiations between the Quinault Nation (QIN) and WDFW are dysfunctional from the general public’s perspective. The ZOOM process that Region 6 implemented due to the recent concerns over the virus and public health has had a chilling effect on public participation to the point where few make any effort to participate.

2023 NOF public meeting seemed to start off well as did the first ZOOM NOF and then staff went to California to finalize the 2023 commercial seasons with QIN due to scheduling issues with the QIN. Imagine our surprise when staff returned and stated that due to the QIN aggressive harvest for the 2023 season that WDFW was going to stand down the GHP because Region 6 staff felt the 2023 QIN seasons did not allow for a reasonable state nontreaty commercial fishery resulting in the loss of two fishing days when compared to the 2022 season.

When I asked at the last ZOOM NOF Grays Harbor that with the all-out effort to create more NT Commercial time would we make Chinook escapement staff replied yes and as the final model showing the changes were not provided to the public until after the last NOF ZOOM the explanation was accepted. After receiving the model it was clear something was not right. Adding both wild and hatchery escapement numbers it is clear we have a problem. The escapement goal is 9754 for wild Chinook and adding in the expected hatchery escapement the model shows 9066 Chinook to the gravel. In other words staff were not truthful and I will stick with not truthful but others may choose different words. Director Susewind this thing with the Quinault Nation has been going on for a long time. I have been present when agency employees refer to the non-treaty gillnetters as “our commercials”. Commissioners we have three commercial net seasons in the Chehalis Basin. They are Chehalis Tribal nontreaty state, treaty Quinault Nation, and the state nontreaty commercial fishers and frankly most folks could care less about the race or ethnicity which WDFW keeps inserting into the conversation simply by their actions. This needs to end as for the fish and inland communities a gillnet is a gillnet and it matters little who owns it! The overarching goal of the co-managers to achieve conservation goals is simply ignored.

In the last two years Region 6 staff have violated the GH Policy on non-treaty harvest sharing in about every way possible, attacked the inriver fisher for using catch and release for Chinook which is legal and used in nearly all WDFW managed fisheries, and shut down huge portions of the Rec fishers for conservation under premise of low flows stacking the fish up. I then provided a video of salmon movement to staff showing this was untrue. The manner WDFW implemented the restricted recreational season placed the conservation burden on the bank fishery who are usually folks who cannot afford a boat or are simply poor. The bias in Region 6 toward the inriver Rec fisher of limited means is not acceptable.

Commissioners I realize the present Commission were not part of the process that created the GHP but simply put it is a conservation-based policy that provides guidance to WDFW staff and defines how non-treaty harvest is to be shared. It does not address and is not binding for tribal fisheries dictated by past court decisions for either the non-treaty Chehalis Tribal or treaty QIN fisheries. It has many provisions but for the inland communities it is what is known as 4/3 provision that is critical. This requires that at least three days in a calendar week be net free if possible which is not always possible if the QIN fish more than four days in a calendar week such as this year. That said the state nontreaty commercials seasons are not supposed to violate the 4/3 clause or the designated 0.8 nontreaty commercial exploitation rate simply to get more commercial harvest which Region 6 did in 2022 and 2023. The GHP does have an adaptive management clause to allow for modifications to harvest guidelines but when this was discussed during the process creating the GHP and staff assured all that this clause would only be used for issues of “extraordinary circumstance.” The GHP has a clause that limits harvest known as 3/5 that limits nontreaty impacts if a salmon species has not made escapement 3 out of 5 years. For 2022 this clause was in play for Coho when the preseason forecast showed substantial numbers of harvestable Coho. 3/5 was stood down and seasons set minus the 3/5 requirement limiting nontreaty harvest. I thought this was an appropriate use adaptive management and “extraordinary circumstance” but the expansion of the nontreaty commercial above the .8 Chinook exploitation rate in 2022 was not! To make things worse for 2023 staff utilized the loss of two days in the modeled 2023 nontreaty gillnet season from the 2022 NT commercial season which was only created by violating the GHP in 2022.

The 4/3 clause was included in the GHP because prior to the GHP WDFW managed harvest in the Chehalis River, which is the second longest watershed in the state, for commercial fishing at Aberdeen at the mouth of the river limiting the inland recreational fisheries and Chehalis Tribal fisheries. It took years of effort by local advocates for the inland communities to get reasonable salmon seasons for recreational fisheries. Additionally as a former commissioner said 4/3 had the unexpected benefit of providing a safety net for wild salmon escapement, primarily Chinook and Coho, which have failed make escapement even after the Chehalis Chinook escapement goal was reduced a few years back.

The continuing whatever between the Quinault Nation and WDFW staff needs to end as the fish and the Chehalis communities cannot afford it any longer. This thing where post Boldt decision WDFW has continued resent the imposition of co-management needs to end! If the QIN are harvesting more than the court mandated share then WDFW needs to forcefully address it but standing down conservation guidelines of the GHP for the states share is not the appropriate remedy.

Commissioners I urge you to find a third party to bring both the Quinault Nation and WDFW staff together to moderate a discussion to put an end to this ongoing issue between the two parties as it is clear they lack the will, desire, or ability to do so on their own.

If any have questions feel free to contact me and the final 2023 Harvest Model, GHP are attached.

Sincerely

Dave