The RMP is primarily a COMMERCIAL harvest plan. (As are ALL harvest plans. Get it through your heads: you are an afterthought to fisheries managers.) The RMP REDUCES escapement thresholds for chinook on most Puget Sound Rivers, in many cases by as much as half. It will allow commercial harvest on listed chinook every year, NO MATTER HOW SMALL THE ACTUAL RUN SIZE IS, because it utilizes a fixed-percentage exploitation rate, rather than an escapement-goal management regime. It will allow harvest on smaller subpopulations without any monitoring. WDFW claims that allowing more fish to spawn will not increase salmon production, because they say that the existing habitat is already being seeded to capacity, but they offer no data to support this counterintuitive hypothesis.

(I can hear smalma coming, so I'll mention that the only credible way to test the hypothesis would be to allow chinook escapement to significantly exceed existing goals for at least two chinook generations, ten to twelve years. In the last 25 years, how many years in a row has WDFW ever allowed chinook escapement to significantly exceed existing goals? I believe the answer is none. How many years in a row has it actually even met those goals? I believe the answer is few. I don't want to know how much harvest has been reduced; I want to know how often escapement has been exceeded.)

How many of you think those all sound like good ways to manage the harvest of salmon the are THREATENED WITH EXTINCTION? Washington Trout didn't. At the very least, we thought NMFS needed to meet its legal responsibility and subject the proposal to full environmental and biological analyses before it was approved. We believe the "sound science" WDFW, the tribes, and NMFS cite will have a hard time making it through an EIS. We believe having to analyze a "no fishing" option and other more conservative alternatives will force NMFS to confront the weaknesses in the "habitat capacity" hypothesis.

This process will not lead to no fishing; it will likely not even lead to no commercial fishing. We hope it will lead to better managed fishing. It is not WT's position that there are no salmon to catch. There may even be individual populations of Puget Sound chinook that can tolerate some level of harvest, but not if harvesting those fish puts other, weaker populations at increased or uncertain levels of risk. It is our position that any harvest regime that impacts listed stocks must adequately account for ALL risks and uncertainties. Conservative fisheries management will likely include reduced pressure on mixed stock fisheries, and high reliance on non-lethal, selective-fishing techniques and terminal fisheries.

As I have reminded this board again and again, WT is NOT a sportfishing-advocacy organization and it is against our bylaws to become involved in allocation issues. However, it seems to me that organizations and individuals interested in sportfishing-allocation issues would understand that the management scheme WDFW and NMFS are defending is not in sportfishers' interest. It seems to me they might understand that the management regimes WT is advocating could be much easier realized in a sportfishing context, and would support it. Perhaps that's why PSA, the REEL NEWS, and other sportfishing institutions supported WT's suit, even though they understood it risked some short-term pain for anglers (if we had gone to court and won, there WAS a chance ALL fishing could have been shut down this year, a fact we never hid when we went to them for support; neither did we hide our position on hatcheries), and perhaps it's why they've welcomed this settlement agreement.

While Washington Trout advocates solely for the interests of wild fish and not for any stakeholder group, it thoroughly analyzes all the facts, examines every side of the issue, and considers every implication or potential consequence before taking an action or a position. It seems to me that is an ethos others might consider adopting. Toward that end, please visit www.washingtontrout.org. After you learn about the work Washington Trout is doing every day, on a host of habitat, harvest, and hatchery issue to protect and recover Washington's wild-fish resources, please consider becoming a member.

Ramon Vanden Brulle,
Communications Director
Washington Trout