Smalma:

I have been rolling around with the "math" at 2.7.7 of the draft plan and not only is the 5MM pound figure wrong they mix the San Juans with all of Puget Sound so a very close read is necessary.

First, the 5 MM pounds simply does not correspond to the discrete pieces of information they provide - SJ or PS.

14,000 seals (actually read another report that it is near 15K) in P.S.
X 140 # Seal in P.S.
= 1,960,000 pounds of seal
x .04 Percentage of body wt of fish each day
= 78,400 of fish consumed each day
x 365 days per year
= 28,616,000 pounds of fish consumed per year
x .12 percentage consumed that are rockfish by#
= 3,433,920 total poundage that is rockfish
div by 2 my guesstimate of avg rockfish wt.
= 1,716,960 number of rockfish consumed per year in P.S.

Note that the 12 % is a figure from studies in the S.J.s that I applied to the entire P.S. and that the 2# per rockfish is purely my figure as it makes the math easier and certainly does not understate the weight (lower wt. per fish = more fish taken by seals)

Doubling your 14,308,000 total food poundage for 7,000 seals to 28,616,000 for 14,000 works out the same as mine. Then apply the 12% being rockfish and convert to number of fish to have total fish numbers as that is how WDFW cites the Stressors. I have seen another tech pub that said Puget Sound seal population is nearing 15,000 (still growing).

In Trends and Status of Harbor Seals in Washington State: 1978-99 Harriet Huber and Jess Laake divided WA seal population into Coastal and Inland with the geographic area for Inland being the same as for Puget Sound as described in the draft Plan with 5 separate breakouts within the Inland group. While their monitoring began in 1975 and ran through 1999 they only had counts for all five sub-groups for years 1991-1993 and 1996-1999. The high count was 1996 with 11,933 and decreasing each year to 1999 with 8949. Among their conclusions was that "For both stocks, the observed population size for 1999 is very close to the predicted carrying capacity (K)." Also, that "estimated abundance has increased seven to tenfold since 1970." (Keep in mind this is referring to 1999 levels) In this report they also wrote "It is evident that harbor seal stocks in Washington could decline by 20% and still be above MNPL (maximum net productivity level). A direct comparison is that the count in 1999 for the San Juans was 3,588 and they now say 7,000 which I take as being a 2007 figure as the 14,000 total is from (PSAT 2007); a 95% increase in eight years or 12% per year.

The draft plan acknowledges that the seal population is now 14,000 (2007) (and may be nearing 15,000 today). I think the 1999 report grossly underestimated the carrying capacity and that there may have been another explanation for the drop from 1996 to 1999. Bad surveys or Orca transient predation? Anyway, the draft plan cites Jeffries et al 2003 as saying that "the growth rate of the seal population is decreasing, and that the population may be reaching its maximum carrying capacity in Puget Sound." Well, the experts seemed to have again underestimated the carrying capacity. Don't have to wonder where the low reproducing rockfish are REALLY going?

Another thing to be aware of is that the NOAA findings established that rockfish stocks east of a line starting just east of Pt. Angeles and running to Victoria (an uplift) separates Puget Sound stocks from coastal stocks because NOAA basically concluded that there is no movement from healthier coastal stocks to areas east of that line. That makes the adverse impact of those seals even more critical as affects rockfish reductions and, clearly, any attempt to recover rockfish stocks.

Oh, and so far we haven't even discussed the Steller sea lions that visit the S.J.s fall and winter estimated at 800-1000 animals. I played with some rough assumptions and came to an annual impact of 16,162,200 pounds of food (using the seal % of body wt.). Using .083 (% of scat rockfish) and arrived at 1,341,463 pounds of rockfish or 670,730 rockfish at the 2#/rockfish guesstimate.

O'k, we are now at 2,387,690 rockfish consumed per year by seals and Steller sea lions. I would add a number for California sea lions but there is not enough info provided but they have to have some effect.

So how does that compare to the 11,500 C&K as reported in the draft Plan? Or the 61,000 (probably higher) killed per year by derelict gear (hopefully going away due to current removal efforts)?

Our impact is like one raindrop in the rain barrel!

Sorry this has been so long but the more I look at this the failure by WDFW to have provided truly comparative numbers between their various Stressor factors is deceit by omission. Deceit is a pretty strong accusation.

They need to withdraw this draft. If, after considering all of the input to date, they decide to move forward they should re-accomplish the draft recognizing and fully addressing all of the Stressors, their comparative impacts, and recommendations addressing each of those Stressors tied directly to each one's relative significance to the problem. They should then go through the public process again with adequate time for the public to review, attend meetings and have pertinent and knowledgeable input. This rush to judgment is not acceptable.