Smalma:

I realized what you had done but wanted to be sure that first time readers understood the full impact of seal predation within the area covered by the draft Plan and, therefore, to be able to compare the Stressors actually set forth by WDFW in the draft plan.

You asked if this should invalidate the whole enchilada and suggested that it might not. I respectfully disagree.

This convenient omission is huge in terms of its impact on the listed species and also in terms of the hope for success and the amount of time that recovery might require (and when any forthcoming Draconian limitations might be lifted) for those three as well as all the other rockfish species of concern. It goes to the reasonableness of this non-project plan and subsequent projects initiated under its guidelines.

For comparative purposes the plan includes an annual sportfishing rockfish C&K figure of roughly 11,500 rockfish (not including C&R mortality). The plan suggests a goal is to reduce the opportunity for sportfishing encounters with rockfish. That sounds innocuous but the devil is always in the details as well as future interpretations (this plan needs a lot more details of what will and will not be promoted in discrete projects). If each seal consumes 123 rockfish per year the sportfishing rockfish C&K of 11,500 represents the annual rockfish consumption of 93.5 seals.

If the seal population is growing at 12% per year as my calculations suggest and using the State's 2007 seal population of 14,000 the annual growth figure would be 1,680 seals. Compare that to sportfishing's C&K of 93.5 seal equivalents.

Between the recent past WDFW rule changes (maybe not factored into the 2004-2007 averages) and the proposed changes there is not an awful lot that we can bring to the table to be applied to the rockfish recovery goal.

Unless and until WDFW incorporates into the plan a seal control program which reduces the impact of seals over the long haul and to a level sufficient to provide a realistic recovery opportunity no amount of controls on sportfishing will yield the desired result.

And that is why I believe that the draft Plan needs to be rewritten to recognize the 800 pound gorilla at the dinner table (they really thought we wouldn't see him there and mention his presence???) and then work the other ideas around that problem. Once the idea of lethal removal is thrown into the Plan the roof will come off (Chittenden Locks; Bonneville) and that is also why we need a new Draft subject to another round of preliminary review and comment (unless they really think they can sneak that into the final plan and get it approved and implemented without greenie lawsuits stopping the whole thing).

Larry