From the Advocay's Willapa C0mmercial CR 102 comments.

ISSUE:

The Department’s historical failure to properly monitor the season as it progresses and reluctance to utilize inseason adjustments magnifies the danger of setting a season using a flawed harvest model

The Department has historically ignored the landing reports coming in daily showing the harvest rate that is incurring on the water. Then, WDFW staff are reluctant to make inseason adjustments in Willapa Bay to prevent the season from overfishing the stocks. The result is the Department effectively reserves commercial inseason adjustments to honor requests from the commercial fleet that the season be modified to increase harvest by the fleet.

During the legal challenge to the 2013 season, Advocacy members outlined to the court our concerns that the season set (to the last available fish in the model) would result in overfishing of Chinook. The Department filed a declaration from District 17 Manager Kirt Hughes contesting the concern and implied assurance to the court by stating Hughes could use inseason adjustments if overharvest seemed underway.

Several weeks into the season, landings showed the harvest was well over the model’s prediction and the petitioners requested the Department consider an inseason adjustment. The Department’s response was it had told the court it could do an adjustment, not that it would. Management then stood idly by as the fleet landed 194% of the model’s prediction and undermined escapement goals once again.

The steadfast refusal of the Department to monitor the progress of the Willapa commercial season and use inseason adjustments in Willapa as it does throughout the rest of the fisheries it manages magnifies the problem of using an unreliable model to set a 2014 season that “fishes to the last fish”. Once adopted, history has taught all that we will have to live with it as written regardless of the damage to the stocks.