The comments below are a response by the Advocacy to the Willapa Commercial season for 2014 outlined in the CES. It was the Advocacy that brought the legal action in 2013 challenging the Commercial season that basically started the effort to protect natural origin spawners ( wild ) so I thought this might be of interest to some folks following the many issues surrounding Willapa salmon harvest.

Phil Anderson, Director
Washington Department of Fish & Wildlife 600 Capitol Way N.
Olympia, WA 98501-1091 RE: 2014 Willapa Commercial Season Dear Director Anderson:
The Twin Harbors Fish & Wildlife Advocacy offers the following comments on the 2014 com- mercial season recently adopted for Willapa Bay. In addition, the Advocacy feels that the parties should move forward with completing their performance under the agreement reached as a result of the 2013 season challenge.

The Advocacy recognizes significant improvements in the NOF process used to develop the 2014 commercial season. We believe more improvements are in order, especially in the area of reliabil- ity and accuracy of presentation materials. That being said, we compliment the efforts undertaken by the staff this year to improve the public’s ability to participate in the process. We take special note of the efforts undertaken by Region 6 staff under the leadership provided by Steve Thiesfeld.

Another noteworthy improvement related to public participation is the season adopted actually re- flected many of the comments and input provided by the public during NOF. While many will be disappointed that their points of view were not adopted in the fashion they sought, the CES draft- ing improved significantly and the public could actually recognize the process they participated in and see where the Department agreed and WDFW’s rationale when it didn’t agree with their points of view.

The Advocacy further recognizes that the season adopted shows significant progress in regards to the Advocacy’s concerns over selective fishing utilization and conservations standards. We note the following highlights:

• The installation of a protection zone for the North River Chinook stock;

• Reducing the harvest cap for Chinook from 30% down to 20%;

• Seeking support from the commercial fleet to find alternative gears;

• Increasing onboard observers from <1% historically to 15% during selective fishing periods;

Page 2, Willapa Commercial Season Comments

• Reducing the reliance upon selective fishing and moving toward a non-selective approach with retention to reduce discarding large numbers of dead bycatch;

• Language changes in the WAC that require all bycatch to be released be placed into a recovery box and remain there until fully recovered;

• Insertion of net free days during weekly cycles rather than continuous 7 day a week seasons to help get fish upriver; and

• Insertion of several weeks of net free time during the high point of the Chum run cycle.

Unfortunately, the Advocacy also has significant concerns over the season that was adopted. In our view, the 2014 season once again fails to rise to the legislative mandate that the Department manage first for conservation and harvest second.

We highlight the following concerns:

a. The CES only references inseason adjustments to increase the commercial season when professional fisheries management protocols recognize that inseason monitoring (the purpose of quick reporting of landings) and reducing harvest if over-harvest is underway is a key to insuring conservation standards are met. (In season management is used regularly for recreational seasons and other commercial fisheries in Washington);

b. The season adopted installs unlimited net pressure (number of boats) into 2T during much of the run cycle for North River Chinook dramatically negating the intended benefits of the protection zone

c. The decision to once again install a net season of this magnitude in 2T as a means to deliver the fleet the maximum-possible ex-vessel values from hatchery Chinook will continue the downward trend of natural spawning Chinook reaching the gravel in the Willapa, Nasalle, and other streams (evolved after the Department installed a lucrative net season into the area now known as 2T over 5 years ago);

d. The Department states that it will increase observers but doesn’t provide any assurance that observers will be properly trained and enforcement staff will be present in adequate numbers to deliver the 90% compliance rate assumed by the Department;

e. Reliance on an assumed 90% mortality figure without adequate historical
justification and when WDFW possesses ample evidence that fisher compliance with Fish Friendly Practices is inconsistent, at best;

Page 3, Willapa Commercial Season comments

f. While the Department adopted the Advocacy and others recommendation to allow the fleet to retain Chum as a means to avoid wasting fish while increasing the ex-vessel value to the fleet, it failed to adopt the key reason for supporting such a move, adding another week cycle of net free time during the prime time of the Chum run cycle (practicing avoidance).

While we had sincerely hoped it would be otherwise, due to the above stated concerns, the Advocacy cannot endorse the season that has been adopted. As a result, we intend to reserve our rights to object in the future if the problems identified above in a. through
f. are proven valid during the 2014 season or similar conditions reappear in an adopted WAC in the future.

Hopefully, Mr. Theisfeld and others within the Department will conduct the fisheries in such a fashion that our concerns are not proven valid. The natural spawners and future generations of citizens would benefit greatly if the Department can prove us wrong and the Advocacy members would like nothing better than to admit the Department did so. The question remaining is “Will the Department conduct the season in a manner that actually delivers the conservation results that are implied by or expressed within the text of the CES?”

The decision to opt not to challenge this year’s season was difficult in many ways. A pri- mary driver was the Advocacy’s recognition that the department faces the difficult task of correcting decades of unsuccessful hatchery and harvest practices and success will depend greatly on a concerted effort by all involved.

The Advocacy is ready and willing to move forward in a positive fashion. To that end, we look forward to receiving notification that you have requested that the Commission revisit the Willapa plan. We also stand ready to begin working directly with WDFW staff to schedule and conduct the four public meetings called for in the settlement agreement.

Again, we compliment the Department on its improvements installed this year over the experience of last year. We feel that now is the time to continue with those improvements and complete the performance of the 2013 settlement agreement.
Dazed and confused.............the fog is closing in