It is time for those who can to submit your thought to the Commission and Fish Program (Jim Scott & Steve Thiesfeld) on how the GHMP did in 2014. The Commission is going to review the GHMP shortly. My input is below and it is important that those who wish do the same with YOUR thoughts.

December 25, 2015


I am writing to place in the record my final thoughts on the Grays Harbor Management Policy (GHMP) performance in 2014. I am also providing copies of my previous comments on the GHMP. In looking back the issues remain similar but also different than I identified previously.

1. Three net free days a week. (4/3)
While I understand the Commercial opposition to 4/3 in the end it not only provided a real inriver Recreational fishery but was also a major factor in preventing a huge failure in Chehalis Chinook escapement. As the Commissioners are aware we again failed to reach our Chehalis Chinook escapement goal. While the state side restrained harvest (due to 3/5 which I will address later) the Quinault Indian Nation (QIN) did not. As the finger pointing started I requested that Mr. John Campbell review and back math the 2014 Chinook harvest and identify where the harvest model failed. His response follows:

To try to answer your question I assume you mean for Chinook. I looked at the total harvest compared to the plan total which is mostly natural origin.

The actual run was smaller than the plan but it looks like it came in faster in the early weeks. Harvest was about on plan for the first two weeks, (weeks 39 and 40). Even week 41 was 72% of plan. After that it declined rapidly.

I do not think I could predict a short run until at least week 42 and by then all but the last 150 fish had been harvested. In my view I could not have said the run was small and the normal looking harvest was really going to go into escapement.

Simply put Commissioners the comanagers could not have been able to identify the harvest model failure until the damage was done. The saving grace was 4/3 and 3/5 which prevented the heavy non treaty commercial impacts of the past. Had not the GHMP 4/3 been in place it is likely the failure in not making escapement would have been of a scale not seen before.

Now with Chum it is different. In Mr. Campbell's review he found the following.

I just now looked at Chum. The picture is a bit different. The Chum run started out with less harvest than the plan and by week 43 one would conclude that the run was about 60% of the forecast size.

In this case again it was 4/3 that prevented a bad situation from being much worse. The difference here is both the QIN & WDF&W staff should have caught the over harvest due to a failure of the preseason forecast model. They did not and that is a substantial failure that both share responsibility for but regardless it was again 4/3 that prevented a much larger failure to make escapement.

Failure to make escapement three out of 5 years:
This provision in the GHMP addresses the failure to make escapement three out of five years and restricts directed harvest. It is known by the nickname "penalty box" and frankly Commissioners I really dislike it, will never like it and please do not substantially alter it. Strange as it may sound it is the tool that holds staff accountable and forces the public to stay engaged.

That said one can make the case that it should perhaps had a starting date of 2014? Additionally maybe more performance driven? By that I mean in 2014 it was not possible to catch the failure in harvest predictions (outlined previously) so perhaps that should not be a penalty box year for Chinook? On the other hand the Chum failure to make escapement could & should have been caught and harvest adjusted so this should be a penalty box year.

Foregone opportunity:
This issue is a difficult one to address. That the QIN took more than its 50% share but how does that compare with Steelhead which the state recreational fisher harvest more than the QIN fishers? Consider the impact on non treaty harvest of clams and crabs if the split was a hard 50%. So this issue deserves more thought and perhaps a wider look at the harvest of all the resources not just one species of salmon when setting salmon harvest in Grays Harbor.

Humptulips Natural Origin Coho:
The failure to make escapement for over twenty years is a issue that remains unresolved and needs resolution. That said it is a issue that only the agency, Commission, and the QIN can resolve. There is little citizen such as myself can do but bring the issue forward.

Aggregate of the Chehalis & Humptulips:
The QIN did not agree to the separation of the Humptulips and Chehalis for harvest management. As I understand it they wish to maintain the court driven mandates which allow aggregate management of all streams flowing into Grays Harbor. The issue remains unresolved.

Wynoochee Mitigation:
On this issue the agency has done absolutely nothing. Zero! Little can be said or should be said in defense of this total failure by staff to move forward on this issue. As in the prior twenty plus years the funds remain not being utilized to meet the requirements of the Tacoma City Light power generation mitigation that WDF&W has a legal requirement to meet. Big fat F- here.

GHMP clarification:
It is possible to read when breaking item a) word by word in the sentence that the 5% is to the aggregate not singular to a stock in the Chehalis or Humptulips. The key words are predicted fishery impact for that stock which is singular as to stock. The following words in WDFW-managed fisheries in the Grays Harbor Basin then direct one to the aggregate of all streams flowing into Grays Harbor. The sentence finishes with will not exceed 5% of the adult return to Grays Harbor; and which continues to direct management toward the aggregate. This is how Chum are managed but not Chinook and Coho which is a conflict within itself. Region 6 is defining the verbiage as singular to a stock and some disagree and say regardless of intent the verbiage directs aggregate so clarification is needed.

From the GHMP:
As a component of the annual fishery management review, the Department shall assess if spawner goals were achieved for Chehalis spring Chinook, Chehalis fall Chinook, Humptulips fall Chinook, Chehalis Coho, Humptulips Coho, and Grays Harbor chum salmon. If the number of natural-origin spawners was less than the goal in 3 out of the last 5 years (beginning in 2009), the Department shall implement the following measures:

a) The predicted fishery impact for that stock in WDFW-managed fisheries in the Grays Harbor Basin will not exceed 5% of the adult return to Grays Harbor; and

b) The predicted fishery impact for that stock in WDFW-managed fisheries in the Grays Harbor Basin will not exceed 5% of the adult return to Grays Harbor; and

c) If a spawner goal for fall Chinook salmon is not achieved, the Grays Harbor control zone2 off of the mouth of Grays Harbor will be implemented no later than the second Monday in August and continue until the end of September.

In closing I would grade the GHMP performance as a solid B. It was successful in many ways in particular conservation. It also had failures but that should not be unexpected for a management policy in its first year. Solid B.


Edited by Rivrguy (03/25/15 11:34 AM)
Dazed and confused.............the fog is closing in