This is a letter I submitted to the Commission for clarification. In all fisheries be it Rec or Commercial you encounter and have a mortality impact on another species. The most glaring examples happen to be Commercial to be honest. We have had targeted Coho fisheries that get more Chum which many immediately call foul on. Now out of the many tribal legal actions came definitive seasons by species Coho / Chinook / Chum and they are by week. Now this can make sense in the tribal fisheries but WDF&W carries the definitions into the Non Treaty fisheries and that is the issue.

So I was asked to seek clarification and that is the letter below. Be interesting to see what the response is. Oh almost forgot I directed the question directly to the Commission and did a CC to WDF&W staff.

March 25, 2015

I have been asked to submit as a Grays Harbor Adviser for clarification the definition of the word "incidental" as it applies to harvest in both the Grays Harbor Management Policy (GHMP) and the currently being developed Willapa Management Policy (WMP).

Incidental is the term to used to describe the impacts of harvest on one species of salmon while harvesting another in both GHMP & WMMP. At the present it normally revolves around Chinook and Chum impacts while commercially harvesting Coho but it also occurs in the recreational fisheries also.

The question I am requesting clarification on is just what percentage of catch should be allowed as incidental? In both Willapa & Grays Harbor we have had targeted Coho fisheries that had greater impacts or nearly equal impacts on Chum. This primarily happens when guidelines or harvest policy limits a directed harvest on a species.

This leads to considerable confusion and lack of trust as many view this as a blatant attempt to circumvent policy guidelines. In discussing with others the meaning and implications of the term "incidental" they turn to the following definition of the word incidental.

(sometimes followed by `to') minor or casual or subordinate in significance or nature or occurring as a chance concomitant or consequence

I am requesting clarification of how the term "incidental" or any other term staff would choose to describe impacts on one species while harvesting another. I am not aware of a percentage utilized such as in a Coho fishery where 55% is Coho and 45% Chum or even reversed when a Coho fishery is 45% and "incidental" Chum is 55%. We do have verbiage such the 5% limiters & 10% but circumstances are seldom the same year to year and often the conflict in definition of impacts of a non targeted species is present.

Be it the word "incidental" or any other agency staff choose to utilize, when does the bycatch of one species while targeting another for harvest become in reality two targeted or directed fisheries? I am requesting clarification as many feel it is needed to end what they see as attempts to circumvent both the GHMP & WMP while others do not. The different views on the definition of non targeted impacts are not reconcilable so clarification is needed.

Dazed and confused.............the fog is closing in