Attached and below are comments on the final draft of the WMP put together by the Advocacy. I think that about 18 of us signed on to the letter which is a bit of a shock as getting on the same page was similar to herding cats! Key things?

• A 14% harvest rate for both the North & South portions of the bay.
Modified
• 2.Modified Option E is the only way to go.
• Also staff is playing games with a couple things identified.

So take a look and see what you think. I have some additional thoughts I will get out in the next couple of days but we are getting close to closing time.





WB Request For Adoption Of An Interim Policy For Willapa Bay Fisheries



May 26, 2015 Via Email

The Honorable Members
Washington Fish and Wildlife Commission 600 Capitol Way N.
Olympia, WA 98501-1091

RE: WB Salmon Management Policy Recommendations

Dear Commissioners:

The 17 individuals who have served on the Ad Hoc Committee or regularly attended the public meetings in Raymond that are shown as endorsees below have reviewed the latest draft for a new salmon management policy for Willapa Bay. We respectfully reject Alternatives A-D and endorse Alternative E. Further, we offer several suggestions for improvements to Alternative E that we believe would prove helpful to restoring natural spawning stocks and increase the likelihood that recovery can be attained within the next two decades.

Our suggestions to Alternative E have been incorporated into the latest draft produced by the Department and attached in a PDF file format. The attachment shows deletions in red strikethrough and our additional language or changes in blue (see Strikethrough_Option E with improvements.pdf).

We offer the following comments and recommendations to the members of the Commission regarding the numerous alternatives for Chinook management.

Alternatives A-D All of these Alternatives are fatally flawed for the following reasons:

1. The AHA modeling during the ad hoc process found a maximum harvest rate of 14% on both the south and north tributaries would be required in order for natural spawning to recover within 16-21 years. The harvest rate of 20% or 14% on only a single river (Willapa) with no limitation on others will delay recover further into the future and creates a scenario where recovery is likely to never be achieved in the majority of tributaries throughout the rest of the bay. Last season, the harvest rate was capped at 20% in the Naselle only. The end result was a harvest at 38.8% in the Naselle and significantly higher in the Willapa. Having a single stream harvest rate has led to the Department setting seasons that dramatically increase the harvest against the other streams that are provided little if any protection from over-harvesting. The harvest occurring on the non- index streams during seasons installed by the Department has exceeded the harvest rate maximum for the index stream by a factor of 3-4. Use of a single stream as a harvest index will effectively delay if not block entirely, the restoration of natural spawning on the other less fortunate streams.

2. The use of "aggregates" creates similar problems for in season adjustments and managing for escapement goals. In essence, all the stocks in all the different tributaries are combined for harvest management or spawning escapement into a single Chinook, Coho, and Chum for the entire bay. While the Department's harvest model and the AHA model separates the different river runs for harvest rates and escapement goals, Alternatives A-D basically allow the Department to ignore over-harvest occurring on Chinook in one or more streams by linking in season adjustments to an aggregate number for the entire bay. The same linkage is installed for escapement goals for Coho and Chum. The use of aggregate thresholds allows the Department to regularly fail to reach its goals for harvest or escapement as long as it can get a portion of the Bay to compensate for the other. One example would be having Chinook restoration occurring in the northern tributaries where recreational priority has been limited while over-harvesting with the commercial sector on all the southern tributaries is preventing escapement from occurring. A reverse example would be having Coho in the south coming out of the Naselle with its problem weir cover for a decline in Coho occurring in the Willapa or North River. Hatchery Reform should apply to the entire bay, not just a single stream.

3. The Chinook hatchery production in the future will drop dramatically out of Forks Creek in the Willapa River. Restoration of the natural spawning production quickly as possible is of critical importance if one wishes to have any meaningful harvest opportunity once the past hatchery releases have cleared. It is therefore imperative that hatchery runs returning to the Willapa River over the next 4 years be allowed to jump start natural spawning (adverse impacts to current natural spawners is not expected as the stray rate has been historically high as 4-1 hatchery fish over the last decade). The Chinook "stage up" in the lower stretches close to the mouth of the Willapa in late August and early September in the lower reaches of the Willapa River waiting to spawn. These staging areas are included in marine Area 2U and open to commercial harvest approximately 5 miles up from the mouth of the river to the 101 bridge in Raymond. Alternatives A-D install the commercial fleet in 2U after Labor Day in the first four years and then not prior to September 16 in the second phase. While filling nets with the last of the large hatchery releases will be financially rewarding to the commercial sector over the first 4 years, it will leave the Willapa River effectively "clear-cut", delay recovery, and at the same time, provide little meaningful harvest opportunity in the future for others once the nets are cleared back.

4. Hatchery Reform seems to the public to be a procedure for operating hatcheries in a manner that is compatible with the native spawning populations. The creative use of stream designations contained in Alternatives A-D that move streams with existing hatcheries down to the lowest ranking of stabilizing effectively negates the implementation of Hatchery Reform. As an example, the Naselle has one of the better Coho natural production spawning capacities that warrants recognition as either a prime or at least a contributing but also has a hatchery with a weir problem that allows excessive hatchery straying into the spawning grounds. The most obvious simple solution would be to cure the problem with the weir. The solution contained in Alternatives A-D is to creatively insert a stream designation of "stabilizing" to the Naselle for Coho effectively making an "end run" around HSRG standards for straying. To label hatchery streams like the Naselle as stabilizing effectively stands down hatchery reform except in those areas where no hatchery exists.

Alternatives E The general language of the full policy and the hatchery production levels create problems for many in the public sector. Such is especially the case for those who recreational fish for Chinook in the north who will see Chinook production in Forks Creek decline dramatically due to the lack of a weir in the mainstream of the Willapa
River. Alternative E is the only alternative that rises to the challenge of installing hatchery reform and seeks to achieve restoration of natural origin populations during most of our lifetimes. Simply put, AHA modeling shows that it is unlikely to achieve restoration within the next 27 years unless a maximum harvest rate of 14% is installed for both, the Willapa and the Naselle. Having a harvest cap for both provides necessary protection from seasons being set that over-harvest in either end of the bay. Without a cap on both, one end of the bay or the other is not likely to ever see natural spawning populations recover. Therefore, Alternative E is the only alternative that provides a potential for successfully recovering natural spawning Chinook in Willapa Bay.

We offer several suggested changes to Alternative E that we believe would greatly enhance the policy in fulfilling its purposes and reaching the goals. The changes are relatively easy to install and are included in the draft language markup that is attached. The changes are as follows:

1. (Addressing the aggregate problem) Under the "Guiding Principals" section, add a new subsection as follows:

12) When managing fisheries using an “aggregate”, the Department shall utilize an aggregate of streams flowing into the north of Willapa Bay (Areas 2T, 2U, 2K) and an aggregate of streams flowing into the south of Willapa Bay (Areas 2N, 2M, 2R, 2P).

2. (Addressing the need to let the next four years of Chinook hatchery returns accelerate the restoration of natural spawners in the Willapa River) In Alternative E, delete the early start time of commercial seasons in the north set forth in Phase 1 and use the start times found in Phase 2
for years five and beyond. The effect of this change would be to move the commercial start time back from “after Labor Day” as set in the current draft for Phase 1 until September 7th in the south and September 15 in the North as set forth under Phase 2.

3. (Addressing the two options for Chum harvest) Under Section 3) of the Chum Salmon heading, select Option B for harvest impact limitations which is based on the language contained in the GH Policy.

Again, the individuals listed below that have served on the ad hoc committee and attended the public workshops in Raymond for all these months are requesting that the members of the Commission incorporate Alternative E into the new policy. Further, while the suggested changes shown above might seem relatively minor to some, the recommended improvements to Alternative E listed above will greatly improve the chances of success for the new
policy. Therefore, we strongly encourage the members of the Commission to consider our suggested improvements to Alternative E for incorporation as well.

Sincerely-