Not so much but they went to the Portland PFMC and followed up with the bit below.

February 11, 2016

Twin Harbors Fish & Wildlife Advocacy
PO Box 179
McCleary, WA 9855 thfwa@comcast.net


Pacific Fishery Management Council via: email in PDF format 7700 NE Ambassador Place, Suite 101
Portland, Oregon 97220-1384

Re: Request For Consideration In Ocean Harvest Impacts On Coastal Natural Spawning Salmon Stocks

The Twin Harbors Fish & Wildlife Advocacy is a non-profit organization based in Washington State. The purpose of the Advocacy is “Provide education, science, and other efforts that en- courage the public, regulatory agencies and private businesses to manage or utilize fish, wildlife and other natural resources in a fashion that insures the sustainable of those resources on into the future for the benefit of future generations.” (www. thfwa.org).

Advocacy members and their family and neighbors have personally spent decades investing in salmon production through volunteer projects that have raised millions of Chinook, Coho, and Chum salmon that contribute to the pool of fish caught in the Pacific Ocean. Our members and supporters have joined with other Washington citizens and property owners in contributing billions of dollars in habitat restoration, state operated hatchery production, culvert replacements, property devaluation, loss of timber harvest, municipal or private sewage and storm water improvements, etc. under government mandates wherein the stated primary purpose is the recovery or substainability of natural spawning salmon stocks in WA streams.

With all this effort and investment, salmon recovery has struggled to succeed. Instate fishing has declined and ESA listings have plauged the state from the Columbia on the south to Puget Sound to the north.

Over the last 4 years, the Advocacy and others have invested thousands of hours in assisting the Washington Fish & Wildlife Commission in adoption of two new salmon management policies for the coastal terminals of Willapa Bay1 and Grays Harbor2. The policies prioritize conservation over harvest, install hatchery reform and place an increased emphasis on achieving escapement goals for natural spawning stocks. In simple terms, an all out effort is underway to avoid further ESA designations and return natural spawning production to numbers adequate to sustain viable fisheries in the future.

The effort underway went forth with the knowledge that harvest inside the terminal has to be managed in a manner that could often require reduction of harvest inside the two terminals in order to achieve escapement goals. Using 2015 as an example, tribal and non-tribal commercial seasons were curtailed for Chinook in Willapa and Grays Harbor. Recreational fishers in both


1 http://wdfw.wa.gov/conservation/fisheries/willapa_bay_salmon/
2 http://wdfw.wa.gov/conservation/fisheries/grays_harbor_salmon/


terminals were forced to forgo retention of unmarked Chinook. Then, the much smaller than expected 2015 coho return forced closures of tribal commercial, non-tribal commercial, and recreational seasons within both coastal terminals.

Even with all these measures and sacrifices, we believe it is clear escapement goals for natural spawning Chinook in Willapa Bay in 2015 were not reached. The adjustments in non-tribal and tribal fisheries inside the terminal, combined with a recent lowering of the escapement goal, allowed us to reach escapement goals in Grays Harbor. Coho escapement goals were not achieved in either terminal even with the closures as once again the conservation burdon fell on the terminal fishers who waited patiently for their turn to fish as harvest continued on schedule on the ocean. As an example, the Humptulips in GH achieved less than 20 percent of its goal.

We recognize that the citizens who live on and around salmon bearing streams are stewards of those streams and will pay a significantly greater price than non-locals for the production of fish that are likely to be harvested on the open ocean. However, in providing this subsidy to fishers on the ocean, the harvest rate applied outside the terminals by the PFMC should not make it nearly impossible to achieve escapement goals or threaten the locals with the potential of additional burdens from ESA listing of species in the future.

In a recent appearance before the Pacific Salmon Commission, the Advocacy pointed out a problem with seasons set to the north. An example of the hardship placed on those inside the terminal was pointed out by quoting page 51 of PSC’s annual report on Chinook harvest (TCCHI- NOOK15-1_V1, PSC.PDF) which states in 2014 “....on average 86% of fishery-related mortality on WA coastal stocks” results from PSC sanctioned fisheries located north of the Canadian/WA border. As a direct result, the returning runsize of Chinook natural spawners coming across the bar into Willapa was reduced below the escapement goal.

In simple terms, the number of natural spawning Chinook heading for Willapa Bay was reduced by harvest in AK and BC in PSC sanctioned fishers to the north and once again in PFMC seasons off the coast. As the result of those two regulatory schemes, the runsize was reduced to below the escapement goal making achievement of the goal impossible even if all fishing inside the terminal was canceled. It is important to note that this phenomena is not limited to 2014, but rather the norm in Willapa for over a decade. Neither is it limited to just Chinook as the runsize below escapement goal occurred in 2015 for coho in both terminals resulted in season cancellations though seasons on the ocean proceeded forward on the initial schedule.

In accordance with the Advocacy’s purpose referenced earlier, it is our belief that the elected officials and citizens of Washington state should have the opportunity to fully understand all the reasons why the billions already invested by Washingtonians have not produced the anticipated conservation results and the list of threatened or endangered stocks continue to grow in Puget Sound and elsewhere. It is therefore our intention to engage all in a long over-due discussion re- guarding the reasons why the state is plagued by the failure to recovery natural spawning salmon stocks.

The latest indicator of the need for such a broad based public discussion is the overfishing notice recently published by NOAA in the federal register for Willapa Bay and Grays Harbor fall

Chinook and coho in the Hoh River further up the coast. We believe the citizens will quickly ask “Where is all this fishing occurring?” With 86% of fishing mortality occurring north of the WA/ Canada border, we expect most eyes to first turn to the PFC processes. The question we expect to hear is “If we can’t get PFC to let enough back to the streams to meet escapement goals, where’s the incentive for Washingtonians to continue pouring billions of dollars in public and private resources into habitat restoration and hatchery production?”

The next point of reference will be the ocean harvest installed by PFMC off the coast. While of less impact than the northern fisheries, the PFMC seasons “piggy-back” onto the northern harvest leaving the citizens within the terminal a minor portion of the return even though they are the ones primarily footing the bill for the productions costs that feeds all on the open ocean.

At this point, the Advocacy doesn’t have an explanation that we are confident the majority of citizens of Washington would find acceptable. Especially when responding to the family living on Willapa Bay that recently lost a quarter of a million dollars in harvestable timber due to set- backs intended to protect habitat for natural spawners that have yet to materialize in the nearby stream due to harvest impacts, primarily on the open ocean.

As we move forward in our project to engage all in discussions about how we can restore natural spawning stocks in Washington, the Advocacy respectfully requests that the PFMC consider seasons that reduce the impacts on natural origin salmon stocks that have either struggled to meet escapement goals or already been noted under ESA guidelines. In the case of Willapa Chinook and Hoh River coho, we are requesting a decrease in impacts on natural spawners incurring in PFMC sanctioned fisheries. Same as the request made to PSC, a reduction of 10% per year for five consecutive years or until such time as the number crossing over from the Pacific is forecasted to be at least 110% of the escapement goal for two consecutive years.

We end by asking for personal consideration from each of the voting members of the PFMC. Specifically, when setting seasons off the coast, we ask each of you to simply ask yourselves two questions prior to voting. The first is “Will the seasons being proposed for the ocean create an incentive for the citizens who live inside the terminals to continue to invest billions into habitat restoration and hatchery production that supports ocean harvest?” The second is “Will
the number of fish allowed to return to the coastal terminals allow managers a reasonable ability to achieve escapement goals for natural spawning stocks?” If the answer is no to either, we ask each of you to soundly reject the proposal.

Respectfully,




Tim Hamilton Art Holman Ron Schweitzer
President Vice-President Secretary/Treasurer
cc: The Honorable Members of the WA Fish & Wildlife Commission Director Jim Unsworth, WDFW
Assistant Director Ron Warren, WDFW Fish Program