Thought I would post this up for folks watching Willapa. Tim, Ron & Art have pretty much stayed right on the Willapa policy as the agency has a rather short memory as to what words mean let alone what a paragraph was intended to portray.

January 2, 2018

Twin Harbors Fish & Wildlife Advocacy
PO Box 179
McCleary, WA 9855

To: The Members of the WDFW Commission via: email in PDF format Re: Response to Department Presentation and Comments on Willapa Bay
The Twin Harbors Fish & Wildlife Advocacy and members of the public have invested thousands of hours and tens of thousands of dollars into the development of the Willapa Bay Salmon Management Policy (C-3622). We offer the following comments regarding the presentation provided the Commission by Region 6 Fish Program Manager Annette Hoffman during the regular meeting on Saturday, Decem- ber 9, 2017.

First, the presentation was smoothly delivered and contained numerous tables, charts and graphs. How- ever, unless a person was very familiar with the data and history in Willapa Bay, we believe the public could come away from the presentation under false or inaccurate impressions.

The Willapa Bay Policy states:

The objective of this policy is to achieve the conservation and restoration of wild salmon in Willapa Bay and avoid ESA designation of any salmon species.

The presentation by the Department was vague at best about conservation, restoration of wild salmon, or our progress in avoiding ESA. Conservation over harvest does not appear to be a Department priority when one viewed the presentation.

In the week following the presentation to the Commission, Ms. Hoffman offered the first conference call of the season with the Willapa Bay Advisors. The outcome was the Advisors were told the Department would likely fail to reach escapement goals on natural spawning Chinook, Coho, and Chum in Willapa Bay in 2017. The Department either did or, should have known, this fact at the time of the presentatio Many in the public had come to that conclusion over a month earlier. Zero for three on reaching natural spawning escapement deserved prominent notice in the presentation.

To further understand the conservation problems in Willapa Bay, turn to hatchery egg take which is the lowest performance bar one could establish. The Department missed hatchery egg take for Chinook.
Then, Chum too if not for efforts to “mine the gravel” as Chum were snagged or dip netted in the spawn- ing grounds of other streams and transported back to the hatcheries. Now comes an emergency rule cutting rec bag limits down to the minimum (1 clipped Coho) on January 1st. The reason provided was
a fear the Department would not make hatchery egg take on Coho either. Without mining for Chum, the Department seems to be approaching zero for six on reaching escapement goals. Is it possible to get any worse than that?

How could such a result not be included in the presentation? Advisors in the conference call asked this very question of Ms. Hoffman and were told the data was all in there, you just have to add up the dif- ferent numbers. The response was “Do you think it is appropriate to expect the members of the Com-

mission to figure out how to do that (paraphrasing)? Since the priority is conservation first and harvest second, zero for six should have made it into the presentation. The fact the Department failed to point out the failure to reach escapement goals in it’s annual review in a clear and precise fashion is telling on its own. Neither members of the public or members of the Commission should be required to retain a forensic accountant to figure out success and failure in reaching escapement goals in Willapa Bay.

Perhaps the most alarming factor to many viewing the presentation to the Commission was some of the comments offered by Ms. Hoffman. It seemed to many present that she was somehow trying to claim the only major problem facing us in 2018 was “Allocation of Available Impacts” (See Slide #21). Then, her comments left many with the belief she was promoting the notion that the recreational sector had exceeded the share of the catch the Commission intended when passing the policy. Recognizing Ms.
Hoffman was stationed in Region 4 and not present during the passage of the policy, we can not find a source for this claim on the public record and the Advocacy members attended every Ad Hoc Meeting and Commission meeting wherein the policy was discussed.

Regardless, the facts are again telling. When one compares the impacts (fish killed) by the recs and nets bay wide the impression recs were somehow exceeding the commission expectation by a factor of two is clearly debunked. Using the data in the Dept’s Excel spreadsheet filed with passage of the commercial

Willapa Chinook NOR Impacts (Bay Wide)
Year Nets Recs Net % Recs %
2014 2,553 205 92.6% 0.074
2015 606 243 71.4% 0.286
2016 385 149 72.1% 0.279
Total #s Average % 3,544 596 78.7% 21.3%

season in WB in 2017, the Advocacy found the last three years wherein data is available for both sectors (2017 rec data is not available at this time). The impacts on Chinook natural origin spawners (NORs) provided the commercial nets averaged 78.7% of the total bay wide terminal impacts and the rec sec- tor averaged 21.3%. It is noteworthy that the policy establishes a rec priority for Chinook and the same for the nets on Coho and Chum. The one with the priority gets to use all the available impacts and any remainder goes to the other. How does the recs historically taking only 21% of the impacts align with Ms. Hoffman’s comments that they somehow were using twice the impacts as intended by the Commis- sion when the policy was passed?

In fact, Ms. Hoffman’s comments are contrary to the actual language of the policy which states:

4. Fishery Management Objectives. The fishery management objectives for fall Chinook salmon, in priority order, are to:

a) Achieve spawner goals for the North, Naselle, and Willapa stocks of natural-origin Chinook and hatchery reform broodstock objectives through the two phase rebuilding program described above.

b) Provide for an enhanced recreational fishing season. The impact rate of the recreational fishery is anticipated to be ~3.2% during the initial years of the policy, but may increase in subsequent years to provide for an enhanced recreational season as described below:

c) Manage Chinook salmon for an enhanced recreational fishing season to increase participation and/ or catch including consideration of increased daily limits, earlier openings, multiple rods, and other measures.

d) Conservation actions, as necessary, shall be shared equally between marine and freshwater fisheries.

e) Provide opportunities for commercial fisheries within the remaining available fishery impacts.

As for increasing the rec impacts in the future, clearly the Commission not only recognized but encour- age this to happen. While the increase occurred faster than some thought would the case, it is important to note that the declining rec opportunities statewide and the Departments fishing reports, etc. led to an increased pressure as WB was promoted as the best opportunity for recreational license holders. The result was the local community shared with the rest of the state the resource which encourages license sales by the Department. It is time to insert the old saying “No good deed ever goes unpunished”?

Prior calculations used the actual impacts and the percentage of the impacts between sectors. The Harvest Rate is a percentage of the fish killed compared to the runsize. Reviewing the Department’s presentation, slide #10 shows the harvest rate of the recs on the Willapa Bay (marine)@ 9.6%, Willapa River @ 14.9%, and Naselle River @6.1%. The font for the Willapa River is set in red as if to point out this is a problem (rec sector taking more than anticipated?).

Returning to the spreadsheet utilized by the Department to set the seasons in 2017, the data does not sup- port the impression recs in the north have somehow overpowered commercial fishing. From 2014-2016 the nets took an annual average of 1,181 Chinook impacts (bay wide) and the recs in the marine and freshwater up north took 150. Would a transfer of impacts from the northern rec sector provide an eco- nomic surge for the nets? Hardly, unless one terminated rec fishing in the north nearly entirely. One can now see why those who understood the implications of Ms. Hoffman’s comments immediately became alarmed over the future of recreational fishing in WB, especially in the north.

What would be the purpose of the Department seeking to convince the Commission to shift impacts from the rec sector to the commercial sector? The most logical answer the Advocacy could develop is the Department is seeking to transfer rec pole impacts to the commercial sector to allow use of non- selective gillnets during Coho run time. The use of gillnets over the more-selective tangle net would
increase the mortality on the late portion of the Chinook NORs mixed in with the Coho requiring extra Chinook impacts from somewhere. Where does the Department look for them? In the north where most of recreational fishing occurs seems to be the direction the Department is headed.

The Advocacy tries to avoid allocation battles and maintains the belief that a dead fish is a dead fish re- gardless of the gear type used to kill it. However, moving the impacts from the most selective (pole) to the least selective gear (gillnet) is punishing those who have adopted selective fishing. Certainly not an effort to improve conservation performance and ironically, would likely prove be the equivalent of “put- ting a Band-Aid on an open chest wound” for the commercials. Further, it is contrary to the language of the Policy which directs the Department to: “Pursue implementation of additional mark-selective com- mercial fishing gear to enhance conservation and provide harvest opportunities”. The Policy does not contain a provision calling for transfering rec impacts to the commercial sector so the Deptartment can provided additional harvest opportunities for non-selective gears.

The economic reality of commercial fishing is not based on who gets the larger portion of the impacts as

Page 4, Commission Presentation by Dept
shown on a computer model (effect of moving impacts). That just gets them a few extra days of the season or increasing the use of non-selective gillnets over tangle nets during season adoption in NOF. Rather, it is primarily the run-size coming back into the Bay that puts fish in the boat and makes both sectors “winners or losers”.

As we pointed out in our comments to the commission following the presentation, the commer- cial sector caught 198 less Chinook this year than landed the previous year. The Coho crash in 2017 resulted in a drop of 14,729 from the previous year. Clearly, it wasn’t Chinook that broke the bank this year and neither was it using more selective tangle nets. Rather, it was the simple fact that Coho were in such small numbers the commercials stayed home many of the days when they were able to fish.

Are the smaller runs the result of passage of the policy? No. The small run sizes in 2017 are the results of “sins of days passed” under the management schemes used prior to the passage of the policy wherein the gillnet dominated the Bay. As a result, we’ve failed to make escapement goals 7 years in a row. For Coho, which were thought to be in the best shape, we’ve missed escapement goals 2 out the last 3 years. Then in a Bay which historically had huge runs of Chum which were the backbone of commercial fishing, we’ve failed to reach escapement goals 11 out of the last 13 years. It is important to note that the Advocacy and many who have studied WB fear the runsizes have yet to bottom out. Runs will likely decline even further due to low ocean productivity, warmer climates, and the continuing failure to meet escapement goals.

Recently, the Court soundly rejected the assertion by the Willapa Bay Gillnetters Association that a gillnet license holder’s profit margins are on an equal par with the state’s duty to manage for conservation. At this point, one wonders if the Department listened to its own successful argu- ments in that case. Regardless, it’s time for the Department Senior management to realize it can not provide harvesters with fish that are not in the water. Rather than continuing to open up old allocation wounds, the Department needs to address the conservation problems and take mea- sures that restore the run sizes.

In closing, the Advocacy sincerely hopes that the Commission will allow the public time to digest the content and comment on presentations from the Department related to the Willapa Bay Salmon Policy before reaching mindsets or adopting positions on requested actions. As one Commissioner noted last meeting, it is very difficult to respond quickly in 3 minutes at the mike. The Commission Members have similar challenges. We would point to that old saying on the radio of “Now.......for the rest of the story.”

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