May as well add my Willapa Policy comments, too...



I am deeply concerned about the way WDFW Fish Program and the Region 6 staff are implementing YOUR Willapa Bay Policy and the intellectually dishonest manner in which they attempt to hide their management failures from you…. THEIR BOSS!

A bit of historical context helps to set the stage.

Let’s start with the most fundamental conservation tenet of the Policy…. rebuilding a wild chinook population that historically has been ravaged by a century of harvest and hatchery abuses. Let’s be CLEAR that the primary impetus for crafting this Policy is recovering a healthy self-sustaining population of natural origin chinook in the basin. WDFW’s best scientific models predict that recovery to the agency’s natural origin escapement goal is possible within 16-21 years ONLY if harvest becomes more hatchery-selective AND releases of hatchery chinook are sufficiently tempered in order to markedly reduce pHOS (the proportion of hatchery strays on the spawning gravel)…. while concurrently curtailing the in-basin exploitation of natural origin chinook to an impact cap or harvest rate of 14%. This is the level of harvest restraint necessary to rebuild the stock in 16-21 years. Exploitation at any rate exceeding 14% would only serve to flatten the rebuilding trajectory, delaying or perhaps extinguishing any possibility of recovery…. EVER!

The commercial advisors balked at a 14% impact objective right out of the gate, arguing that a significant cohort of hatchery chinook from prior large releases were still grazing the ocean pasture. These fish needed to be caught as they returned to Willapa Bay to keep them off the gravel, so gillnetters argued that a 20% impact cap would not only soften the blow to their fleet, but also help them to remove more hatchery fish to improve the glaring pHOS problem on the spawning grounds.

The Commission went along with this compromise to phase in the 14% impact cap by allowing a “transition” of 4 years to allow a 20% harvest rate. Incentives are built into the policy to ramp up the implementation of selective gears during the transition with a goal of at least 6% allocated to alternative gear. The Policy requires an annual review of fishery impacts and includes an insurance provision or “payback clause” to maintain the rebuilding trajectory if the harvest rate is exceeded in any given year.

So how are we doing on natural origin chinook recovery? Are we hitting the conservation benchmarks spelled out in the policy? How well is Region 6 / Fish Program fulfilling the deliverables spelled out on the Policy?

To put it bluntly, staff is failing the Policy and you the Commission… MISERABLY!

But how would the Commission even realize this when staff refuses to include a PowerPoint slide/graph showing the historic escapements relative to the natural origin spawner goal. Upon identifying the oversight in the PowerPoint prior to the staff presentation, I personally asked that the slide be included. This advisor request was REJECTED by staff, citing that achievement of the natural escapement goal is NOT a staff objective during the transition, but rather one reserved for 16-21 years out. The objective metric during the transition is a 20% harvest rate, so that’s what they would present to the Commission.

But they didn’t even do that. The truth is they are batting a thousand on exceeding the 20% harvest rate, but were too cowardly to tell you outright. Instead they cleverly parsed up the exploitation by each sector…. commercial, marine recreational, and freshwater recreational… to intentionally muddy the waters to disguise yet another year of over-harvest.

When I confronted Annette Hoffman about the glaring error of omission, her response was simply. “It was all there, all you had to do was just add it up.”

<< Are you fooking kidding me >> (and no I didn't send that part... READ ON)

So I ask you, how many commissioners were familiar enough with the spreadsheets to “just add it up” on the fly from two spreadsheets presented FIVE SLIDES APART during the last Commission meeting? Prior to my testimony in the public hearing, how many of you were honestly left with the impression that the rate had been exceeded yet again? Hmmmm… I wonder why.

Not once since the Policy took effect has staff delivered on the already lenient 20% impact cap. It has been EXCEEDED every year. What’s worse is that they couldn’t muster the intellectual honesty to tell you straight up. This inexcusable pattern of staff-sanctioned over-exploitation under the leadership of Annette Hoffman mirrors exactly that of pre-Policy management under the leadership of Ron Warren. When the Policy says to shoot for 20%, they deliver 25-27% instead. When it was 30% pre-Policy, they consistently delivered 36-38%. Regardless of what goal you set before them, Region 6 staff is still habitually overexploiting the Willapa harvest objectives by a margin of 25-30%.... NOTHING HAS CHANGED ! ! !

And what about the payback clause? Not once has staff considered invoking it to pay for past sins. Instead they look for weasel words in black and white to justify why the clause does NOT apply. Once again, where is the intellectual honesty? Are they serious about recovery within the 16-21 year time frame? And will they hold themselves accountable to maintaining the rebuilding trajectory?

This is exactly like an undisciplined fat kid whose doctor/dietician has laid out a perfect plan to slowly get him back to a healthy weight over the next 16-21 months. The first 4 months, the doctor gives Fat Albert a break by allowing him 2000 calories a day to lessen the shock from his typically obscene 3600-3800 caloric intake. Eventually Albert’s got to whittle down to 1400 calories a day for this health plan to work. But he just can’t help himself. He’s just got to snarf down that extra 500-700 calories. Besides, he’s thinking who’s really gonna know… and who’s even gonna care?

So I ask you, will Fat Albert ever reach his goal in 16-21 months if he’s habitually sneaking an extra 25-30% in calories without telling his doctor? If he can’t hold himself accountable to the plan, then who will?
"Let every angler who loves to fish think what it would mean to him to find the fish were gone." (Zane Grey)

"If you don't kill them, they will spawn." (Carcassman)

The Keen Eye MD
Long Live the Kings!