I just got this response from the Commission. I assume it's a cut and paste that they sent to lots of people, because it attributes a few statements to me that I never said.

There's a chart at the bottom that doesn't cut & paste well, so I've left it out.

(sic) throughout.

"Thank you for sharing your concern regarding the harvest of Snohomish wild steelhead in Tulalip Treaty fisheries. As you point out the Snohomish stock of steelhead is listed under the federal Endangered Species Act (ESA); it is a component of the Puget Sound evolutionary significant unit which was listed in 2007. As a result both state managed sport fisheries and tribally managed fisheries with impacts on these stocks are required to be permitted by NOAA Fisheries. As part of the listing and permitting process NOAA develops what is called a Biological Opinion in which it assess factors associated with our fisheries and the likelihood that our combined “action” – the fisheries being assessed – will or will not “pose jeopardy to recovery” of the stock. In their assessment, NOAA Fisheries looked at our future fisheries with the expectation that they would remaining at levels similar to those which immediately preceded the listed. The basis for this is rooting the fact that the co-managers had taken significant actions to reduce impacts in the years prior to the listing. In their assessment NOAA Fisheries viewed harvest impacts on wild winter steelhead relative to “historic levels”; here again, that period immediately prior to listing – 2001/02 through 2006/07 fishing season. Their assessment focused on the 5 key stocks (Skagit, Snohomish, Green, Puyallup, and Nisqually); for the aggregate the average harvest rate identified by NOAA was 4.2%.



With that as the backdrop for developing a fishery management plan for the 2017/18 season, co-managers craft fisheries based on historical rates of effort and catch. In this system these rates are considered to be conservative given actual effort and catch when assessed in the post-season context. The forecast runsize for the 2017/18 season is 3,000 wild winter steelhead and the total predicted harvest impact is 3.4% (73 fish in the Tulalip fishery and 27 All citizens sport fishery). This is associated with a Tulalip fishery that is predicted to harvest 66 hatchery origin winter steelhead and a sport fishery which is predicted to harvest 2,271 hatchery origin steelhead.



In your correspondence you state that “there are no harvestable hatchery wild steelhead in the lower reaches on the Snohomish system at this time of year”, from historical data we see that the fishery has harvested hatchery fish into March. From our perspective removing adult hatchery fish from the system is a good thing. You also indicate that the Tulalip Tribe has not fished for steelhead in these areas during this time of year in a very long time, to the contrary, while the Tulalip Tribes’ fishery has very little effort – particularly in the past 5 seasons – this regulation is very similar to those issued in recent years. Their total catch of wild fish in recent years has substantively declined; date for three recent five-year periods is summarized in the table below:



5-year season range


Average annual harvest of wild winter steelhead

2002/03 - 2006/07*


31.2*

2007/08 - 2011/12


18

2012/13 - 2016/17


1.6

* all fisheries were closed due to a low predicted run-size in 2002/03; taking that season out of the average would result in an average of 39 fish/year.



I point out this catch information because I think it is important in the context of the impacts predicted to occur versus their actual fishery; i.e. we would anticipate something far less than 73 wild.


For comparison Snohomish sport impacts over the past 10 years have averaged an estimated annual hooking mortality of 28 wild winter steelhead and an average annual harvest of 3,001 early winter hatchery steelhead.


The management plan also includes language which states that co-managers will exchange information through the end of week 5 (end of January), to determine how the remainder of the season will proceed. The threshold for this trigger is based on effort and catch of wild winter steelhead. From the start of the fishery in December through February 5 the Tulalip harvest were 2 unmarked and 17 marked steelhead reported; therefore these was co-manager agreement to proceed with the remaining schedule. Another provision in the plan says that the tribe will closely monitor the fishery and close if catch approaches the pre-season modeled value for wild steelhead. Suffice it to say WDFW sees no justification for or options by which we would object to the fishery."