Two wrongs don't make a right. That is, allowing a kill fishery the last several years on weak populations doesn't justify allowing incidental mortality (via C&R) on a weak run this season. Or incidental mortality during a fishery targeting the hatchery run.

Having said that, I share your concern about closing the C&R fishery on one or two systems, thereby increasing the pressure - and incidental mortality - on the rivers that remain open. I'm also concerned about narrow views of conservation.

The issue would seem to hinge on predictability and risk. Oh, yeah, and policy, which may, or may not, be well informed.

About predictability, how does wild steelhead run size correlate with brood year escapements? From what I've seen of data, run sizes only correlate to brood year escapements when escapements are extremely low, likely below some critical threshold that reasonably seeds a system with fry. Escapements well below the official escapement goals have produced excellent returns, and high escapements have produced low returns. This is one reason, I think, why the Skagit tribes don't agree with WDFW's escapement goal.

Steelhead run sizes are a product of much more than brood year escapement. Freshwater rearing conditions and ocean survival are as important an indicator as escapement of run size. These are significant variables. The 90s generally saw low ocean survival coupled with either flood or drought or both, which depressed those runs. Ocean survival is increasing this past year or so.

Further, this year's 4 year olds experienced no floods or droughts. Five year fish would have experienced the Feb. 96 flood. It is important to note that flood effects don't correlate nearly so well for steelhead as salmon. (Spring vs. fall spawners. Juvenile steelhead are relatively safe if they find flood refuge.)

My thought is that 2 of 3 significant indicators of run size point to increased production over the last decade. I don't know what the brood year escapements were, so I can't comment on that variable.

After considering predictability comes risk assessment. What is at risk? The risk of not meeting the escapement goal. Just what is the escapement goal a measure of? If it is a measure of the number of spawners, on average, that is required to maximize production or harvestable surplus, on average; do the availbable data support that declaration? I doubt it. Escapement goals for steelhead have been set either arbitrarily or through composite habitat parr productivity estimates. I don't think any steelhead escapement goals have been set through spawner-recruit analysis, which is the only method that empirically supports its conclusions. However, I digress; S-R MSY/MSH analysis usually picks escapement goals that maximize short term harvest that is not sustainable over the long term because the environment changes and long term data don't exist.

What I'm trying to get at regarding the steelhead escapement goal, is that it doesn't deserve its high regard given how it was developed. And it is important only because the managers and many of the constituents (anglers) are incredibly devoted to killing as many wild steelhead as possible every year.

The state has choices. They say they must implement the legislative mandate of "preserve, protect, perpetuate, . . . allow utilization . . ." like there isn't much choice. Preserve, protect, perpetuate seem clear as my favorite stream. And the state has done these so well that several steelhead stocks are now ESA listed. As for utilization, we know there is more than one way to utilize. Killing wild steelhead might be a traditional use, but that doesn't inherently make it the highest and best use under contemporary social values and conservation circumstances. The only choice the state has no voice in is meeting treaty fishing obligations. Fine, the state and we are not obligated to hold that same value. We are free to choose differently for the non-treaty share of the resource.

We could choose to exercise a high degree of preserve, protect, and perpetuate and offer extensive utilization in the form of recreational opportunity via C&R fishing seasons. We could ask for the application of some common sense in this judgement. For instance, the Deer Creek summer steelhead population would qualify for ESA listing if it were its own ESU. Yet anglers C&R fish for them all summer and fall year after year on the Stilly because there is a wild steelhead release regulation. And this is an under-escaped population. Would a ban on fishing on the Stilly year round improve the Deer Creek population? No, not really. A handful of fish that are lost to incidental mortality would survive to spawn. And that would be good, but it wouldn't make a significant difference ecologically. The reason is that the Deer Creek population will recover at about the same rate as its horribly degraded habitat recovers.

So what are the risks of allowing the customary C&R season? If the risk is that the escapement goal may not be met again, but that the steelhead productivity is about as good as it is going to be under extant environmental conditions, then what purpose of regional ecology and conservation and contemporary social value is served by closing the C&R season on the Snohomish and Stillaguamish River systems?

And if by chance there is some redeeming biological value, then how can we justify allowing incidental mortality of wild steelhead during the hatchery target season and closing the March-April C&R season. Surely an early season wild steelhead is as valuable (in the form of diversity) as a late run fish to the population as a whole. Making a decision to allow the hatchery season with a wild fish release regulation is an arbitrary determination that the early season wild steelhead is more expendable than his later running brethren. Simple biology and genetics rejects that argument - Patooey!!

I hate to seem to be arguing against conservation. I prefer to think of myself as more a conservatinist than self-centered angler. But I just can't help but think this proposed closure is based on a rather narrow view of biology, escapement goal concepts, incidental mortality, and conservation.

Thank you for tolerating my rant. Perhaps some of this will be useful to you as you prepare your own arguments to Region 4 and the WDFW Commission.

Sincerely,

Salmo g.