The Grays Harbor WAC process is now complete. The past three years I provided public input in the form of a request to collect valid salmon mortality data due to pinniped harvest for the Grays Harbor harvest model. WDFW justifies using an inappropriate data point from a 22 year old report that was from out of the area. If my pinniped harvest estimates are even close then the existing model counts most of the harvest as escapement. YGTBFKMR?
Following is a copy of my input and then the departments CES response.
Subject: Public comment for CR-102 for Grays Harbor filed as WSR 19-11-076 on May 16, 2019
Date: June 14, 2019
Last year I submitted the attached file as public input for Grays Harbor. I am resubmitting it as it is still pertinent.
It states estimates for pinniped harvest based on my observations. Specifically, I estimate 50% of the fish that impact a set net are taken by pinnipeds. For drift nets the estimate is 20% of impacts. This is in addition to the 2-3% of the fish that fall out when the net is being pulled. There is also a small loss for pole caught fish and an unknown loss of released fish.
In the 2018 CES the department claims that a 3% drop out for chinook and a 2% drop out for coho includes the pinniped harvest. This is based on a 1997 Pacific Salmon Commission report for losses in the open ocean. The report also found 8% losses in Puget Sound which would be more applicable to Grays Harbor conditions. It found that rates were highly variable from fishery to fishery and noted one chinook dropout rate of 87% in Puget Sound in 1982. Twenty-two years ago those may have been good estimates, but pinniped populations have increased by several hundred percent since then. The Puget Sound estimate expanded by the pinniped population increase could easily be in the range of the above estimates.
The nature of the model is that the calculated escapement estimate is the result of taking the run size estimate minus the gill net harvest minus the 2-3% net drop out minus the recreational harvest and minus the release mortality. The result is that most of the pinniped harvest is counted as escaped spawners. The real result is over harvest and the risk of not meeting escapement goals. This is especially true for the weakest runs.
Some of the staff have worked on gill net boats as observers and surely must know that pinniped harvest is significantly higher than the estimate used in the model. Use of this model to plan harvest and escapement is seriously flawed.
I am asking you to collect good pinniped harvest data this fall season for future modeling use and if the data confirms the higher mortality then consider in-season management to protect weak run escapement this year.
The CES response is posted below and can be found here on page 10. https://wdfw.wa.gov/sites/default/files/2019-07/2019ghcommercialfallfisheriescesfinal7.9.19.pdf
Comment 2: Commenter expressed concern that salmon mortality caused by pinnipeds was not
being considered in the proposed rule, and the proposed rule “could not be justified if the
significant pinniped losses were properly accounted”.
WDFW understands pinniped depredation occurs during fisheries in marine waters;
correspondingly, an additional “drop-out” mortality rate of 3% for Chinook and 2% for coho were added to the harvest rates during the development of the proposed rule. In a recommendation by
the Pacific Salmon Commission (PSC) in 1997 estimated mortality rates were applied to account for non-harvest mortalities incurred, such as pinniped depreation, by the prosecution of
commercial fisheries . Additionally, the estimated mortality rate of pinniped derived mortality in the PSC recommendation may be overestimated within Grays Harbor because research has
shown a positive correlation between soak-time and drop-out rates; thus, short soak-time (≤ 45 min) as practiced in Grays Harbor may overestimate the influence of depredation when using PSC
recommendations . On the other hand, WDFW understands pinniped derived mortality rates predicated upon the PSC recommendation rely upon the assumption that pinniped depredation is independent of pinniped population density. Without additional data associated with pinniped abundance coupled with an estimate of the probability of pinniped depredation as a function of
pinniped abundance, WDFW will consider the PSC recommendations as the best available science.