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#1011808 - 07/16/19 07:59 AM Are there Pinnipeds in Grays Harbor?
Soft bite Offline
Juvenile at Sea

Registered: 11/11/08
Posts: 142
Loc: Central Park
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.

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 [7]. 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 [8]. 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.

#1011810 - 07/16/19 08:21 AM Re: Are there Pinnipeds in Grays Harbor? [Re: Soft bite]
DrifterWA Offline
River Nutrients

Registered: 04/25/00
Posts: 4672
Loc: East of Aberdeen, West of Mont...
Soft bite:

Hang in there, WDFW marches to the beat of its own drum.

Anyone that has fished the Chehalis/Humptulips marine area, or the Chehalis River above the 101 bridge knows that the sea lion and seal population has been on the increase.

Videos of the NT and QIN gill netting, during their scheduled fishery would show how many fish are taken "right out of the nets" during a set time.

Videos of just the 1 QIN set net, Swanson's South Side, during the time that net is fishing.....should be a eye opener!!!!! I've sat there for different time periods, just watching the Sea Lions pick fish out of the net.....grrrrrrrr

"Worse day sport fishing, still better than the best day working"

"I thought growing older would take longer"

#1011828 - 07/16/19 11:16 AM Re: Are there Pinnipeds in Grays Harbor? [Re: Soft bite]
Larry B Offline
River Nutrients

Registered: 10/22/09
Posts: 2855
Loc: University Place and Whidbey I...
Talk about not passing the whiff test:

"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."

Or is that simply the "ostrich" approach to addressing the issue?????
Remember to immediately record your catch or you may become the catch!

It's the person who has done nothing who is sure nothing can be done. (Ewing)

#1011829 - 07/16/19 11:26 AM Re: Are there Pinnipeds in Grays Harbor? [Re: Soft bite]
FleaFlickr02 Offline
River Nutrients

Registered: 10/28/09
Posts: 3004
Looks pretty typical. Underestimating competition for scarce resources to the end of justifying higher exploitation rates by one user group or another is WDFW's bread and butter. They are also fond of overestimating recreational bycatch and dropout rates, much to the same end. The 1997 study, woefully outdated as it is, is just another tool in the commercial harvest justification arsenal at this point.

#1011852 - 07/17/19 08:28 AM Re: Are there Pinnipeds in Grays Harbor? [Re: Soft bite]
Salmo g. Offline
River Nutrients

Registered: 03/08/99
Posts: 12907
We often forget that the purpose of harvest management is harvest, not conservation.

#1011859 - 07/17/19 09:07 AM Re: Are there Pinnipeds in Grays Harbor? [Re: Salmo g.]
Rivrguy Offline
River Nutrients

Registered: 03/03/09
Posts: 3472
Loc: Somewhere on the planet,I hope
Having spent many a lunch time setting on the wall behind Walmart watching the drift nets it is a issue. It is really easy to count how many fish the Sealions get. They will pop their heads out of the water and swim upstream toward a net watching and when they see the floats bob charge. If they get one the seagulls zoom in for scraps even if the sealions do not do the rip & splatter with the head shake. They are most deadly early in the fall and seem to really prefer Chinook. The other side of the coin that is when they get the first opportunity and are hungry. Later you go they are not as aggressive but greater numbers of fish. If the nets are not in they will follow the fish upstream but more seals do this, prefer Chum, and like to charge into a school or chase the fish into the shallows.

One thing I find weird is both sealions & seals prefer live fish and seldom take a dead fish out of a net. Now why they then are willing to rob one hanging dead as a door nail off the back of my boat is beyond me!

Edited by Rivrguy (07/17/19 11:32 AM)
Dazed and confused.............the fog is closing in

#1011861 - 07/17/19 09:42 AM Re: Are there Pinnipeds in Grays Harbor? [Re: Soft bite]
blenny Offline

Registered: 12/19/18
Posts: 26
It seems like a sick joke to call something "best available data" when the study barely looks at terminal fisheries and the predation that happens. Even sicker that its 20 year old data- they actually have studies published on the wdfw website that show the significance of pinnpiped predation on outmigrating steelhead smolt.

"A major shift in the Puget Sound food web
occurred in the early 1990s (Harvey et al. 2012).
Although the specific causes are un known, several
previously abundant demersal species (Pacific cod
Gadus macrocephalus, hake Merluccius productus,
rockfishes Sebastes spp.) and some pelagic (Pacific
herring Clupea pallasi) stocks suffered steep
declines (Gustafson et al. 2000, Drake et al. 2010,
Landis & Bryant 2010). Concurrently, marine survival rates of larger-bodied salmonid smolts (steelhead and coho salmon) also declined (Scott & Gill
2008, Zimmerman et al. 2015). These changes
occurred at the same time that harbor seal numbers
increased following implementation of the federal
protections for marine mammals (Jeffries et al.

#1011875 - 07/17/19 05:12 PM Re: Are there Pinnipeds in Grays Harbor? [Re: Soft bite]
Carcassman Offline
River Nutrients

Registered: 11/21/07
Posts: 5855
Loc: Olema,California,Planet Earth
If you don't collect new data, or local data, then what you have is the "Best Available Data" (BAD). Ask Rivrguy about the release rates they used for WB Chinook released from nets.

There is, unfortunately in natural systems, always a justification for throwing out data that doesn't fit the model. Sometimes, the justifications are better than "We want to go fishing".

#1011883 - 07/17/19 10:28 PM Re: Are there Pinnipeds in Grays Harbor? [Re: DrifterWA]
fish4brains Offline
Dah Rivah Stinkah Pink Mastah

Registered: 08/23/06
Posts: 6374
Loc: zipper
Originally Posted By: DrifterWA
the 1 QIN set net, Swanson's South Side,

that one net gets a LOT of fish
Propping up an obsolete fishing industry at the expense of sound fisheries management is irresponsible. -Sg



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