Larry -
Please note that I limited my "math" exercise to the San Juans just as the State did in their report. Regardless it does indicate an error.

It is precisely this sort of thing that the DEIS is designed to catch. As we provide comments the State has to address those comments and as need make the needed changes in the final EIS. One would hope that any correction would elevate that status of the seal predation stressor.
It will be interesting to see if that changes recommended actions or the selection of alternatives.

Does this one item make the DEIS a "fatally flawed" document? I don't think so (assuming the State adequately addresses it in the final EIS). However I'm thinking there may be other issues that maybe more critical however I'm still digging; hopefully I'll be able to get to it prior to the November 19th deadline.

Tight lines
Curt

A question I have is why the push for the regulation change when the DEIS/EIS hasn't been completed? There is the tight deadline for the DEIS (November 19) and the regulations are scheduled for final action in February with public input due by December 1. The DEIS inputs need to be reviewed and any changes incorporated in the final EIS. Seems to me that the regulation changes are putting the cart before the horse and might be best put on hold pending the final EIS.

Smalma:

I realized what you had done but wanted to be sure that first time readers understood the full impact of seal predation within the area covered by the draft Plan and, therefore, to be able to compare the Stressors actually set forth by WDFW in the draft plan.

You asked if this should invalidate the whole enchilada and suggested that it might not. I respectfully disagree.

This convenient omission is huge in terms of its impact on the listed species and also in terms of the hope for success and the amount of time that recovery might require (and when any forthcoming Draconian limitations might be lifted) for those three as well as all the other rockfish species of concern. It goes to the reasonableness of this non-project plan and subsequent projects initiated under its guidelines.

For comparative purposes the plan includes an annual sportfishing rockfish C&K figure of roughly 11,500 rockfish (not including C&R mortality). The plan suggests a goal is to reduce the opportunity for sportfishing encounters with rockfish. That sounds innocuous but the devil is always in the details as well as future interpretations (this plan needs a lot more details of what will and will not be promoted in discrete projects). If each seal consumes 123 rockfish per year the sportfishing rockfish C&K of 11,500 represents the annual rockfish consumption of 93.5 seals.

If the seal population is growing at 12% per year as my calculations suggest and using the State's 2007 seal population of 14,000 the annual growth figure would be 1,680 seals. Compare that to sportfishing's C&K of 93.5 seal equivalents.

Between the recent past WDFW rule changes (maybe not factored into the 2004-2007 averages) and the proposed changes there is not an awful lot that we can bring to the table to be applied to the rockfish recovery goal.

Unless and until WDFW incorporates into the plan a seal control program which reduces the impact of seals over the long haul and to a level sufficient to provide a realistic recovery opportunity no amount of controls on sportfishing will yield the desired result.

And that is why I believe that the draft Plan needs to be rewritten to recognize the 800 pound gorilla at the dinner table (they really thought we wouldn't see him there and mention his presence???) and then work the other ideas around that problem. Once the idea of lethal removal is thrown into the Plan the roof will come off (Chittenden Locks; Bonneville) and that is also why we need a new Draft subject to another round of preliminary review and comment (unless they really think they can sneak that into the final plan and get it approved and implemented without greenie lawsuits stopping the whole thing).

Larry

....the other problem we're facing is the proposed regulation (#10) which would implement the principals of the DEIS. The DEIS becomes moot.

Kicking around the math on the seals is good stuff and I think worth challenging the numbers and the assumptions that are connected to the numbers.

Most guys I talk to haven’t read the plan and don’t really care about rockfish. My personal opinion is that this plan is more about “other species” than it is about rockfish and I don’t understand the apathy.

This is from a slide from the Department’s Puget Sound Rockfish Conservation Plan PowerPoint presentation; it is their preferred alternative.

• All fisheries in Puget Sound waters will be managed to ensure the health and productivity of all rockfish populations

– Provides greatest benefit to rockfish because all stocks will be considered in management decisions
– All fisheries will be analyzed for impacts on rockfish
– Fishing opportunities for other species may be limited to protect rockfish

In my opinion the Puget Sound Rockfish Conservation Plan, as written, has the potential to be the most significant issue affecting salmon fishing in Puget Sound since the Boldt decision and only a handful of anglers seem to care.

One more sanity check for data presented in the WDFW draft Plan to Close Puget Sound to Recreational Fishing;

The average weight of harbor seals in Puget Sound is approximately 63 kg (140 pounds) and daily food consumption rates are approximately 4 % of body weight. <this works out to 5.6 pounds per day> page 34 draft PSRCP from WDFW

Adult harbor seals eat 5% to 6% of their body weight per day, about 4.5 to 8.2 kg (10-18 lb.).
Sea world fact sheet <http://www.seaworld.org/infobooks/HarborSeal/hsdiet.html>

NOAA data indicates Puget Sound harbor seals, on average, consume 8.7 pounds per day.

Derived from these NOAA publications;
Harbor seal consumption;
http://www.nwfsc.noaa.gov/publications/techmemos/tm45/risk.htm
1993 Harbor Seal Population;
http://www.afsc.noaa.gov/Quarterly/ond2002/ond02feature.pdf
(table 1 page 6)



If you think closing of Puget Sound because of rockfish is an extremest viewpoint,
PLEASE PLEASE PLEASE read this article and reconsider.

"The (MPA) law was passed after experts said catches of some species, including cod and rockfish, had fallen by as much as 95% in recent decades. Regulations limiting the number of fish that can be caught have failed to stave off the decline. Marine scientists fear it could lead to a collapse of marine life."

Link to LA Times Article

Gary, good information; please fix your link to the LA Times article.

Scary stuff right there.

It doesn't take much of an imagination to visualize an out of control seal population contributing to what man has already done to rockfish and herring stocks to get to the point that the Department would start shutting down increasingly larger areas to recreational fishing to fix the problem.

Overstated? Perhaps, but look where NOAA is headed with the Orcas and what has happened to rockfish, lingcod, crab and shrimp seasons/limits in the last few years. And it won’t take too much influence from other recreational and environmental groups to help push that concept forward.

Sealions and seals primary diet is high Omega 3 fish, herring salmon sardine candlefish smelt etc..When these are depleted they turn to other fish, rockfish sturgeon lingcod etc to supplement there diet but it won't sustain them. This was already tested with Bering Sea Pollock which was fed to captive Stellar Sea lions who rapidily lost weight even though they were given all they could eat.

Here is a link to pictures to include a great one of an elephant seal scarfing down a bocaccio - just sliding it down the throat and not looking a bit guilty that it is a threatened fish species!

http://seapics.com/feature-subject/fish/bocaccio-pictures.html

Slowleak posted the Plan's preferred management approach:

"All fisheries in Puget Sound waters will be managed to ensure the health and productivity of all rockfish populations."

Bocaccio is the species found by NOAA to be endangered with the other two being threatened. According to NOAA's findings and the draft plan Bocaccio has always been in extremely small numbers in P.S. Although it matures quickly (4-6 years) and egg production increases with age/size it's overall spawning success is poor. As with most of the rockfish it has intermittent successful spawns. Apparently Bocaccio are less successful than the others and spawning is highly susceptible to environmental conditions. NOAA had no records of these fish being seen in P.S for years and suggested that this species may have been extirpated (as in gone!). So, how does the State plan on managing to ensure the health and productivity of this species? Oh, it is also a deep water species found at 50 meters and deeper.

Bump

The more I read into the penniped portion of the proposal it makes zero sense why population control isn't addressed or why these numbers of seals are acceptable. I am sure no one, but us (concerned), wants to address the issue for fear of the hatchet. Anyone planning on asking the question during the (non recorded - how convenient) Q&A portion of the meeting tomorrow night?

What are the plans, timelines, goals for ghost net removal?

One issue that caught my eye in reviewing the Sound's MPAs is divers that frequently utilize these areas. Of particular interest are the smaller MPAs. Who's patrolling the divers? What or who is to say these areas are not being poached? What evidence is there of damage or stressors to habitat by frequently dropping or dragging an anchor around or even the divers themselves being in the area?

One thing I have noticed over the last few years is the lack of year around herring in the Gibson, Toliva, Ketron, Fox Point and Point Fosdick areas. Coupling this lack of herring with the amount of pinnipeds in the area makes me wonder if a diet shift to rockfish hasn't already begun.

I have had a steady diet of this draft plan for a few days and I still don't fully understand it. It is complex and I have a sneaky suspicion the plan is aimed more towards other species than rockfish. Like I mentioned earlier, I haven't caught a incidental rockfish in years in the South Sound- probably late 70s early 80's. These dates roughly coincide with the last time the draggers came though. If Mother Nature hasn't fixed it in the last 30-years how is a rockfish recovery area in the South Sound going to be the "heal all?"

We'll see you tomorrow night!

Made time to go to the Friday Harbor meeting. The 12:00 noon start gave me time to catch a ride on the Hyak, have an early lunch, and walk to the UW campus. Nice day for a brisk walk in the Pacific Northwest!

Small crowd, I counted 6 (including myself) plus 2 WDFW, Greg Bargmann and Wayne Palsson.

Same presentation as Mill Creek, it was video taped for the records.

I took these notes from the presentation and 'clarification' question and answer period (this was not taped - off the record);

* WDFW have no specific definition for 'sufficient size' and 'location' of MPAs proposed by the draft plan. (it is a blank check)
* Seals are predators of rockfish. The draft plan identifies 2 estimates for seal consumption of rockfish; 300,000 per year is an estimate from NOAA, 12% of diet is an estimate from the 'Jeffries' San Juan Island report.
* Stock estimates for Canary and Yelloweye are based on ocean surveys. WDFW data indicate these fish migrate into Puget Sound from the ocean and are not a unique population.
* NOAA endangered listing for Bocaccio assumes the Puget Sound population is unique. WDFW data indicate these fish migrate into Puget Sound from other areas and are not a unique population.
* The draft plan discusses Puget Sound Rockfishes and Puget Sound Rockfish. Puget Sound Rockfishes refers to all rockfish in Puget sound, Puget Sound Rockfish is the name of a specific rockfish. The Puget Sound Rockfish is included in the draft plan as a reference stock because it is not fished in the Puget Sound.
* Ocean stocks are very productive, black rockfish populations are OK and being managed well.
* Lingcod likely have negative impact to rockfish populations.
* Black rockfish used to be 10% to 20% of P.S. recreational fishery, where did they go ? Data indicates population declines were associated with 'climate change' a few years ago. There was a large influx of black rockfish into Puget Sound from Ocean in 2006, these fish are growing and reoccupying habitat in Puget Sound.
* WDFW do not have study of ocean acidification
* WDFW are coordinating with NOAA on Federal listing of rockfish as threatened and endangered species; participation in meetings and providing comments. The Federal listing will take into account conservation efforts made to protect Puget Sound rockfish.

There were only 2 people who provided public testimony. A summary of my statements;

* I read the 2009 Wild Fish Journal published by the Wildfish Conservancy that was distributed at the Mill Creek meeting. Reading the MPA article from the viewpoint of a recreational fisherman, their discussion about fishermen is divisive and offensive. What do they expect to accomplish by publishing inflammatory rhetoric? Check the records for contributions made to conservation by sportsmen in this country, it is significant.
* For me, MPAs mean elimination of opportunity to fish for salmon, ling, halibut, crab, and shrimp. While I agree with many of the proposals in the draft plan, I can not agree to 'blank check' approval of MPA. (MPAs are a solution looking for a problem)
* Very concerned about declining fish stocks in Puget Sound. Reviewing data from the WDFW and NOAA; compared to harbor seal consumption of rockfish, sportfishermen took 20% during years 1978 through 1993 and less than 1% during years 1994 through 2007. If we assume the sportcatch goes to zero next year, it will only be enough rockfish for a small percentage of the (estimated) additional 1,200 harbor seal population.
* Harbor seals do not belong in lake Washington. I understand Lake Washington salmon and steelhead stocks are some of the most depleted in the state. I have seen harbor seals feeding on salmon at the north end of lake Washington, I can only watch in horror.
* Why would NOAA, or anyone, accept the proposal when it does not identify conservation measures recommended by NOAA that will protect declining populations of rockfish, herring, salmon, steelhead, and Orcas ?

Hung out with Doc at Haleys for awhile and then I went to the whale museum. Paid the $6 to go upstairs, I could not get out of there quick enough - that place gave me the creeps.

Nice ride back to Anacortes, stopped by the Village for pizza and libation. Next stop, Olympia.

See ya there. I will be the guy wearing this shirt;

Many
Problems
Ahead

Just Say No

Thanks for the report, and thanks for going to the meeting. See you in Olympia.

Bear

Fantastic report

Bushbear, 20 years ago approximate there was a good population of either yelloweye or canary rock fish in Daobob bay on the Hood Canal. I could go out there at any time of the year and catch them.
Chuck G

Wednesday, Nov. 4 – From 7-9 p.m. in Olympia in room 172 of the Natural Resources Building, 1111 Washington St. S.E. is the next opportunity to voice one's opinion.

First Plus 1, thank you for the outstanding report.

I am trying to draw an analogy between the date the prohibiting of the killing of pinnipeds came into effect in Puget Sound and the decline of the rockfish population since that date. There seems to me to be a direct correlation. The limiting of pesky predacious pinnipeds appears to me one of the major steps in revving the rockfish populations.

Does anyone know: What is major reason given by the powers-that-be as to why they have not began limiting or getting permission to limit the pinnipeds populations?

If you anglers don’t start participating in these meeting anent rockfish and Marine Protection Areas( MPAs) you will soon find yourselves perched on piers, peering out over a vast MPA ,AKA: Puget Sound, in which you may not fish.

This is not a joke nor just a minor rockfish problem.

Please go to the meetings, e.g., the meeting in Olympia, this evening, 4 Nov 09.

Phoenix -
AS you know the issue is the Marine mammal protection act of 1972; see -

http://www.nmfs.noaa.gov/pr/pdfs/laws/mmpa.pdf

This prohibits the "take" of any marine mammals excpet for specific exceptions. As the experiences at Ballard and the Columbia getting the OK for that take is difficult and reguires some specific information on the problem. In reading the rockfish report it is clear that it has been relatively recently (I believe the diet study was produced in 2007) that the potential of significant impacts from seal predation is an issue (at least in the San Juans).

Hopefully the input from this DEIS process will help move the State forward in exploring this option. That said I would not count on much relieve on that front. Establishing a target of removing 1000s seals will be a huge emotional issue for most of the public and will be a very difficult sell. I sure that you remember the media attention that the "seal watchers" got late this summer/fall in protecting the pups that were hauling up on the beaches and boat launches in central sound.

BTW -
There is little question that the major driver in the decline of Puget Sound rockfish was the over fishing that occurred during the 1970s and 1980s. I'm not sure that is a lot of benefit from debating the role of other factors in that decline. I think it will be much more productivie in focusing on what currently is limiting the status of the various rockfish and what strategies are best suited to assure a reasonable expectation of successfully rebuilding those populations.

Tight lines
Curt

Thanks for your response Smalma, I am aware of your information Supra; however, I still want to believe, someday, reason should prevail over blind luck, stupidity and emotions.

The seals wouldn't hang around if the food source wasn't abundant.