Seems to me that over the past 15 to 20 years;
recreational and commercial fishing pressure on rockfish has been reduced significantly
herring, salmon, rockfish, and Orcas populations have declined
seal, sea-lion, dogfish populations have increased substantially

Not sure how or if it is all related - but it seems unreasonable to expect any significant changes by closing recreational fishing, even if it was completely eliminated.

So much literature; so little time!

1. Found in the Puget Sound Groundfish Management Plan (Revised) December 1998 (Palsson, Northup and Barker):

Marine Mammal Interactions (pg 23); "Marine mammals are key predators on groundfish populations in Puget Sound (Schmitt et al. 1995) and may also compete with groundfish populations and fisheries for limited food and other resources. Because of their special status of protection, marine mammals present a difficult management problem and are likely limiting the population of Pacific shiting in Port Susan and may be affecting lingcod, walleye pollock, and Pacific cod resources throughout Puget Sound."

(Note that Palsson is Wayne Palsson, Research Scientist, Marine Fish Science Unit, Fish Program of WDFW and is a major contributor of scientific research papers and is also one of the seven members of the Core Team which put together the Puget Sound Rockfish Conservation Plan and also is one of two WDFW employees currently presenting this plan to the public. Barker is Dr. Morris Barker who is retired from WDFW but was also one of the seven Core Members).

2. Trends and Status of Harbor Seals in Washington State:1978-99 (Huber and Laake):

This report provided history that "In the first half of the 20th century the number of harbor seals in WA State was severely reduced by a state-financed population control program, which considered harbor seals to be predators in direct competition with commercial and sport fishermen. Seals began to recover after the bounty program ended in 1960 and the Marine Mammal Protection Act was passed in 1972." It further reported that "Since 1978, harbor seal counts have increased threefold, and estimated abundance has increased seven- to tenfold since 1970."

Figure 5 Generalized Logistic Growth Curve for Harbor Seals In WA Expressed as Population Size (1970-2000):

This report combines both coastal and inland populations. The report and graph shows the 1970 combined population at between 2-3,000 and grew fairly steadily until about 1990 at which time the rate of growth began to decrease (total growth continued) and appeared to stop growing about 1999 at about 30,000. Again, this is coastal and inland. The report in more than one place indcated that the population was near or at carrying capacity (note that their final survey in 1999 had the inland population at 8949 animals).

The report concluded with Management Implications where the authors wrote, in part, "if formally determined to be at OSP (optimum sustainable population), NMFS could return management authority for harbor seals to Washington State, if requested." It went on to opine that "It is evident that harbor seal stocks in Washington could decline by 20% and still be above MNPL (maximum net productivity level). In explanation of terms, "NMFS adoped the definition for OSP as a population level between carrying capacity (K) and the population size which provided the maximum net productivity level (MNPL)."

Bottom line was that at the time of this study and report seal populations were perceived as being at carrying capacity (inland at 8949) and suggested that NMFS would "allow" a reduction of 20% or roughly 1,800 animals. The inland population in 2007 was estimated at 14,000 (documented in the PSRCP) and further estimated to have grown to approximately 15,000 at this date. So much for being at carrying capacity in 1999. I will leave it to you all to look at the precipitous drop in rockfish catch rates starting in 1990 and draw your own conclusions. Also, as to who knew (or should have known) what and when relative to increasing seal populations and falling rockfish populations.

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One might speculate that rockfish populations may have been artificially high going into the 70s due to the the seal bounty program. As fishing pressure increased into the 80s and through 1990 the seal population rebounded and added to the stress on rockfish (at issue here). When human fishing pressure was reduced the seal population continued to grow to where it is now.

I opined elsewhere that it would be nice to see a graph showing human take and seal consumption over this same time period.

Despite all of the research available and the involvement of Dr. Barker and Mr. Palsson there is no absolute number for current seal predation upon rockfish in the PSRCP. I crunched the pertinent figures provided in the PSRCP for the San Juans and came up with 1,716,960 pounds for 7,000 seals. Absent any other information I doubled that number for all of the Puget Sound covered under the PSRCP yielding 3,433,920 pounds. If the average rockfish is 2# that makes the total number of rockfish consumed per year 1,716,960. That number does not include Steller and California seal lions. I acknowledge there are some assumptions in this calculation but it does provide some magnitude for comparison purposes.

Under the PSRCP para 1.9 Alternatives Considered, but not Analyzed defines (under SEPA) a reasonable alternative as being "an action that could feasibly attain or approximate a proposal's objectives, but at a lower environmental cost or decreased level of environmental degradation. Reasonable alternatives may be those over which an agency with jurisdiction has authority to control impacts, either directly or indirectly"(WAC 197-11-786). It went on to list six samples of alternatives that were considered but not analyzed because "they did not fully address the stated purpose and need of the PSRCP and were not considered to be "reasonable"." One of those six was Intentionally decreasing abundance of rockfish predators to increase populations of rockfish.

Given the current low levels of some rockfish stocks and their low natural fecundity rate can the PSRCP ever achieve its goal without reducing the impact of predators (and particularly seals)? Even if it is possible (50-60-70 years or more) is that reasonable given the impacts of the PSRCP on the human community?

Or would reduction of seals hasten rockfish recovery and undermine efforts to implement an extensive (intimated but not defined in the PSRCP) system of MPAs? (Dang black helicopter flew over again)

Off to Olympia tonight to ask some questions.

Does the plan have any provision for more enforcement dollars?

Not that I noticed.

Hmmm I'll have to think that one over

No, and it's a fair question to ask. Given the 110 new proposed rules, proposed MPA's, RRA's and depth and gear restrictions, it's going to be a significant challenge for some folks who are already over extended and in a Department that will likely be faced with additional budget cuts in the very near future.

Too late to edit my typo. I will confirm that the original document cited "whiting". Only funny (maybe) part of this whole mess. And it was unintentional - really!

I tried to eat one once, might be a better name for them.

Lots of seasoning, wrap in foil, and bake for 2 hours at 350 degrees. Vacate the house. Actually, maybe should be concerned about marine mammals shiting whiting. Or are they trained to use the marina facilities? Some 15,000 little poopers in Puget Sound!

The following link to the WDFW website might provide avenues to use when discussing the DEIS with the state. There will be economic impacts and as other threads have suggested, gaps in data being used for the DEIS. There are obligations that state agencies must follow when preparing SEPA documents and for impacts on the local economy/small businesses

http://wdfw.wa.gov/about/regulations/

One thing struck me at tonights meeting. This looks more like a dog and pony show.

Sportfishing is once again, thrown under the bus to provide a "viable" commercial harvest.
Wonder how the impacts of the ESA, Puget Sound Chinook and Rockfish, Management Plans are to be allocated?
Restrict anglers and allow the most harmful, least sustainable methods of commercial take?

Back from the big evening in Olympia. Lots of feedback to Staff regarding the plan. I think the safest thing to say is that everyone wants to see rockfish recover.

Virtually all attendees who provided comments for the record asked for an extension and Staff indicated it was being considered. My caveat here and now is to provide your comments on the current plan as presented because the final date of 19 Nov is the final until and unless changed.

Many comments about the need to flesh out the plan so that stakeholders fully understand magnitude of some of the ideas in the plan as they may impact other fisheries (areas, time, depth, gear, etc.) Lots of resistance to MPAs as being permanent and restricted; more support for Rockfish Recovery Areas that meet recovery requirements and have periodic reviews and subject to a "sunset" time table.

As for seal total food consumption figures they will check out their 5 million pounds versus the 28,616,000 pounds one can calculate from their own component data. The issue of how much of that is rockfish is not clear and hopefully they will provide better information. Also, if they still cannot analyze and incorporate predator (seal) reduction into the action plan they should at least identify the actual numbers (and species) of rockfish lost to seals and explain why no action is being built into the plan. Call that a need for full disclosure. They did say that most of those taken by seals are probably Puget Sound rockfish (the species) but even if the % of rockfish of concern is low the sheer amount of fish involved means the impact on those of concern could still be quite high compared to the other stressors.

There was a point made in the slide presentation that the plan has to be realistic with a recognition that there are funding limitations.

Finally, there was a comment regarding lack of economic impact in the DEIS.

Regarding the rockfish species composition in the diet of the San Juan Island seals -

I checked the Lance and Jefferies 2007 article and the authors reported that they were not able to determine the species of rockfish being comsumed due to "acid" erosion of the otoliths. Remember scats were being used to determine the diet. They did note that there were juvenile, subadult and adult age fish in the diet. Inferred from that it is likely that at least part of that rockfish diet is something other the Puget Sound rockfish.

Tight lines
Curt

Time for some idiot to state the obvious and I'm just the guy for the job!
This plan is a real "onion"... the more you peel, the more it stinks..
Curt, what geographic definition for Puget Sound are you using to determine the origin of the rockfish in the San Juan Island seals?

According to the proposal, "Puget Sound" might just extend to the SJ's, Neah Bay and beyond.

I wonder if this plan would change if diving in MPA's was prohibited?
Seems to me if we cannot fish in MPA's why will diving and possibly spearfishing be permitted?

Hans,

What commercial fisheries are you refering to? My understanding is that there is virtually no rockfish bycatch in non-treaty commercial fisheries in areas 6 through 13, and the only fishery with any impact at all is a trawl fishery in the west end of area 5. Commercial fishing was definitely a problem, perhaps "the" problem. I don't believe it is anymore, especially for populations inside of Sekiu.

Cheers

....maybe the bycatch is low because the populations are so reduced as to be inconsequential in the non-treaty commercial net fisheries. The size of the fish encountered might also play in if the mesh size is such that a large portion of the rockfish encountered can pass through the mesh...

You folks need to do some research on Jane Lubchenco who is the new head of NMFS. She's one hundred percent Pew Foundation and two hundred percent pro MPA's. I listened to one of her presentaions in Newport a few years ago, and she was having a tough sell there too. No need to worry now she has the full support of Washington DC to implement the plan. She has a FaceBook site with good info...

During the meeting it was acknowledged by Staff that the ongoing commercial netting of rockfish in the north sound is documented by fish tickets which identify "rockfish" and a quantity but that there is no count by species. I would think that WDFW could have one of their fish checkers at the dock looking at commercial offloads.

Also, in the draft plan at para 2.5.1 it is acknowledged that catch estimates for commercial fisheries do not include estimates for rockfish encountered during commercial fishing operations and released at sea. "No monitoring program exists with which to estimate the magnitude of this release rate. The amount of this release is thought to be low, but the mortality rate high (Palsson et al 2009)"


No on the water monitoring and no at the delivery point inspections. Just a round number of "rockfish" sold to the buyer.

All that may be true, but this particular proposal is being put forth by WDFW, not NMFS.

Didn't Phil Anderson say that to get NMFS to ok the salmon plan that this was part of the deal? Washington state gets what they want. She gets what she wants, only the beginning I'm afraid.