Guys, I know you are already on top of this potential huge closure of Neah Bay waters to bottomfishing, but I wanted to appeal to you one more time because the deadline for comments is fast approaching (Jan 29):

http://wdfw.wa.gov/fishing/regulations/rule_proposals/comments/proposal.php?id=146

PLEASE go to the link above and fill out the comments form to try to stop this rule change, and encourage others to do the same. Even if you are not in WA, you should be concerned too. This is a dangerous precedent that is being set in WA that other states' F&W agencies may follow in the future. It is a continuation of an aggressive anti-sportfishing agenda that's been all too effective in Washington, and is not based on real science. We have to stop this.

WDFW will consider the opinions they get, but they will definitely NOT consider the opinions they don't get! Make sense? Please say something! At the very least, go to the link above and just put "I do not support WDFW Rule Change Proposal #69". If you want to add more, that's great...

I have pasted in comments you can use (if you want) for both the comment form on the WDFW site (1000 char max), and a long-form letter that explains in detail why this proposal should not pass. I will be doing both. And will be copying my congressman and local newspaper on the letter.

If anyone has any ideas for what else can be done to stop this from going through (other than submitting comments and attending the WDFW public meetings), post it up.

FOR WDFW COMMENT FORM:
----------------------------------
I do not support rule change proposal "#69. Reduce lingcod season in Marine Area 4B". The data behind this proposal does not justify the action.

A WDFW representative provided data that was from 2010/2011 dockside sampling. This data shows that for each legal Lingcod, 1.6 protected rockfish were caught.
WDFW itself estimates that rockfish caught in <120' of water have 17%-37% mortality. This translates to 712-1552 rockfish. Considering only Yelloweye and Canary, the resulting mortality would be 41-90, and 109-238, respectively. The 120' depth restriction already sufficiently protects rockfish. Please see http://www.thewhiteroom.com/wdfw_letter.html

Additionally, this rule change would have a huge impact on WA's fishing community and the economy that supports it. And it will create a safety hazard since smaller boats will inevitably try to fish 4A in weather conditions that they would normally fish the more protected 4B.

Thanks for your consideration and all of your hard work.
----------------------------------

FOR A LETTER:
----------------------------------
Dear WDFW Commissioners,

I am writing to express my deep concern regarding WDFW's "# 69. Reduce lingcod season in Marine Area 4B" rule change proposal. If this rule went into effect it would have a HUGE impact on Washington's fishing community and the economy that supports it. Additionally, I believe this rule change would create a serious safety issue. Most importantly, the data behind this proposal does not justify the action.

I understand that this rule change is being considered in order to reduce the by catch of "protected" rockfish species. We anglers are very interested in conservation, because we know if we are not, we are compromising the future of the sport we love. However, as avid fishermen of area 4B for Lingcod, the by-catch issue just does not correlate for me and my colleagues at the North West Kayak Anglers (NWKA). We know from experience that very few rockfish are caught while targeting Lingcod. And, it is rare to catch Canary or Yelloweye in 4B due to the 120 foot depth restriction. If you are catching rockfish, you either change bait or move. Nobody wants to sit there and catch rockfish after rockfish that are illegal to retain.

But we didn't want to rely on our own experience alone, so we inquired to WDFW to find out what data was used to back the proposal. A WDFW representative sent us data that was from 2010 and 2011 dockside sampling. This sampling occurred throughout the entire season and has standard statistical methods for determining complete harvest from MA4B. This data, which the WDFW considers valid, shows that for each legal Lingcod caught, 1.6 “protected” rockfish were caught.

Furthermore, according to this WDFW document: http://wdfw.wa.gov/publications/00035/wdfw00035.pdf "...For rockfish found in Puget Sound, mortality rates of released rockfish from 120 feet (36 m) or less in depth ranged from 17% to 37%." During the dockside sampling period, the total number of "protected" rockfish encountered in 4B was on average 4195 rockfish per year. Considering the mortality rates above, this translates to 712-1552 rockfish that perished. Consider that there were 18,905 black rockfish retained per year on average. Now, if you considered only Yelloweye and Canary, there were 242 Yelloweye and 642 Canary encountered per year on average. The resulting mortality would be 41-90 Yelloweye and 109-238 Canary.

The 120 foot depth restriction already sufficiently protects rockfish, which is why the WDFW itself is estimating a survival rate of roughly 75%. And the average depth Lingcod are targeted (by NWKA estimation) is 70-80 feet, which gives rockfish an even better chance.

While by-catch is never great, it is a reality in both commercial and sportfishing and there is an acceptable threshold…these numbers just do not merit a 75% reduction in the Lingcod sportfishing season for 4B, from 180 to 45 days. That is the most important reason why this rule change proposal should not be passed. And if that weren't enough, here's a couple more…

The first is safety. Because of its unique geographical situation, 4B allows anglers access to rich, world-class, ocean fishing with good protection from westerly wind and swell. Naturally, 4B is fished by anglers with smaller boats that can't normally fish the ocean side (4A), and by almost ALL boats on choppy or bigger swell days. Severely restricting 4B to bottomfishing will likely result in more boats taking risks they shouldn't, by trying to fish 4A.

A scenario: A few guys with a smaller boat, an 18', plan a July weekend out at Neah Bay targeting bottomfish. Saturday's weather is great, they get out to 4A and the fishing is good. Sunday the weather is marginal...the kind of day they would in the past stay in 4B, but with the rule change they can't. Rather than cut their big fishing weekend short, they take the risk and run out to 4A...and put themselves in danger and those that have to come to their aid, be it private boats or the Coast Guard.

And for every scenario like that, there will likely be many trips that get cancelled because 4B would no longer be an option. Because of fast-changing coastal weather, planning a fishing trip where only 4A is fishable is too risky, given 4B would be illegal to bottomfish. Not to mention the many, many trips never even planned by those who ONLY fish 4B. That would add up to a lot of fishing trips that never get made.

Which leads to another important factor…economic impact. Neah Bay is a community that depends on sport fishing, of which 4B's Lingcod season is a large part. Guides, foodservice, lodging would all take a severe hit. And it's not just Neah Bay, but all the towns in the Olympic Peninsula anglers pass through on their way to Neah Bay, where they stay, eat and fill up their tanks. Then the tackle shops across Washington that won't sell the bottomfishing gear, the manufacturers who make that gear…even lost WDFW license revenue from those who come from out of state just to fish Neah Bay (it is, most definitely, a world-class fishing destination). And that's just naming a few.

The American Sportfishing Association reported that Washington State's saltwater fishing economy is worth nearly $600 million http://asafishing.org/uploads/2011_ASASportfishing_in_America_Report_January_2013.pdf. It's hard to say how much of that MA4 is responsible for, but given that area 4B's unique geographic protection from the ocean, access to world-class fish, and the fact that it's considered fishing heaven by so many anglers...I'm quite certain it's responsible for a good chunk. The economic ripple effect of this rule change would be devastating. Please consider the livelihoods that would be impacted by this single rule change.

Fishing is something I am very passionate about, and 4B is one of my favorite places to fish on this earth. It's a place myself and my fishing friends visit often throughout the 180-day season (most of those trips take place AFTER June 15, when the weather is more predictable). Marine area 4B's fishing, and it's beauty, is unparalleled. Please do not make this proposal a rule change.

Thanks for your consideration and all of your hard work,

R. O'Connor
------------------------------

Thanks for bring this back up. I fish that area often with my family. Comments left on wdfw site.

Does anyone know if the tribe is formally opposing this as well?

Thanks for the form letter for submitting comments to WDFW. I changed it a bit and used words like "I" as I am one who plans to be out there this summer. Only my boat is even smaller, a 15' Arima.

"Thank you for submitting your comments"

The issue of safety provided by an "inside" area to fish was a significant talking point when this area was peviously proposed for complete bottomfish closure.

Recently the Commission, and particularly the Chairperson, made particular note of safety being a consideration in adopting the new P.S. shrimp policy.

Anyway, thanks for the reminder!

The Makah's are aware of it. I made sure of that.

Thanks guys!