Back when I was involved in Fraser sockeye management they actually planned the fisheries so that an opening would result in fish to catch AND escapement was planned to pass through in a block. Required a lot of effort but was pretty successful.

For some reason, the managers believed that an opening with no fish to catch was a bad idea. Of course, they were mostly managing commercial fisheries but they still believed that theyre should actually be fish out there to catch. And spawners for the gravel.

As we truck on down the road I thought I would let everyone get a look at my comments to the Commission. Now these are my thoughts but agree or disagree I urge everyone to comment directly to the Commissioners on the continuing process of remaking the Grays Harbor Management Plan. A e-mail or letter but all the citizens in the Chehalis Basin communities need to participate. commission@dfw.wa.gov is the Commission address and staff will direct your correspondence to each Commissioner.



Dear Commissioners,

I am writing to express my concerns regarding the current effort by WDF&W staff to review and modify the Grays Harbor Management Plan. As a member of the GH Advisers I applaud Mr. Scott's efforts but this is not the case to many citizens that have communicated to myself and others as they fail to see any fundamental changes from the failed past practices of Region 6 District 17 staff. In fact the term " dog & pony show " is once again being utilized to describe the process by many citizens. Little faith exist that the input from the public is not being " sanitized " to in effect not allow the public's comments to fully and accurately provided to the Commissioners. This being the case I have attempted to define some basic issues and provide alternative solutions.

1. Failure To Make Escapement: The Grays Harbor / Chehalis Basin has failed to make escapement on Chinook and Chum stocks for one reason and one reason only, commercial over- harvest. The desire by all elements of the public as a whole for the greatest possible harvest opportunity creates a climate of that nearly dictates the failure will happen again and again. In fact I ask the Commissioners to ask of yourselves and others this question. " What other river in the state does the WDF&W Commission authorize commercial fisheries six to seven days a week with stocks not making escapement? " I urge the Commissioners to consider the following as a policy guideline that is a rock solid baseline policy not to be violated.

4 & 3
" In any given calendar week commercial fisheries not exceed four days and those days must be consecutive."

Boiled down to the simplest terms one citizen put forth this simple definition. " Four days a week for harvest and three days the gravel / fish " In addition all recognize that the Quinault Nations Commercial fisheries do exceed four days at times this guideline is intended to address the cumulative days of both the non treaty and tribal commercial fisheries but not in any way abridge the QIN treaty rights. Also as the Humptulips and Chehalis Rivers are managed separately by the state but not so by the tribal co managers it is recognized further " side boards " would need to be defined.

2. The Harvest Model: The model utilized for the management of Grays Harbor fisheries has been the subject of intense scrutiny. After considerable input ( or harassment depending on your view ) from citizen John Campbell over forty eight math errors and false data points have been corrected but not the failure of the model to correctly predict the commercial and recreational impacts. This has been brought to R-6 District 17 staff repeatedly yet little has been done to correct this issue. I must admit though Dr. Estalilla was told be careful what he wished for in a 2013 Advisers meeting he strenuously objected to this practice. Simply put Commissioners staff must be required to utilize the model in a manner that insures accuracy and NOT in a manner that insures it is absolutely not accurate as R-6 District 17 presently does.

3. Selective Fishing: In Grays Harbor the Commercials and Recreational fisheries utilize catch & release ( C&R ) and in both the true and actual impacts are not correctly represented in the model. In the case of the non treaty commercial fisheries it is particularly egregious as the impacts have been intentionally misrepresented. In the Grays Harbor Non Treaty Commercial Fishery training is required, the British Columbia training films are utilized, recovery boxes required, protocols reviewed, mortality applied, ( developed in the Columbia River ) and other elements outlined. I am sad to say it is a complete farce as it is a Selective Fishery in name only. District 17 violates virtually every protocol from avoidance to revival box use. Two videos documenting this abuse can be viewed on the Fishing The Chehalis website and for Grays Harbor practices I urge you to review the Chehalis Fling and in relating to the design protocols and lack of the correct development Selective Fishing I urge the Commission to require the processes and protocols to be utilized in selective fisheries be clearly defined and not open to manipulation and abuse as R-6 District 17 staff currently practices.

4. Inland Communities: At every meeting for the current GH Management WDF&W has time and time again represented the current difficulties as a Recreational fisher vs a NT Commercial fisher. This 100% correct and yet is 100% incorrect. At the heart of the current difficulties is not just rec v commercial but rather the inland communities citizens growing and adamant opposition to the failure to make escapement and the practice of WDF&W awarding the vast majority of harvest taking place in the marine area communities of Aberdeen and Hoquiam. It should also be understood by the Commissioners that the inland citizens do not separate the commercial fisheries by race and ethnicity but view the both QIN and NT nets as commercial, period. The inland communities citizens have borne the vast majority of the cost environmental reform / timber harvest reform and neither they or the fish receive any benefit. R-6 District 17 continues the practice of institutionalized discrimination towards the citizens of the inland Chehalis Basin by directing the vast majority of harvest opportunity to the bay and terminal fisheries centered around the communities of Aberdeen and Hoquiam.

Commissioners I urge you to end this practice immediately! In the coming months and years additional sacrifice will be required to address the court mandated culvert replacement and other issues relating natural origin salmon populations. For what? To have any benefits to be harvested at Aberdeen & Hoquiam and not enhance the spawning salmonid populations? To continue to deny the vast majority of Chehalis Basin citizens that shoulder the financial burden any of the benefits? The management of the Grays Harbor / Chehalis Basin has been referred to as the " poster child for not supporting any additional citizen cost in taxes or regulation. " It is difficult to challenge that view as neither the fish or citizens of the inland communities will see any benefit under Region 6 District 17 policies.

The issues I have outlined are complex yet the solutions need not be. If the Commission does not take dramatic steps to resolve the issues I have outlined the future will not hold much promise for the Grays Harbor / Chehalis Bain watershed but rather a ever growing controversy returning to the Commission year after year.

Sincerely,

DH

My initial public comments were along the line of:

*** Require agreement between the QIN and WDFW as to harvest parameters, model inputs, and 50% sharing.

*** Protect under escaped runs.

*** Region 6 to advocate for Grays Harbor bay returns through our PFMC representative (especially for Chinook).


While these are all favorable for improved recovery of critical runs they do not address the elephant in the room which is the continual effort by all groups to over harvest.
My input at the next meeting focused on how fish are shared between user groups. The advisors and even the public view of sharing is somewhat of a gentlemanly compromise between stakeholders. WDFW is trying to use the rec input and the gill net input to give the commission a bracket to base policy on.

I personally have more of an economic view of how sharing should be considered. My public input on this subject included the following points:

*** There are three existing commercial fisheries in Grays Harbor
*** 58% of the fish are mandated for tribal commercial fisheries
*** Recreational fishing is constrained by commercial harvest.
*** The TCW-2008 study clearly demonstrates that the economic contribution of recreational fishing per fish caught vastly out weighs the economic contribution from commercial fishing.
*** The ex-vessel value of the non tribal commercial catch probably does not justify the cost or time put into the business. Is this a hobby?
*** WDFW (internal document) spends $382,000/year to manage a commercial fishery with a 13 year average average ex.vessel value of $92,652/year (range $10,636 to $217,550).

When I worked in private industry the state expected a business to pay the cost for the state to manage our environmental performance. If commercial fishery management costs were paid for by the Non Treaty gill netters the business would be clearly uneconomic and would quickly go away.

My recommendation was that a rigorous economic study of the NT gill net business should be conducted. The apparent conclusion is that this business should not exist. This would lead to the recommendation that the Commission consider the option of ELIMINATING the NT gill net industry.

If Region 6 even remembers my input they are probably still getting a good chuckle out of it.

While many would LOVE for this to be the final outcome, the Commission would be in breach of it's own NOF Policy C-3608…

http://wdfw.wa.gov/commission/policies/c3608.html

Unfortunately, there's this pesky little clause in there about managing the NT share….

"Grays Harbor harvest management objectives shall include opportunities for both the recreational AND commercial fisheries."

Given the greater economic return of every fish allocated rec, the citizens would be better served by allocating the GH salmon resource accordingly. Whatever opportunity they are granted, the rec community should make an all out push to convince the commission to transition the NT comm fleet to live capture gear.

eyefish -
Commission policy 3608 is hardly etched in stone. It usually comes up annually for review and public comment. Last year the commission meeting where that happened was in early January and I believe there was a period before that time for written comments and suggestions from the public.

In the last few years there has been modifications to the wording in the Puget Sound section on pinks and chums. While not earth shaking those changes came from the sport fishing community and illustrates that change is possible.

I agree that major changes are likely to be a long term process but it seems to be a potential approach would be to attempt to define or prioritize those opportunities. That was what was done in Puget Sound years ago where the recreational fishery is given first priority for Chinook and coho in PS.

Clearly the Grays Harbor seasons are on the Commission's radar and thus the next couple months is a major window of opportunity that may not come around again for sometime.

Curt

Your correct it was Jan or Feb when 3608 came up. The thing is it was changed AND NOBODY KNEW THEY WERE DOING IT. Now that does not mean R6 D17 tried to hide it but rather it was business as usual and you can bet the commercial interest tracked it! Not so the rest of us so I guess you can say it is the inland Recs fault also. Doubt that will happen again.

eyeFISH, I am aware of the policy and I think it is only a small stretch to consider that the treaty and non treaty tribal commercial fisheries are adequate to meet this policy, at least if they have been given the opportunity to harvest fish.

The final Grays Harbor model anticipated a total harvest of 115,700 fish of all species. The WDFW as our bargining agent negotiated a plan where the QIN commercial share was 61.6% of the total harvest and the Chehalis commercial share was 5.5% of the total harvest. In my view that should constitute a substantial opportunity for commercial fisheries.

Can you or anyone in the brain trust explain why the commission cannot consider tribal commercial fisheries as satisfying this policy and thus adequate to meet the policy requirement?

I understand the rationale behind your argument and support it completely. As has been posted, before a single WDFW fishery deploys any gear (hooks or nets), the paper allocation of chinook crossing the bar at Westport is already 58% commercial.

I've had high level conversations that lead me to believe that elimination of the NT nets in GH is just not reality.

If that is to be the case, our future focus should be on ridding the basin of dinosaur gill nets.

There seems to be a bit of slight of hand here. The two tribal commercial fisheries are credited with an allocation of 58% of the Chinook harvest. In the negotiated final model the QIN were expected to harvest 65.4% of the Chinook and the Chehalis tribe 2.7% for a total of 68.1%. It still seems to me that the tribal commercial fishery should be considered as part of the overall commercial industry. How much is enough for commercial harvest?

If elimination of the NT commercial industry is totally unrealistic then I agree that the next best option is live capture selective gear for the NT commercial allocation.

Then a gillnet ban by statewide initiative may be the best path to making GH NT commercial free. For the cost of an initiative drive, may as well include lower Columbia River NT commercial as well.

Sg

Been tried already but that effort was pretty underfunded and not too well organized as I recall. Times have changed, maybe it's worth another shot.

Long time ago........might seem short but way before I retired in 1997....people need to know that tribes can catch all the fish needed for local/Washington State people and others.

I still can not believe the hours spent by WDFW, sports individuals, and the NT gillnetters, to keep a net fishery going that costs the State more than the gillnetters make. How stupid is that???????

...a question that I'm not sure about the answer to....

Does the Chehalis tribal share of fish come out of the NT commercial or the sport allotment or out of the combined NT numbers ?

yes

It's welfare, plain and simple. They don't want to do something else for those few weeks because the state gives them a freebie and we all pay for it. The main commercial fishery, the tribe, provides PLENTY of fish to the market.

Thanks

" Does the Chehalis tribal share of fish come out of the NT commercial or the sport allotment or out of the combined NT numbers ? "

It comes right off the top of the non tribal share then the department divides the remaining non treaty share NT nets and sport.

Couple of items. This link is to the FTC library and two documents regarding the Grays Harbor Management plan redo. One is mine which I have made public and the other is a complete break down of the policy guidelines and recommended changes by the East County guys which is titled Commission Policy Edits. I urge you to read through it completely as the policy guidelines approved by the Commission will determine the fisheries in Grays Harbor & the Chehalis Basin in coming years.

https://drive.google.com/folderview?id=0...aDJvWjFiaUVoNGc

Second item is a reminder of the next Public Input meeting for the Grays Harbor Management Plan Tuesday the 26th, 6:00 PM at Montesano City Hall. I urge all to attend and speak your mind on the status of the Grays Harbor & the Chehalis Basin Salmon Management, or lack of depending on your views!

Refreshing news…

First off, let me say I was fully prepared to bag out on the GH public meeting tonight, fearing it would just devolve into another 2-3 hour food fight over who gets to kill what and how many. Just didn't want to spend another worthless evening arguing over who gets to kill the last fish.

So pleased to report that when RW turned to the topic of narrowing the grand canyon between the desired rec vs comm allocations, those in attendance entirely abandoned any discussion along those lines. Folks basically decided they were NOT gonna waste any more time talking about it... pointless as neither side is prepared to budge.

So what did happen?

One of the rec advisors gave an impassioned speech about past management failures, ridiculous arguments over who catches the last fish, and the urgency to abandon the past for a paradigm shift in managing these runs for the future.

The conversation shifted to conservation and escapement… specifically the chronic under escapement of wild fish in the basin.

We talked about escapement goals… habitat-based (river miles available for seeding) vs biologically-based (spawner-recruit ratios) ways of determining them… the merits of using escapement ranges to reflect the diversity of escapements that can produce optimal yields rather than clinging to archaic point-escapement goal management that all too often results in gross overharvest and failure to meet conservation objectives.

We talked about ensuring escapement windows with a minimum of 3 consecutive days per week of escapement past the estuary to deliver fish inland… and capping commercial fishing effort to no more than 4 consecutive days per week. And dedicating that available commercial time to ALL commercial fishermen regardless of skin color… finally taking the literal interpretation of "fishing in common with" to mean the state and tribe shall conduct concurrent fishing periods, KUM BA YA.

We talked about maximizing economic value from a limited precious natural resource.

These are the talking points that will resonate with the commission, folks. Fighting over 90:10, 80:20, 60:40 just makes each camp sound like a bunch of greedy bass turds. The conversation MUST be about the health of the resource and finding better ways to limit exploitation to consistently deliver enough fish inland to meet biological spawning escapement goals.

The conversation has finally shifted folks. Help us carry that message to Olympia. The commissioners need to be educated that these are the primary considerations upon which the allocation decision will ultimately fall. That allocative responsibility is not ours, nor is it the gill netters… that's something the commission has to own.

WYNOOCHEE MITIGATION MONIES

finally after 20+ years of a fund just sitting in a bank account it will be going before the Commission. Maybe Coho and steelhead will finally be placed in this fine, beautiful river, that the mitigation fund was going to do........20+ years ago. Yea, yea, yea......