Last Thursday the Commission adopted an interim policy to get the agency thru the 2015 season-setting for Willapa Bay commercial and rec fisheries. This was done as a ONE-SEASON stop gap to give specific guidance to WDFW for the 2015 NOF process because the Commission is still deliberating on a more permanent Willapa Policy that is not proposed for adoption until at least June (after NOF is over).

The new policy is rooted in the conservation of WILD fish. Particularly contentious is the emphasis on reducing exploitation on WILD chinook.

In the interim policy, the Commission voted in favor of a conservation/HSRG-based impact cap of 14% for WILD chinook in the Naselle and Willapa Rivers rather than the 20% recommended in the staff proposal. This has been cause for much celebration in the conservation community. It was met with much less enthusiasm by the commercial gillnet community.

Before the ink has even dried, the push for reversing the Commission's decision has begun in earnest. Naysayers allege that the 14% impact cap had not been properly vetted thru the public process. Not only is this allegation embarrassingly WEAK, but it is also categorically false.

The 14% cap has been fully vetted (along with a full spectrum of potential impact caps) by advisors on the WB Ad Hoc Committee, at several public meetings since December, thru written testimony submitted to the Commission, and was even promoted in live public testimony at the Thursday hearing when the decision was made.

Models have been repeatedly run at all levels of impact up to 20% and beyond. In a nutshell NONE of the impact calculations exceeding 15% could deliver on the desired chinook conservation objectives.

The Commission needs to hear from you!

Please send the Commission an e-mail supporting their decision and urging them to HOLD FIRM on the principles of conservation. DO NOT CAVE to political/agency pressure to reverse the 14% impact cap.

The NOF/PFMC season-setting process culminates this week (April 11-16) in California. Do it now!

PLEASE....

http://wdfw.wa.gov/commission/contact.html

or send your comments directly to:
commission@dfw.wa.gov

Doc hit it on the head here guys and is 100% accurate. The 14% was the baseline harvest rate for recovery in the AHA model runs, was submitted by myself and others for consideration, was the chosen recommendation submitted by the Advocacy on behalf of the majority of the AD HOC Advisers along with citizens participating. Agency staff refused to present it to the Commission as a option. What we have here is blatant pressure by the Commercial fleet and WDF&W staff who support them to derail reform in Willapa. I urge you to e mail or write the Commission urging them to stand firm and reject this attempt to derail reform in the Willapa fisheries with misrepresentation and falsehood.

E mail Sent

email sent

DITTO.... and please, feel free to copy/paste any portion of my post in your comments to the Commission.

Sitting on the sidelines gets you more of the same ol' same ol'

C'mon folks, roll call has begun. Who's next?

I would CC Director Unsworth also.

director@dfw.wa.gov

sent....and will email others, to make sure they can help.

WDFW's actions in this Goat Roping Rodeo are a concern. Staff actually "hides" the only workable (from a conservation perspective) harvest scheme and this is supposed to engender trust and openess? My view is we need to know what at least appears to work before we decide what course to take.

Another thought that should be bothersome. Many folks believe that the problems we have in salmon management are caused by having the Treaty Tribes and Federals involved. Meeting their needs (treaties, ESA, etc.) is what gums up the process. Except that WDFW runs the whole show in Willapa. What they are telling us is that if we can get rid of the tribes and get rid of the Feds we'll give you WB all over the state.

email sent to both, hope it helps

229 views and how many in the roll call?

Serially?

Any member here who wets a line in Willapa Bay or its tributaries needs to step up.... remember that your 2015 season is riding on it!

To the question of what just happened? Best I can tell is that staff in San Francisco at PFMC wayyyyyyyyyyyyy out of the public eye started going after two of the Commissioners on the Willapa decision. It appears at this moment they utilized misrepresentation and utter fabrication to try and get the Commission to reverse its self on Willapa one day after the Commission adopted reform. It is going take a bit to get to the bottom of this but we will, one way or another we will. E mail the Commission your thoughts as it is important to participate.

Can you believe it? Senior agency staff ( & the former Director kill'em all Phil ) go 3/4 of the way to Mexico to San Francisco and out of t he public eye attempt to derail reform in Willapa? This is so far past acceptable that I think some folks need new jobs. Truly, I think Director Unsworth needs to clean house of garbage.............. now.

Anyhow here are the Advocacy's thoughts on the Willapa dust up. It is a good read and spot on.




April 12, 2014

To: The Honorable Members of the Fish & Wildlife Commission

Re: The recently adopted interim Willapa Policy


First, I thank the Commission for the time invested in developing a new policy for the Willapa.

Secondly, I wish to address a question that arose during the Commission hearing and apparently afterwards in the short time that has followed. Specifically, whether or not the 14% harvest rate adopted by the Commission was discussed publicly before the action taken by the Commission. Let me assure all that it was discussed repeatedly in the Ad Hoc and public workshops wherein all the AHA modeling showed a maximum harvest rate of 14% would be required to restore natural spawning Chinook within 16-21 years. When the Department came out with another draft long term policy as the ad hoc process schedule was winding down it contained the 20%. This high harvest rate was immediately and repeatedly challenged as exceeding the 14% that was being discussed throughout the process.

On March 18, 2015, approximately 20 citizens who are ad hoc members and public at large participants in the public process for Willapa met in the Elma Library. Steve Theisfeld delivered a copy of the Department's proposed interim policy, offered an explanation of the draft and took questions. Subsequently we spent until 10 pm that evening discussing the Department's proposals. Topping the list of concerns was the insertion of 20% into the drafts, including the interim policy seen for the first time that evening.

The attached meeting minutes were submitted to the Department staff on March 23, 2015 with copy to the Commission, Director, and all the citizens listed as participants that were in attendance. Further, the minutes were posted on websites and blogs and sent out to over 300 individuals who are signed up to the contact list of the website Fishingthechehalis.net

The meeting minutes say it this way:

Recapping and highlighting some of the commentary:

• All of the AHA modeling conducted during the ad hoc process showed the different alternatives would require a reduction in the maximum harvest rate to 14% to reach long range recovery goals in 16-21 yrs. The draft under all 3 Chinook Alternatives calls for a 20% harvest rate in the first phase (yrs. 1-4) which could delay the beginning of the recovery process up to 5 or more years. Further, the higher than modeled harvest rate proposed by the Dept. could continue the decline in NOR return run size to the point natural spawning recovery is delayed for decades and even limit future hatchery production (lack of NORs available for blending into hatchery broodstocks). While a 20% short term harvest rate would allow a greater Chinook harvest of returns from the higher past releases from hatcheries, the corresponding effect on NORs could create extremely difficult obstacles for the long term. The likelihood conservation goals could be reached would improve if harvest in the short term was reduced (10% suggested) and then raised it in the future to the 14% modeled using AHA.

Long term policy recommendations:

• Regardless of the Chinook Alternative adopted, reduce the proposed 20% harvest rate in Phase 1 (Years 1-4) from 20% to the 14% used in AHA modeling to reach goals in 16-21 years.

Interim policy recommendations:

• A harvest rate of 20% is set for both the Willapa and Naselle. Having a harvest rate on both rivers is considered by many to be a key component for success in the future. The recommendation is to reduce the harvest rate in 2015 to the 14% modeled by AHA and begin the recovery process without further delay and reduce the risk the Department will install a 2015 season that results in a further decline in NOR populations.

The cover email transmitting the minutes and recommendations to the Department staff, Director, and Commission on March 23rd contained a clear and precise request that the Department staff and the Commission consider adoption of the recommendations shown on the attached minutes with the following:

The group respectfully asks the Department to support, and the Commission to adopt, each of the recommendations outlined in the attached minutes.

To be frank, especially once one reviews the record of the ad hoc and public workshop process used for Willapa, the notion being raised that the Commission can only adopt language that has been some how posted by Department staff on its website or something of that order is novel at best. Worse, such a concept would tie the hands of Commissioners and effectively transfer the decision making power from the Commission down to the Department staff. I would argue the Commission was created by a vote of the people specifically to insure policy decisions were not left in the hands of Department staff, but rather rest with the Commission members who were intended to be the "representatives of the people."

The same problem of role blocking exists for the public at large under this scheme. Just how would the public get any input into the process if the Commission is limited to only considering language coming from the Department staff? The Department chose to ignore public's concern over the 20% during the process and likewise rejected the group's recommendation to adopt 14%. Under this scheme, the staff effectively blocked consideration of the public's input by simply refusing to insert the public recommendations into the draft produced for the Commission's consideration. Under such a doctrine, the public's confidence in the Commission would decline to the point where it is hard to imagine why anyone would be willing to take the time to drive to Olympia for a Commission meeting or even send an email.

I point out how Dr. Kraemer (ad hoc member) expressed to all of you his frustration over the Department's use, or misuse, of the citizens in the Willapa process during his testimony before the Commission on Thursday. Now, comes this latest wrinkle. Imagine how it will look to Dr. Kraemer and others who have invested so greatly in this process if this dubious claim lack of public disclosure is somehow rug-weaved into grounds for a "flip-flop" by the Commission? I surely wouldn't want the challenge of selling that rationale to the public to rest on my shoulders.

In summary, a claim that the Commission did not follow legal protocols when amending the draft interim policy from 20% to 14% is contrary to our legislative processes in WA wherein the use of "floor amendments" are common place. The claim fails once again under the standards of the Administrative Procedures Act (APA). Further, the claim also contradicts the Department's own historical behavior. As an example, the Department adopted a commercial season WAC for Grays Harbor in 2013 at the request of its commercial advisers that was significantly different than the season presented to the public in advisory meetings and the APA hearings on the WAC. The rest of the advisers and the general public found out about it after the season was adopted and the WAC published. The Department quickly pointed out that the APA allowed changes from the original language as long as the record showed a citizen could reasonably envision a change was possible. The record for the interim policy as shown in the attached meeting minutes clearly establishes the standard quoted regularly by Department staff was met and exceeded long before the Commission voted on Thursday.

Respectfully,


XXXX XXXXXXX
Twin Harbors Fish & Wildlife Advocacy

I am happy to write letters on this, but would like a few facts first. I was at the commission meeting on Thursday but not Friday. Did something happen after noon on thursday that was public?

I'd appreciate facts not somebody in SF said something that could be construed as hurting one of the commissioners feelings, but we can't tell you who said it or who's feelings might have suffered.

I'm sure all manner of backroom pressure has been and will continue to be applied on WB managment. I have a hard time writing letters based on internet conjecture.

While some may be shocked that WB managment might have historically (and even presently) be predicated on half truths and outright falsehoods, I would be more shocked if it started to be managed on the basis of facts, data, and sound scientific principles.

Sent

I am pleased to read that the commission has continued down the path of conservation when decisions are being considered. This time the 14% impact instead of the 20% impact on wild salmon in the Willapa Bay fishery.

Sent to commission and Director of WDFW.

The idea that harvest impacts of 10%, 14%, 20% 30% and other scenarios have not been modeled or discussed in public prior to the meeting on 4/9/15 is patently absurd. All of these possibilities were discussed in many different WB workshops with the public present. While much of the public commentary may not have been particularly cogent and staff presentations less than completely clear, it was discussed ad naseum with ample opportunity for both advisors and the public to share their view both in writing and speech. Furthermore, the AHA model has been available to the public for months on the WDFW website to run the model as they see fit. This goes way beyond any historical level of transparency of WB management and cannot be construed as a failure to notify the public in any rational definition of due process or public transparency. In fact for all its warts, the WB policy process has not had any failings with regards for public participation as all advisory meetings and workshops have been open to and attended by the public including the commission meeting of 4/9/15

Here are some well thought out comments from a long time Willapa fisher. He did a good job I think.




Honorable WDFW Commission members

In reference to the proposed 2015 interim Willapa Bay policy.

First off, I sit on the Willapa Bay Advisory Committee as a recreational advisor & have since it's inception. I also attended this last Commission meeting. I have heard that now there is a push from some interests in trying to remove the 14% Chinook cap amendment you voted on & approved on Thursday.

I / we, & the public have seen the AHA model & it's bottom line at public meetings. Some however may have not understood the consequences.

I believe that you the Commission, did the right thing in regard to Chinook conservation on the Thursday meeting. Mainly, if there would ever be an ESA listing on the bay, (and there appears to be a distinct possibility), as Commissioner Carpenter pointed out, by trying to do a PATCH that NOAA would not accept, life for everyone who fishes this bay WILL be very different & not in a good way for a long time.

Also, if there was even a Phase in from 20% down to 14% over 4 years, we may not have enough recovery to achieve any conservation goal for a VERY LONG time.

There are some things in HSRG that I disagree with, but overall salmon management in this state needs a guide, and this has to be something other than personal agendas.

XXXXXXX XXXXXXX

And another's thoughts are in.


I have been a member of the Ad Hoc Advisory Committee which has been advising your staff on subject policy for several months. We have reviewed and commented on many approaches and associated computer runs. I have attended at least three lectures on HSRG standards and measures. We have seen many runs for our drainage using an assumed harvest rate of 14% on Natural Origin Recruits. At this rate it seems difficult but possible to make escapement goals for Chinook in 21 years or so. In the April 9 commission meeting, your staff presented you with proposals for a 20% harvest rate in an interim period for at least the first four years. In this proposal delays are so great as to stretch credibility of ever meeting escapement goals. I testified as such on the eighth. It will be essential to stick to the 14% harvest rate or lower for many years to come. Public input and participation has been extensive. Now is the time to stick to our knitting on this well aired subject. Fears by some on the commission about ESA listing are well founded and we must show some good faith effort here.

XXXX XXXXX

I sent this yesterday.

Members of the Fish & Wildlife Commission

Thanks for your time and efforts on the Willapa Bay 2015 reform process. Please hold the maximum impact level at 14% on wild chinook in the Naselle and Willapa Rivers.
I believe this is the harvest rate moving toward recovery from the modeling.

Thanks for giving WDFW staff this direction.
I support your decision and urge you to hold firm on the principles of conservation.

Warmest regards,
Hans

And another that is in !!!!!



Commissioners:

has been a long public process that was designed to develop a management framework for Willapa bay salmon fisheries. WDFW persists in maintaining that the foundation for management decisions be science. To that end the process included the use of the most up-to-date tools, including the All-H-Analyzer (AHA model). Repeated iterations showed that the MAXIMUM terminal exploitation that would allow for recovery on a 20-year time frame for Chinook was 14%. Based on this, Grays Harbor-Willapa Advocacy and numerous advisers developed and supported a management plan that aimed at a 14% exploitation, knowing full well that the WDFW track record in Willapa bay has been to severely underestimate actual exploitation.

WDFW staff did not even provide the Commission with this scenario, much less an explanation as to why the only model to show recovery was not at least presented.

Willapa Bay is unique in Washington. It is the only area where management is the sole responsibility of WDF. The Federal Government is not involved as there are currently no ESA-listed salmonids and the are no co-managers. To that end, Willapa Bay should be a shining example of how well WDFW can manage salmonids, can achieve HSRG goals, can achieve escapement targets. There should be no excuses for Willapa Bay not being a shining example of how salmon management can be done. Unfortunately, without strong direction from Commission that emphasizes long-term conservation over short-term ease this will not occur.

I urge the Commission to adopt the 14% maximum Chinook exploitation for Willapa Bay and further direct WDFW staff to exercise hands-on management to ensure escapement goals are met.

Just saw this, sent an email. Hopefully not too late!

Definitely NOT too late.

Still quite a few planning meetings scheduled when the R6 crew gets back from PFMC