Just rec'd the following:

https://nwtreatytribes.org/frank-sport-crabbing-needs-season-management/


Being Frank: Sport Crabbing Needs In-season Management

Being Frank is a monthly column written by the chair of the Northwest Indian Fisheries Commission. As a statement from the NWIFC chair, the column represents the interests and concerns of treaty Indian tribes throughout western Washington.

The same principles we use to manage many of our salmon fisheries should be used to regulate recreational harvest of Dungeness crab in Puget Sound.

During most chinook salmon fisheries, we develop in-season estimates using catch data gathered from anglers returning to the dock and from fish tickets issued to treaty tribal and non-Indian commercial fishermen when they sell their catch. This allows us to verify our pre-season forecasts, track catch numbers in-season, and decide whether to add or close fisheries to meet our harvest and conservation goals.

Crabbing in Puget Sound has nearly doubled since 1996, when state and tribal crabbers shared a harvest of about 6 million pounds. Because there is no monitoring of Dungeness crab populations in Puget Sound, we have no accurate estimate of how many there are. We think this lack of knowledge requires a more a more careful approach to managing the resource.

When treaty tribal and non-Indian commercial crabbers sell their catch, buyers document the amount of crab, location of harvest and other important data. This information is then shared between the tribal and state co-managers, often within 24 hours. It’s the kind of information needed for effective in-season management.

The same cannot be said of the recreational Dungeness crab fishery.

The daily bag limit for recreational harvesters in Puget Sound is five Dungeness crab, males only, with hard shells that have a minimum size of 6 ¼ inches. Recreational crabbers are supposed to keep track of their harvest on a catch record card that is mailed to WDFW or reported online after the season ends.

The problem is that these rules – implemented in 2007 – are being ignored by many recreational crabbers.

More than 200,000 catch record cards are issued each year, but only about half are returned as required by law. The penalty for not reporting catch is a mere $10 fee tacked onto their next license.

Some recreational crabbers are not recording their catch at all, exceeding catch limits and crabbing when the fishery is closed.

July 4 this year provided a good example. Recreational crab fisheries in Puget Sound have been closed on Tuesdays and Wednesdays for the past couple of years, but many assumed the fishery was open because of the holiday. According to news reports, WDFW enforcement officers in one area found crabbers in seven boats breaking regulations meant to protect the resource. Most said they were unaware crabbing was closed. Some also had harvested more than their limit, and retained female, soft-shell and undersized male crab.

How accurate can the data be when catches don’t have to be reported until the season is over, and the entire program is based on a self-reporting system?

Recreational crabbers harvest most of the non-Indian share, and we think the recreational harvest of Dungeness crab is seriously underestimated. We have asked WDFW to better assess sport crab harvest by conducting catch surveys when crabbers return to the dock. It’s been 10 years since the state last made such an effort.

Until there is a better understanding of Dungeness crab in Puget Sound, we encourage WDFW to increase monitoring, enforcement and education of recreational crabbers to improve compliance, protect the resource and err on the side of caution.

Perhaps we should require all crab be tagged like dear and elk. We could even have reporting stations at every local gas station and convenience store where biological samples and harvest records are entered into a log and returned to the WDFW to be processed in 5 or 6 years maybe never...

a 50$ tag is still cheaper than 5.99 per pound for 2 months out of the year...

on a serious note, the shorter and shorter the seasons get the more concentrated the effort and the more likely there will be for people to poach because of the limited opportunity... when we had year round crabbing, there was never a thought to keep a barely legal or over limit because you could always come out tomorrow or next week, Now that we have only 40 something days, a person thinks about it every time they are out. fortunately, crabbing has been so bad recently that it is not an issue...

"Until there is a better understanding of Dungeness crab in Puget Sound, we encourage WDFW to increase monitoring, enforcement and education of Tribes to improve compliance, protect the resource and err on the side of caution."

Fixed it for you. Turn about is fair play. There is a reason why there are no crab this year and it ain't the sporties. Just like with fish, until we remove the monetization of the crab resource, there will be less and less and less to go around. Last I check, it was against the law for me to sell any of my 5 crab. How about you Mr. Native Man?

As I opined on the other thread the amount of money WDFW gets from the PS endorsement should be sufficient to yield meaningful annual stock assessments for each management area. Of course, the tribes should come up with their half of the cost....and the NT commercial fleet needs to pay their fair share or simply get off the water.

My perspective is that using a running five year average may be okay when the crab population and mix is stable but on a downturn of the cycle that methodology leads to overestimation of the harvestable poundage which means overestimation of the tribes "half" and the State's "half." Unfortunately, when tribal crabbers have first opportunity they fish toward that "half" even extending their seasons in an attempt to achieve that harvest number. The problem is that their "half" may well be more than half of the actual harvestable poundage meaning the State gets shorted.

Now, as to recreational crabber violations. Sure, on the water violations happen when 30% are new every year and, yes, there are also some intentional violators. That said, the State does have active enforcement on the water and does write up tickets which are adjudicated in a public manner.

Can that be said of the tribes? No! So, for the tribes I challenge you to open up your own proceedings before criticizing the State and its crabbers.

Natural for one side to question the other, and vice versa all over again, when an allocation is split 50/50. Kinda like looking to see who got the bigger ice cream, then complaining about it.

The issue is Puget Sound historically fed its residents. Now it tries to feed the world. Read: $$

And I don't think recreational crabbers are selling anything. UAG interpretation has changed with time. Historical UAG and Boldt (1970'2) interpretation of UAG is different than it is now, and capitalism is to blame.

Question: If Puget Sound crab stayed here, would there be a shortage?

So what if tribal and commercial record all their catch? Where does it go then? UAG should be consumed locally. It was never meant, nor did it ever, feed anyone out of state. Same with salmon, geoduck, you name it.

In season real-time management: Yes. $500/crab fines: sure. Real time data from co-management that starts on the same date: we'll get better data.

$10.00 fee, tacked on to the next license fee is xhit money in todays world...make it $50.00 or better yet $100.00, sooner or later WDFW needs to get real.

I'd like to see the same done for salmon/steelhead punch cards....it is shocking percentage wise the small number of punch cards returned...

During the proceedings leading up to the current P.S. crab mgmt policy the NT commercials objected to giving up any poundage to the recs saying that to do so would mean a shortage to WA residents. An astute member of the Commission directed the then Shellfish Manager to investigate where commercially caught crab was being marketed. No big surprise that a huge percentage was going out of State and out of country being shipped alive to Asian markets. So, your point is valid; commercially harvested crab is not in short supply IF you want to compete at the retail level with consumers in Chicago, NY or in a variety of Asian countries.

I should add that anyone crabbing on a rec license and selling their catch is an illegal commercial harvester (poacher).

Here's the eyeDOC's fix....

Charge $25 for the tag imprinted with bar code that automatically takes $20 off the purchase of the next year's license when it is scanned upon surrender.

No cash changes hands for the surrender... just a simple swipe at the time of license purchase.

Simple, cheap, effective .... 10% compliance would jump to >90% among repeat license buyers

One of recreational fisheries managers' biggest problems is that repeat buyers are not a very large component. Saw a paper a couple years ago and, if memory serves, it was something like 30% don't renew. Seems there is a base, which is probably where the harvest is, and lot of folks who try it and don't like it.

Plus, I think the majority of regular buyers are chronologically gifted and not being replaced.

That said, I think Doc's idea should be added for all of the mandatory report requirements. Big game tags, CRCs, crab, all of it.

As I recall the return on summer cards has been about 52%. If one assumes that none of the cards from the 30% of non-renewing crabbers are returned then the potential drops to 70%. Subtract the actual 52% and you have the potential to increase CRC returns by 18% of the total. Note that far fewer winter cards are issued and the rate of return is much higher. The report on the 2016 season will be presented to the Commission this coming Saturday.

Some of the endorsement money was spent surveying those who did not return CRC info and most of those did not crab or caught no crab
which reinforces your perspective that regular crabbers catch the majority of crab and are far more prone to regularly return CRC info.

From a marketing standpoint the loss of 30% of one's customers every year means there needs to be the same number of new customers just to stay even and that comes with its own problems of new crabber ignorance as to regulations and how to crab without losing gear.

That was the point of the article on fishing license purchasers. Two big issues were the lack of people buying annually; it was not a large component, and the mass of one-time buyers.

WDFW has some built-in advantages with its license sales. Since a majority of the fisheries offered are best pursued in a boat or with specialized gear (crab pots, shrimp pots, pullers) and even a big tow vehicle so folks make a fairly significant investment. The license then is a small part of the cost. We get the "Oh, hell, I'll get a license as I have the boat".

But, they are going to have to make an effort to ensure that license holders get a return on investment or they'll invest elsewhere.

And, like Larry says, there needs to be an investment in education. A while ago WDFW had one staffer who particularly educated the immigrant communities in shellfish biology, regulation, laws, and such. The agency was making an effort to reach out. When he retired his files (including contacts) were "recycled".

http://wdfw.wa.gov/publications/01886/wdfw01886.pdf

Still blows me away that they extrapolate data from 9.3% of the cards.

While the pool of repeat annual buyers may be shrinking, as a group they probably represent the bulk of the harvest. These are the guys that are fully invested in the game... they're going fishing regardless.... and odds are pretty good they're in a group of the better, more productive fisherfolks.

Reliably capturing their harvest patterns would be a very good thing for the agency.

I am more concerned about the future of the agency. If the pool of regular buyers of licenses is aging and declining then the end result is not good.

Here is the link to the crab report on the Commission's agenda for Saturday:
http://wdfw.wa.gov/commission/meetings/2017/08/aug0417_18_summary.pdf.

And here is the summary:

The Puget Sound crab fishery policy (Policy C3609) was reviewed and revised by the Commission on October 1, 2010. The policy stipulates that a Department report summarizing the Puget Sound crab fishery will be given to the Commission on an annual basis. This briefing will summarize the performance and harvest of both commercial and recreational fisheries and regulation compliance by enforcement staff during the 2016 season. Puget Sound crab fishery landings have been robust in recent years with a peak in 2015 and slight decline in 2016. Recreational crab endorsement sales show an increasing trend with over 240,000 sold annually in 2016. New crab fishers compared to the total are declining and represented about 26% of the total crab endorsement sales in 2016. There is an intensive enforcement effort for this fishery. Catch record card violations and retention of undersized crab continue to be issues during enforcement contacts with recreational fishers. Commercial crab licenses have been limited entry since 1981 and the total number licenses is 249. Commercial crab harvest is limited to northern Puget Sound and 2016 ex-vessel crab value exceeds $11.7 million.


It is unfortunate that we are only days away from the mandatory annual report to the Commission yet the full slide show is not yet posted. So to respond to enforcement issues of concern as noted in the summary:

1. CRC Violations: First, it is important to remember that WDFW LEOs are on emphasis patrols specifically looking for violators meaning they are watching and targeting areas of known problems and/or suspicious behavior. It is NOT a random process. In addition to the LE contact data there is also data from creel surveys which is more of a random data set. Here are the comparable results as extracted from the report for the 2015 season (http://wdfw.wa.gov/commission/meetings/2016/04/apr0816_20_presentation.pdf) :

Year........Enforcement.......Creel Survey

2010.....................24%............................13%
2011.....................19%............................11%
2012.....................20%............................12%
2013.....................16%.............................9%
2014.....................17%............................. *
2015.....................17%..............................6%

* No data reported.

So, the LEOs' reported violations (failure to promptly record) is substantially higher than what is noted during creel sampling and that creel data also made a point of only 1% not having a CRC.

2. Retention of Undersized Crab: For 2015 the LEO data had 7% of contacts in violation. This is definitely an issue which can and should be improved upon. As I recall the creel survey folks collected some data on the actual size of undersized crab they encountered and found a significant percentage were above 6 inches. Point being that they were "short" by the dimensions of the points indicating improper measuring procedure (point to point). That is an educational issue and while it is well covered in the regs and tri-fold pamphlet and the educational packet distributed at sport/boat shows and seminars it remains an ongoing issue.

If you look at the data you will see that retention of female crab and being over the daily limit are very minor percentages in violation which in my mind supports that the undersized issue is more an educational problem than intentional. Also, a contact may be recorded as being in multiple violation; that is, over limit, undersized crab and retention of female crab as well as not promptly recording on the CRC.

Regarding Puget Sound crab I believe the average crab harvest per endorsement in 2015 was been between 4 and 5 crab.

Given that harvest data for successful crabbers provided via CRCs gives both a date and a number of retained crab I have suggested to WDFW (unsuccessfully to date) that those numbers be crunched to provide (by MA and dates) the number of successful crabbers and the average number of crab retained. To me that data could be graphed and yield a picture of how rapidly harvest rates drop off and correlate that to drop off in successful trips (since the CRC does not provide for recording unsuccessful trips).

Just a quick additional tidbit from the summary: 249 commercial P.S. crab licenses harvested crab with an ex vessel value of $11,700,000. That works out to just under $47K per license in gross revenue.

At some point I would hope that WDFW and the Tribes realize that resources need to be actively assessed and managed if we are to perpetuate not only the resources but the fisheries on them. That includes stock assessment, catch monitoring, and monitoring of spawning (not only numbers but success). There are too many pressures to continue auto-pilot management.

It will be expensive. But, as is often said "If you think knowledge is expensive you should try ignorance."

They made no mention of the audit they are making the state perform. http://www.theoutdoorline.com/podcasts/ July 1

I don't buy these concerns, certainly just as many issues on the tribal side. Lots of finger pointing but it's all about harvest.

For several years they made the area 13 season longer and 7 days so we could keep up with tribal harvest. Then suddenly they cut it back.
They know those crabs are gone now.

The harvest problem in MA13 was that one tribe exceeded its agreed upon share by 3x and then 2x and then simply decided it was easier to not enter into any agreement. That is what led the State to the early openers and extended days/week; an attempt to allow recreational crabbers an opportunity before the crab were all gone. Well, the outcome of that pathetic situation is virtually no Dungies left in MA 13.

As for the podcast (Ron Garner) I suspect that the $100K is coming out of the Endorsement money. Three comments on that: (1) WDFW did a study in past years whereby they contacted folks who did not return their CRC data and were able to determine an adjustment factor and also that most who did not return the cards had not crabbed or did so only once and (2) I find it disingenuous that we would be spending more money on enforcement - after all, that is what it is - over and above WDFW's emphasis patrols and (3) recreational crabbers deserve an active, regularly meeting advisory group with oversight on endorsement money expenditures (as is done with PSRFE and CR endorsement monies) and to have agendas and minutes posted to the WDFW advisory group website (which has NEVER occurred): http://wdfw.wa.gov/about/advisory/.

But if there was oversight, Larry, there would have to be public accountability for expenditures. And seasons. And pre-season planning.

I think your post warranted several very large sarcasm emojis. And I truly understand your frustrations.

I reported to wdfw 3 crab pots out in area 11 Tuesday. Those same pots are out this morning semi drifting in the same spot.
Its illegal to pull someone else's pot even on closed days.
So they create these weekly closures, we pay for audit because we are not allowed to police ourselves.
Derelict gear is free to roam.

Here is a link to the belated report on the results of the 2016 season:
http://wdfw.wa.gov/commission/meetings/2017/08/aug0417_18_presentation.pdf.

The first thing to note is that contrary to the assertion in the NWIFC's article the recreational harvest has not exceeded the NT commercial harvest in any of the years reported and I will go out on a limb and say it has NEVER exceeded the NT commercial harvest. Sorry NWIFC, the stats prove you wrong!

Now, in 2015 there were 25 WDFW LE patrol days which yielded 1,099 recovered pots and 187 which were disabled and tagged. In 2016 there were 21 patrol days and 535 pots recovered and only 23 disabled and tagged. Not too hard to spin that data to conclude that recreational crabbers did a far better job in 2016.

It also needs to be pointed out that not all recovered pots are recreational pots; see the picture on page 31. Deputy Chief Cenci's article in the current (Aug 2017) Reel News indicated that out of 518 pots recovered so far in 2017 sweeps the identifiable recreational pots accounted for 306.

I may be in a gray area but on occasion I have pulled floaters into shallow water and then left them. If there was a telephone number on the buoy I have called the owner. In one instance the owner reported he had lost the pot several days earlier but was out on his boat when he took my call. Didn't take him long to show up.

And to update the WDFW LE versus creel check data for CRC compliance:

Year................Enforcement.................Creel Survey

2010.....................24%............................13%
2011.....................19%............................11%
2012.....................20%............................12%
2013.....................16%.............................9%
2014.....................17%............................. *
2015.....................17%..............................6%
2016.....................17%..............................2%

* No data reported.

And for 2016 the creel check data showed 100% of those checked had CRCs.

Those numbers don't seem too bad. I bet alot of those are non resident or first time crabbers.

It would take a good 10 minutes to kick down further to where those pots were so I did not check them out close up.(float tube)

I'm all for changing the law. If recreational crabbing is going to be closed on those days of the week, then clear red and white pots should be pulled or disabled by anyone.

The violation receiving the most LEO violations is failure to IMMEDIATELY annotate ones CRC. To some that might indicate a serious under reporting.......but the experience of the creel survey folks at the ramps indicates a much better rate of compliance. Is LE being really good or are they being far too picky?

The problems of pulling someone else's pots start with you potentially coming into conflict with the owner. Next would be with LE; "Honest Officer, its a lost pot and I am simply doing my part for resource conservation."

At some point there was some talk about providing some non-LEOs authorization to retrieve pots but nothing on that lately.

My big issue is with floaters or buoys that are only visible at extremely low tide. Those are prime candidates for becoming derelict gear. As I mentioned, I have pulled some of those to shallow water and left them for LE to retrieve.

quite a few years back my dad and I were fishing in lower hood canal and there was about 20' of floating poly rope on the surface with no bouy that was right in our trolling path. we pulled it to get it out of the way and it turned out to be connected to a shrimp pot full of fresh bait and a bunch of spots shrimp in it. we dumped the shrimp and threw the pot in the bushes, its probably still in the bushes to this day.

Since I'm usually a weekend warrior we never needed to worry about what days crab was open. but the family and I were out camping this week and everyone in the group was double checking when pots could be in and out of the water, i feel sorry for the old timers like my dad without smart phones... I hate these types of regulations. Keep it open all week and make it easy.

2 keeper dungees in (3) 3 hour soaks of 6 pots on monday with fresh salmon carcass as bait in an area that was productive last year... it wont be long and the only crab in PS will be red rocks...

It's Tuesday again. Same three pots are in the same spot.

Exactly to whom did you report those pots?

That is, did you report them to the poaching hotline (1-877-933-9847) or via email REPORTINGPOACHING@DFW.WA.GOV?

Me, I like email because then I have a record.

Assuming you reported the same pots they are now into at least the second closure period and the emphasis patrols should have had plenty of time to pick them up given your position report.

Please give them another notice of illegal pots and request a call back when they have been picked up.

Neighbor kayaker said the pots are gone now. Hope there not just underwater. I was out at low tide this morning. I'll try to look tomorrow.
I sent a email to enforcement.

Another week another email to wdfw enforcement.
6 pots between Des Moines marina and saltwater state park.
I looked at the ones by the marina and they are all painted the same pink and green flags with no names on them.
Anyone should be able to pull up pots on closed days.
Was lucky I didn't hook one trolling.

I just sent a msg to a contact within WDFW LE with a link to this thread so let us know if they get back to you. At the least they should acknowledge your report and advise of what resulted.......that is, if they really want folks in the field to be their eyes and ears.

Thank you!

http://www.piscatorialpursuits.com/uploads/UP20963.jpg

I was out working around Mukilteo on Tuesday 8/15 and had a run in with WDFW enforcement. They were out picking up illegal/derelict gear from all over areas 8/9/10. They had a boat full of probably 50 pots or better.

Good to see them out.

I should have included these in one of my earlier posts:

http://www.kiro7.com/news/tulalip-tribe-fish-and-wildlife-director-arrested-/28782032.

And this:

http://nwsportsmanmag.com/headlines/dishonor/2-tulalip-members-accused-poaching-crab/.

And then there was the big case in Bellingham involving what I recall as Lummi tribal members. Sorry, can't seem to find a link for that one.

Not to say that they are the only commercial level violators in the recent past (they weren't) but it is simply disingenuous for any of the tribes to be pointing the finger of guilt at recreational crabbers given their own culpability. Oh, and exactly what were the results of tribal court actions against those tribal members - if any? The silence is deafening.

If they use rec violations to shut us down or reduce our share, what would stop them from dropping a few rec style pots without names to "enhance" our violation rate? Not to be paranoid but I have feeling some of those unknown pots might be setups.

I received some interesting crab pot retrieval data from WDFW yesterday which may go to why they may have been slow in getting to your area. Yearly final reports for the period 2012 through 2016 had numbers of recovered pots ranging from 405 in 2013 over 28 days of sweeps to 1,099 in 2015 over 25 sweep days. Preliminary 2017 data for north Puget Sound only (King County north) is 1,500 for 16 days of sweeps. They have been busy!!

That effort in the field, however, does not explain why you did not receive any acknowledgement/feedback to your several reports. That is not a new complaint. I am following up on that and hopefully will have more to report.

Wait wait wait...... So the dozen tribal boats out the 2 weeks before sport season wiping out northern 8-2 who wdfw claimed openly were just tribal boats contracted to do population size samples for wdfw pre sport season population estimates.... weren't doing that?
Then the 7! crab checkers at kayak point every single day, who when told about all the humpies I caught while salmon was closed on opening weekend of crab told me they "are not counting ANY species of fish nor would they record anything having to do with fish, they are only counting crab in all areas salmon is closed" ......
Weren't counting crab "in-season"?

I don't understand why tribes aren't getting blasted all over the news and social media as racists and have marches held against them. My children and I are getting treated negatively and our wellbeing and livelyhood is being held back by group of people 100% using race as the reason. I can't say black people aren't allowed to fish cause my ancestors were here first, so why can an Indian say the same to me. With all that this state is doing to make every person "equal" in so many different aspects of society, how is this giant one being overlooked?
(p.s I have many tribal family members)

At least one tribe extended their season to the extent that it overlapped the recreational opener. Reason: they had not caught their 50% of the agreed upon harvestable poundage. That is a huge tipoff that the total agreed upon harvestable poundage was likely overestimated.

I have no way of knowing if the dozen tribal boats to which you referred were fishing under that extension but I would really like to know from whom at WDFW you received information that the tribal boats you mentioned were doing population studies for WDFW at that time.

The OP has indicated via PMs that the original pots are gone. Also, he has been provided email contact info for the WDFW LE's point of contact. Seems they have been inordinately busy with errant pots.