In presentations to the Commission, WDFW indicated that the Dec. 1 plan exceeded NOAA's rebuilding exploitation rates (RER) for all P.S. Chinook populations except for the N.F. Stilly. There is no way NOAA can approve and hope to defend a plan in federal court that exceeds its RERs for all but one population.

(RERs are the maximum exploitation rates that populations can withstand without adding risk to their survival or rebuilding according to NOAA's calculations. Salmo g or others with more technical knowledge can probably explain this better.)

Evidently, there is some additional technical work that needs to be done to square NOAA's RFRs (which I understand are based on coded wire tag data used by the PST Chinook technical committee) with the exploitation rates used in the Dec. 1 plan (which I understand are based on the FRAM model used by WDFW and the Tribes).

I think the RER issue is going to be a key one, not only for the P.S. plan, but also in PST negotiations.

Keep the Big Picture in focus...we are not yet out of the 1st inning of this "ball game". There are a good many at-bats, runs, hits, errors, sacrifices, double plays, men left on base, etc. in the innings that remain.

Two very important achievements at this point--1) the Rec fishermen have a pulse and are not collectively dead as many believe, and 2) The Commission has publicly established their rightful leadership and oversight of the resource. The countless years of "our hands are tied", and "the problem is the Tribes and the Feds " are now simply excuses, rather than reasons, for the Fisheries Management's lack of action on the stakeholder's behalf. I can predict with confidence that no Director will ever again ignore and bypass the authority of the Board of Commissioners.

A critical concern at present is renewing and maintaining the public scrutiny that was the catalyst in bringing this about. More than ever, the need for greater transparency along with restructuring policy have proven to be of the highest priority. Your Father's WDFW simply can't and won't cut it any more...

One last point. Not to be pessimistic, but . . .

I looked back at the P.S. Chinook Recovery plan. Back in about 2006, about $60 million a year (since ESA listing in 1999) was being spent on P.S. Chinook recovery, and there were pleas at the time to increase that amount.

Someone please correct me if I'm wrong, but if the same annual amount was spent from 2006 to 2017, that equals over one billion dollars spent since listing on recovery of P.S. Chinook.

Yet, according to NOAA, the Tribes, and WDFW, the ESU as a whole, many of the populations in the ESU, and the habitat supporting the ESU continues to decline, in some cases significantly.

While I applaud Commissioners McIssac and Carpenter and the rest of the Commission for trying to find a solution that conserves the species while not resulting in significant cuts in sport fishing opportunity, I fear the mitigation measures listed in WDFW's press release are "too little to late" and that significant harvest cuts somewhere may be unavoidable.

Hope I'm wrong (it wouldn't be the first time).

Probably a dumb question, but it won't be my first....
Does the ESA listing of PS Chinook only apply to wild chinook or all chinook, whether wild or hatchery?

Thanks,
SF

All natural-origin Puget Sound Chinook are part of the ESA-listed species. Many PS Hatchery Chinook are also part of the listed species.

Here's a report that shows which hatchery programs are part of the listed salmon ans steelhead species. Look for the Puget Sound programs.

http://www.westcoast.fisheries.noaa.gov/...jones-et-al.pdf

Thank you for the link.
SF

How do we get change north of the border?
If we came out with a management plan similar to the status quo, how would it get approved by NOAA? Why would those up north reduce there 71.1% of Stilly mortality?

We had to make drastic cuts here to expect any change. We are unlikely to see any change, but just slight reductions on SUS stocks north of the border could have big effects on all our Salmon runs.

In two weeks there will be an Acting Director at WDFW. With little to lose, it would be an opportune time for the AD to review a bullet point summary of PS Chinook stocks ER by fishery. If my cursory review is correct, most harvest pressure happens north of WA state. Perfect timing for the WDFW AD to advise NMFS that since the ESA is federal law, since the PST is federal, and since inter-state matters of ESA are federal (i.e. AK, the rogue nation), when NMFS gets Dept. of State to obtain cuts in WA Chinook exploitation from AK and CA, then come back and talk to WA. Meanwhile WA will continue to steer the conservative course it has in recent years. Time to fish or cut bait. Well, maybe that's a poor phrase. Call the bluff. It can't get any worse. Oh, and if NMFS pulls the federal LE trigger (different than threatening), then WA cuts all hatchery Chinook production immediately on that day. Cuz if it gets that bad, WA license buyers and taxpayers should stop funding the bleeding. It's just business at that point.

Since NMFS appears to be violating the ESA by allowing the exploitation up north, maybe we can get Bobby to sue them and get them to stop it. He certainly has no qualms about suing the government. Perhaps someone can try to create the angle that it is the conservatives and big business teaming up to steal from Washington Citizens. That should get him a real excited.

You left out that the MMPA falls under NOAA. Furthermore, I haven't read anything even suggesting that the ESA listed Orcas don't treat wild and hatchery Chinook exactly the same. And if they are starving now the public needs to connect the dots as to the potential impact of additional hatchery closures (as I recall WA chinook production has been reduced 60+% since the mid-80s).

Anyway, the Nuclear Option is an interesting thought.

Might have to get the public involved as to which they would rather have. Wild chinook or resident Killer Whales. Given what has been going on since Chinook listing, NOAA prefers wild salmon.

Or a seal/sea lion on every rock which was the intent of my MMPA reference. Aarf Aarf

Absolutely. Restoration of salmon is too politically inconvenient.

Notice how well ESA has worked (it has, actually) on some species like Grizzly, wolves, Condors, Peregrines, Whooping Cranes, gators ... They don't have big consumptive harvests associated with them and they appeal to a broader audience. They also are "watchable" so a non-consumptive industry can grow up around them.

I listened again to AAG MIke Grossman's defense of the PSCHMP to the Commission.
One thing he harps on is that the plan must meet the standard:

"mitigation has to be reasonably certain to occur"

Which I guess is a stipulation by NOAA. My question is, and I know this has been covered many times over, how could ANYONE (including NOAA) look at the last 30 years of declines, harvest cuts, more declines, more harvest cuts...then look at the PSCHMP and say:

"yep - more harvest cuts, that's definitely gonna do it this time!"

It's the one thing that we are fairly certain that if deployed on its own, will NOT work.

It definitely and clearly doesn't meet NOAA's standard and it doesn't meet the standard of COMMON SENSE

My point is, we are so deep in the weeds with policy and a a plethora of different bureaucratic agencies (all seemingly driven by a single thing - the fear of litigation), we've completely and totally departed from common sense.

He belabors, "we are doing things that harm chinook". I agree that harvest DOES harm chinook, But it's been verified that the #3 and #4 spots (#1 and #2 being tribal) on the stilly chinook impact list - area 7 summer/winter sport seasons - ACCOUNT FOR ONLY 3.4 FISH

Total departure from reason!

Setting aside all the policy BS and trying to look at it from a macro perspective...if a harvest-cuts-only route were to be taken, logically sportfishing would be the LAST place to look because that would provide the LEAST BENEFIT.

Yeah hands are tied by Boldt, PST, AK, BC blah blah blah. Circular arguments back to why it's sportfishing that has to be the one to suck it up.

And here's where the economic value SHOULD come into play. Is the juice worth the squeeze? What are the measures that will maximize the benefit for fish and minimize the impact on the economy? Once again, sportfishing would logically be the LAST stop because it's the lowest impact and generates the most dollars. Specifically WA sportfishing because it's mark-selective.

So how about some leadership? We need a Ted Stevens of WA
(OK maybe not *exactly* like Ted Stevens, but somebody who can get stuff done instead of quake in fear of getting sued)

I think experts can punch holes in McIsaac's proposal all day long, but even just the skeleton plan he laid out would (seems to me) come ALOT closer to meeting NOAA's standard than the same 'ol harvest cuts. It at least has a precedent.