Great article on the proposed changes:(Link to article:
Bellingham Herald OUTDOORS: Fishing rule changes may be significantDOUG HUDDLE - THE BELLINGHAM HERALD Washington sport anglers should be following closely the process under way now that will largely decide the future of recreational fishing for 2010 to 2012 and perhaps much further into the future.
The public comment period on the 2009 round of proposed sport fishing regulations changes comes to a close Tuesday, Dec. 1.
A compendium of all the proposals can be found on the Washington Department of Fish and Wildlife's Web site at: (LINK:
2010-2012 Sportfishing Rule Change Proposals )
In the package of more than 100 proposed changes to fresh and saltwater rules are significant, some say radical, departures from the traditional sport rulemaking philosophy.
One, if adopted by the commission, will alter the foundation of sport angling for gamefish in this state.
But first, here's the rest of the timetable, which is short.
Following closure of the written comment period, those will be compiled and provided to the fish and wildlife commission. Then on Saturday, Dec. 5 in Olympia the commission holds the one remaining opportunity for general citizen input on the proposals at a public hearing before the committee-of-the-whole.
Adoption of the sport fishing regulations package either in whole or in part will take place at the commission's regular February session also in Olympia. No testimony will be taken at the adoption proceedings.
A CHANGE AT THE CORE
For the better part of 75 years under the old Washington Department of Wildlife and Game, the fundamental rule in recreational fishing said that during the stream fishing season, all freshwaters are deemed open for the taking of gamefish under general or statewide bag limits and regulations unless or until they are altered or closed by a special regulation that must be listed in the pamphlet. The stream season now opens the first of June and runs to Oct. 31 each year and is extended in major streams if winter anadromous species such as steelhead are present.
Under proposed regulation 23, called the 'Stream Strategy for Puget Sound and the Straits,' if adopted, that basic tenet would change and all streams would be closed to gamefish angling unless they are opened by special regulation.
If this sounds familiar, this approach has been the wellspring rule governing angling for food-fish including salmon that was adhered to for decades by the old Washington Department of Fisheries.
When the two agencies were merged in the mid-90s the dichotomy was kept for food-fish: closed unless opened and for gamefish: open unless closed.
Now with so many Puget Sound salmon, bull trout and steelhead stocks in peril and falling under the exigencies of federal species protection laws, Washington is seeking to tighten its management regime to provide what managers call the maximum possible protection for listed stocks at all life stages.
In the tangled web of fisheries management, sport fishing for gamefish (steelhead, trout and warm-water species) is the domain where the fish and wildlife commission and department have the closest thing to absolute regulatory authority.
Other sport fishing opportunities are bound up in a complex of international treaties, state and federal laws as well as federal court decisions so that matters such as salmon, halibut and Columbia River rules and regs are dealt with in other forums.
The full impact of this paradigm shift, as agency fish managers are calling the proposed rule change, will not likely be fully felt at its start. But it provides a mechanism for slowly restricting sport fishing wherever listed game- and food-fish species are found in freshwater environs under the rationale that those sacrifices will lead to recovery of runs.
To demonstrate how proposal 23 initially would be implemented in year one, there is an 83-page table attached to the proposal package that gives a basin by basin rendition of rivers, creeks and beaver ponds that, by rule, would be opened in the first year plus an indication of those that would remain closed.
A SECOND MAJOR SHIFT
An administrative policy shift, which has already been made and now is in effect, also will influence the frequency with which change is effected in sport fishing rules.
As of this year, the regulations setting process for the basic recreational rules, such as the process underway now, will be done every other year, instead of the way it has been done in the past: annually.
Agency managers point to staff cuts and the increasing burden of other administrative obligations as reasons for cutting out the every-year opportunity for consideration of changes or additions to the fishing regulations.
SOME ISSUES AT THE CORE
The resulting effect of these two changes working together would be tighter unilateral control directed toward protection of listed fishes (especially in their juvenile phases) and less flexibility in providing for recreational fisheries.
There are several things to keep in mind if proposal 23 is adopted:
- The assumption underlying this rule is that sport fishing, not only has a universally adverse effect on the abundance of listed species, but that it is a major factor if not 'the' key cause for their declines.
There are many things responsible for the imperilment of Puget Sound anadromous fish stocks, but the institution of this rule gives the impression that the blame should be put squarely, and some argue logically, on sport fishing.
However, by example, the case has yet to be made that harvest or at least hook and line fishing for them is the singular contributing factor in the downturn of Puget Sound steelhead stocks. Sport angling for them largely halted in the mid-1980s to early 1990s, but there has been no corresponding improvement in their apparent abundance.
- In an ideal world, decisions to not open a stream would be based on a sufficiency of factual information, objectively gathered and specific to that stream or sub-basin area. Some questions included in each individual evaluation would be how much recreational fishing goes on, how many protected fish in their different life stages do anglers come in contact with and how many survive those encounters. It may be that the level of fishing has no effect or is not the chief or proximate cause of a species' poor performance.
However, the department simply does not have the field staff to do such work. Whether it is admitted or not, such a limitation (a data deficit) imposes a bias on decision-making processes. In situations where there are over-arching concerns about declining stocks, managers will likely choose to err on the side of the resource and eliminate the perceived threat by leaving a stream closed. Inaction if no information exists is the default protection for fish stocks every time.
Methods for effective study, accurate determination of spawning numbers and rationally based assumptions concerning the numbers of adult spawners needed to perpetuate every stock are necessities.
- A corollary element to this process is the measurement of results, again, which the agency is increasingly challenged to obtain on a case-by-case basis.
There are examples of how the consequences of limited deployment of field personnel and reduced monitoring already affect fishing rules. Such is the case with federally protected bull trout and Dolly Varden, a native char in the Puget Sound basin. A statewide rule bans retention of these char except where expressly permitted such as the Skagit River.
The reason the Skagit's char were exempted from the statewide rule was because spawning ground surveys mostly funded by Seattle City Light's Skagit Project mitigation monies provided data on the relative abundance of these fish and provided managers snapshots of the age classes in each year's run.
The North Puget Sound inland fish biologist position in part charged with doing those surveys was eliminated in 2009 budget cuts, those duties have been dispersed to staff who already have full plates documenting salmon spawning in the fall.
The Nooksack River, since Puget Sound bull trout ESA listing has stayed closed under the statewide rule because no systematic assessments have been or can be done, though anecdotal information from anglers suggests they may be quite abundant.
The status of Lake Whatcom's wild cutthroat trout and angling for them as well as the Upper South Fork Nooksack closure are yet other examples of needed stock assessment and creel survey work not being done and thus affecting management decisions.
FISCAL IMPLICATIONS
The relative fiscal health of a significant section of the fish and wildlife department's fish program hinges on the perception among potential buyers of sport fishing licenses that affordable, legitimate recreational opportunities are available.
A portion of sport-fishing license (combo and freshwater) proceeds go into the department's wildlife fund, a separate pot of money that, in part, pays for many gamefish management functions including trout hatcheries.
Fishing is a highly personal form of recreation for everyone who partakes of it. From a user perspective, the more diverse and plentiful the options, the more desirable the opportunity is to secure through the purchase of a license.
Polls and surveys often attribute declines in hunting and fishing license sales to causes such as shifts in generational attitudes or competing interests vying for attention. But don't underestimate the viability or marketability of the product itself.
Gamefish management programs in virtually all states including Washington financially depend in large part, if not exclusively, on the largess of anglers either through payment of license fees or federal excise taxes on the sale fishing gear, which come back to state agencies.
Despite the appearance of having the consumer upper hand, anglers should not be complacent or take their opportunities for granted. The angling supply and demand situation is not the same as say the auto market where if General Motors fails there is always a Ford or Toyota to fall back on.
Anglers as consumers must encourage the sole-source supplier, in this case the state, to provide the spectrum of opportunities that make buying a license worthwhile.
MORE DELIBERATENESS NEEDED
No less an authority on Puget Sound salmon, steelhead, cutthroat trout and bull trout than Curt Kraemer, retired WDFW fish biologist and regional freshwater program manager, at a public meeting in October on this and the other regulations proposals said that while the imposition of proposed rule 23 was intriguing and may hold some promise, the initial application drawn up by the department had many flaws and inaccuracies.
Kraemer, whose experience in Western Washington game and food-fish management both in the field and behind a desk spans more than 30 years, did not elaborate on the inadequacies he found in the proposed 'openings list' of Puget Sound streams but summed up his opinion by recommending that the commission not adopt proposal 23 in February. He suggested that more work be done to develop the entire process before it is reconsidered.
Implementation of a proposal with such far-reaching ramifications, which stands to be employed without the benefit of ever-improving evaluation methods and better data or the discipline of use guidelines that the public fully understands and accepts, should be postponed.
For now, given what is at stake for the community of sport-fishing enthusiasts, that's the best course of action.
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