As someone who has spent the past decade in the trenches fighting the good fight in Grays Harbor, I request that the MODS keep it stuck to the ABSOLUTE top of the board until the NOF process for 2013 is complete.
Rivrguy is to be commended for his tireless efforts to help bring the light of day on the harvest abuses perpetrated on the salmon stocks of Grays Harbor and the Chehalis Basin. This website lays it all out there in full living color. Anyone who has fished our local waters owes it to themselves to click on the link below and explore the ENTIRE site. The video tutorials are especially eye-opening.
The Commission, while somewhat insulated from the issue by WDFW staffers has been apprised by public testimony on these harvest abuses on no less than three occasions over the past decade. While commissioners may lack the detailed technical expertise of Fish Program staff, they have been made aware of our concerns.
So again, have a look-see and feel free to comment on what you read/see/hear.
Just watched all available videos, darn good information!
As one who has lived in Washington my whole life and have roots on the OP, I found the whole series very interesting. Not surprising at all as most of us that were on the OP and in Washington in the 50's, 60's and 70's knew exactly what the state was doing! It is just sad to see what the WDFW has systematically done to the Washington fisheries over the years and the worse part, it is all in their own records! They are not even hiding the shame anymore!
Should generate some passionate discussions. I hope it helps produce a positive outcome for all sport fishers in the Chehalis and Willapa basins at the end of NOF.
It is just sad to see what the WDFW has systematically done to the Washington fisheries over the years and the worse part, it is all in their own records! They are not even hiding the shame anymore!
Took some shaking, thru PDR's, to get WDFW to release information. A classical example of "we are government, we'll do things how we want, and feed the general public, what WE feel they need to know".
Still not sure the upper WDFW management, upper Region personnel and upper Olympia Fish management personnel are getting the message???
Time tells all !!!!!! Wheels of progress, move very slowly. Wynoochee River Dam mitigation is a example.....more than 20 years since a fund was established for Coho and Steelhead. That's 20 years that fish have not been placed in the river, for all to enjoy.
More will be forth coming on Tacoma Public Light, WDFW.....and the $2.4 million that "sits", grrrrrrrrrrrrrrrrrr
One of the rumours making the rounds is that TCL has (now) less than 10 years left on their operation at the dam. They could choose to not renew their operation. If they so chose, and WDFW still had not figured out how to spend the money, would it all go back to TCL?
May be in their best interest to just let WDFW play with itself.
I’ve only seen the WDFW Historical Bias video, and have found it to be interesting and informative. So well done, that I’m looking forward to watching the rest of the videos, as time permits.
Good work ! lets try and get things changed , a number of people here on this site have been inolved for a lot of years with no progress and its got to be frustrating to them. I have been involed for 8-9 years now and feel that at times we are moving in the right direction, then the department just changes its mind and tears down everything that we worked on..... very similiar to a dictatorship..................
My name is Francis Estalilla, an eye surgeon from Aberdeen, newly re-appointed member to the Grays Harbor Advisory, member of the Coastal Conservation Association, and concerned sportsman.
A little over four years ago I addressed this body in person to bring your attention to ongoing harvest abuses in Grays Harbor, particularly Chehalis River Fall Chinook. You took genuine interest in the matter and even initiated a “green sheet” to further investigate the allegations. I return today to give you a “report card” of sorts… something to consider as we embark on another NOF proceeding in the next 2 months.
Four years ago I told you that Chehalis fall Chinook had only exceeded the minimum escapement goal twice in the previous 11 years. Since then, we’ve only made it ONCE more. I’d wager that when the 2012 escapement figures are released next month, the record will stand at 3 for 15. In other words, managers are missing the mark 4 out of 5 times! In my profession, I can’t imagine the repercussions if I were to blind 4 out of every 5 eyes that I took to the operating room.
Why does this happen? Well sometimes it’s just bad luck. Some years, the total run size falls short of the escapement goal. Can’t blame the managers for fish that simply aren’t there. Hey… fish happens!
But what about most other years…. when more than enough fish show up to seed the gravel? Once those kings cross the bar at Westport, the only controllable factor keeping them from reaching their spawning grounds is the fishery.
As you are well aware, that fishery is crafted by making a preseason forecast of how many paper fish to expect, subtracting the fish necessary for escapement, and then allocating who gets to kill the remaining “surplus” paper fish. This is the annual ritual we all know as the NOF process.
On paper it all seems to work out, but in the real world, we’re simply kill too many kings. The reality is that the harvest models CLEARLY understate the true fishing power of the fleet… commercial, sport, and tribal. Moreover, understating the fishing power of one user group has an allocative domino effect as it makes even more paper fish available to be exploited by the next. As managers seek to expend every last paper fish, they’re simply fishing the stock too hard… so hard that we’ve made it past the escapement benchmark only 3 times in the past 15 seasons. Sadly the only reason we made it those 3 years is that the run-size happened to come in much stronger expected. Divine grace or blind luck? Take your pick. I would NOT want to rely on chance alone to save my bacon in the operating room.
Another insidious mechanism that promotes the systematic overexploitation of Chehalis fish is the application of faulty assumptions about the co-mingling of Humptulips- and Chehalis-origin kings in the Grays Harbor estuary. The model grossly overstates the proportion of Humptulips stock to effectively dilute and mask the true magnitude of exploitation on Chehalis stock, particularly in the recreational marine area and commercial Area 2A/2D. This allows seemingly benign fishing seasons to occur on paper pre-season…. to the direct detriment of escapement post-season.
I’m prepared to address any questions you may have with very detailed examples. Thank you for your time.
Unfortunately, I got no takers on my invitation for questions.
Here's a year-by-year summary of what I was prepared to present if they had taken any interest in digging deeper. Just wasn't meant to be.
...
How badly do the managers underestimate that fishing power? Let me give some recent examples from each component of the fishery.
In 2005 managers set a 10% impact objective of 1100 dead paper kings for the entire basin. Gillnets alone actually killed 2600 of the free-swimming variety…. most of them at the hands of the QIN.
In 2006 Region 6 set a rec season to harvest 215 paper kings in MA 2-2. We killed 5 times that many (1065).
In 2007 Region 6 set a rec season to harvest 1168 paper kings. We killed 1719.
In 2008 (with no harvestable Chinook, no harvestable chum, and only a Tier 2 coho forecast), a NT gillnet season was set to target Chehalis coho despite specific language stating “no directed commercial coho fishery”. With a NT share of only 3800 wild coho and -400 kings, the NT nets killed over 5200 wild coho AND 150 incidental kings were discarded as bycatch.
The harvest abuses and intentional deviations from the Tier Plan came to a head in 2009. At long last, WDFW finally demonstrated restraint and stewardship when Director Anderson and Pat Patillo settled a NOF stalemate in Montesano by leaving 150 paper kings on the allocation table to reach the gravel. For the first time in my decade-long involvement in this process, the state’s conservation objectives were met for all three species of Chehalis fall salmon (Chinook, coho, and chum). If that was the direct result of Commission intervention, then I owe you my sincere thanks.
2010 and 2011 saw poor Chinook returns that should have compelled Region 6 to manage with a precautionary approach but progressively more gillnet days were added to exceed the planned pre-season impacts.
2012 saw a harvestable Chinook run-size and it was back to business as usual…. with a full court press to maximize the harvest of paper fish while shirking the conservation of REAL fish.
Have only watched sevaral of the videos so far, but want to thank all involved for there tireless efforts. Thanks guys, we appreciate all your hard work.
Back when I first started in front-line management of salmon the goal was achievement of the escapement goal. If the numbers did not show harvestable fish there was no fishery. If the numbers did not show enough fish to cover incidental harvest there was no directed fishery.
That has now morphed into "share the catch". Say that in order to have an ocean sport fishery that 100 Hoh coho will be taken. To balance things, 100 will also be taken in the river by the tribes. What is most important, now, is to craft fisheries that balance catch (first goal).
After a contentious fishing season when Hood Canal coho (at one time a primary stock controlling ocean fisheries) failed to meet goal (again), the WDFW manager noted that "We had a pre-season plan, we all followed it, management was successful".
You just need to set goals that are achievable. So, Doc, your surgery goal is to perform 10 operations per week. Success is doing that. It's not the results, it's the process.
The credit for the website videos goes to Tim the site administrator. I am the gopher / teacher / traffic cop here as I lack the skills to do the videos. Good match really as I have 30 years around fish and the agency and some of the team have even more. The thing about it is this. I am in this for one reason, to break the continuing institutionalized discrimination of WDF&W toward the inland communities and inriver sports fisher. Hopefully in the process help the fish.
Agree or disagree to our views but I think we all can agree on this, the destruction of the resource for the benefit of 22 gillnetters and denying the tax paying citizens of the inland Chehalis Basin communities reasonable access to salmon harvest must end. The failure to allow additional fish to reach spawning areas to utilize revitalized, under seeded, restored habitat must end. The destruction of one species to harvest another must end. Simply put " the Big Lie " that WDF&W manages for anything but commercial harvest must end. It is " game on ".
In case I haven't said it enough, THANK YOU to those of you (you know who you are) who have dedicated so much of their personal time to righting the wrongs of WDFW's management of the Chehalis Basin. I have recently become much more active in the same pursuit, but I recognize that my efforts pale in comparison to those put forth by a few of you over many more years.
Just a note to expand on the EYEfish summary for 2012.
Quote:
2012 saw a harvestable Chinook run-size and it was back to business as usual…. with a full court press to maximize the harvest of paper fish while shirking the conservation of REAL fish.
Quote:
When the NOF was in progress for 2012 the estimated Chehalis Chinook run size was 20,515 fish (mostly wild). The escapement goal was 12,942 leaving 7,573 harvestable fish. This was split up between the Quin, Commercials, Sports, and the Chehalis tribe. This is the critical run that determines how much fishing gets done in Grays Harbor.
After the season ended it became clear that actual harvest for all groups was about 50% of the modeled rate. It was'nt your fishing skill, the fish just were not there. What this means is that the actual run size was about 50% of the forecast or just over 10,000 fish. Clearly not enough for escapement alone! When the actual harvest is known it will probably exceed 4,000 fish!
So our plan to fish to the last paper fish resulted in an escapement of less than 6,000 fish or about half the escapement goal.
The above numbers are my harvest estimates and not from an official source.
You guys are doing fantastic work! The website and video presentations are first class! I take my hat off to you. After looking through the website I'm feeling motivated. I love the Chehalis River along with all its tributaries. The Chehalis itself is a real wonder. It's almost ancient and unique as rivers go in this state. Going forward I am going to try and get involved. I will follow your cause and see where I can help. Again, that is an incredible, well thought out site. Your hard work is much appreciated by me and I'm sure everyone else who is in touch with the cause. Thank you!
Excellent resource! Thanks for the hard work!! I know these guys aren't getting paid for this, and really appreciate that people actually DO give a damn
Some good work there! You might think about contacting Sam Wright (retired WDFW biologist) in Olympia about a petition to list "Gray's Harbor" wild chum salmon as threatened under the ESA. That could throw a rock into the Region 6 salmon management plan since they don't have to deal with ESA issues on the coast. Yet. Sam has experience with submitting successful ESA petitions. I might not have thought about this until seeing that WDFW is systematically trying to extirpate chum salmon from the creek I grew up on simply to appease 22 gillnetters.
The entire ESU must be threatened to achieve a listing. And it may well be that the entire ESU is in deep doo doo. Proving it over over such a wide range over three states is another matter altogether.
Here's a thought. The gillnetters are used to protect the tribal fishery. Without the gillnetters you would have one fishery that can and does fish selectively with little mortality to the incidental and non-target stocks. If the tribal fishery were the only "kill 'em all" show going it might be politically harder to portray ones self as conservation minded. So, the non-Indian gillnets provide cover.
I suspect that if the tribes were forced to fish selectively that there would be a myriad of legal challenges such as what is the superior law-ESA or treaties. And, the one that should concern WA the most; how many salmon do we need to ensure the tribes have access to (Boldt II).
Sorry for the lengthy post below, but there is, within the ESA ESU designation a provision for a Distinct Population Segment (DPS) to allow for management of species within a portion of their overall range. A DPS listing can drive management schemes down to a very small level. In theory, if a DPS within an ESU is never "recovered" the application of 4d take restrictions can be continued on ad infinitum. Personally, I would suggest a strong caution for a DPS listing.
The following is copied from the NOAA website on chum:
"NOAA Fisheries has identified 4 evolutionarily significant units (ESUs) of chum salmon in Washington, Oregon and California. Each ESU is treated as a separate species under the Endangered Species Act. Click the links below to get information about a specific ESU, its status, and other relevant information"
The 4 "distinct" ESUs for chum are the coast (Doc's map) and the Puget Sound/Strait of Georgia, both of which are not currently listed. The other two are the Hood Canal summer chum and the Columbia River chum which are both listed as threatened.
http://www.eoearth.org/article/Distinct_Population_Segment_policy_(1996)_under_the_Endangered_Species_Act,_United_States Distinct Population Segment policy (1996) under the Endangered Species Act, United States Published: June 18, 2008, 8:41 pm Updated: June 18, 2008, 8:41 pm Lead Author: Tatjana Rosen Topics: Ecology Environmental Law
This article has been reviewed by the following Topic Editor: Peter Saundry Under the Endangered Species Act ("ESA" or "Act") as originally enacted, the term species was defined to include "any subspecies of fish or wildlife or plants and any other group of fish or wildlife of the same species or smaller taxa in common spatial arrangement that interbreed when mature". In 1978, the Act was amended and the new definition provides that a species includes “any subspecies of fish or wildlife or plants, and any distinct population segment (DPS) of any species of vertebrate fish or wildlife which interbreeds when mature” (ESA, Section 4). (emphasis added) In 1990, the U.S. Fish and Wildlife Service and the National Marine Fisheries Service (NMFS) convened a Vertebrate Population Workshop to develop guidelines for interpreting the DPS language in the ESA. The NMFS memorandum provided that a vertebrate population (or group of populations) will be considered "distinct" for purposes of the ESA if it represents “an evolutionarily significant unit (ESU) of the biological species”. An ESU was defined as a population that (1) is substantially “reproductively isolated” from other populations of the same species and (2) represents an “important component of the evolutionary legacy of the species”. In 1996, U.S. Fish and Wildlife and the NMFS developed a joint policy (1996 Policy) intended to clarify the meaning of Distinct Population Segment (61 Fed. Reg. 4722, Feb. 7, 1996). Three basic principles guided the development of the 1996 Policy: (1) the intent of the framers of the ESA to use it to protect genetic diversity (93rd Congress, 1st session, 1973, H.R. Report 412); (2) the 1979 directive that the government agencies involved list populations “sparingly“; and (3) the stipulation in the ESA (section 4(b)(1)(A)) that listing decisions be based “solely on the basis of the best scientific and commercial data available”. To constitute a DPS, the policy provides a population must exhibit (i) “discreteness” in relation to the remainder of the species and (ii) “significance” to the species to which it belongs. As to "discreteness" the 1996 Policy states that: “A population segment of a vertebrate species may be considered discrete if [either]: 1. It is markedly separated from other populations of the same taxon as a consequence of physical, physiological, ecological, or behavioral factors …. [or] 2. It is delimited by international governmental boundaries within which differences in control of explication, management of habitat, conservation status or regulatory mechanisms exist ….” (1996 Policy) Once discreteness has been established, “the Services will consider available scientific evidence of the discrete population segment’s importance to the taxon to which it belongs.” This “significance” test may be satisfied by: “1. Persistence of the [DPS] in an ecological setting unusual or unique for the taxon. 2. Evidence that loss of the [DPS] would result in a significant gap in the range of a taxon. 3. Evidence that the [DPS] represents the only surviving natural occurrence of a taxon . . . . [and] 4. Evidence that the [DPS] differs markedly from other populations of the species in its genetic characteristics….” (1996 Policy) Further Reading • Rosen T. 2007. The Endangered Species Act and the distinct population segment policy. Ursus, 18(1):109-116 • U.S. Fish and Wildlife Service, Endangered Species Program. 1996 Distinct Population Segment Policy (full text). • Waples R.S. 1991. Pacific salmon, Oncorhynchus spp. and the definition of “species” under the Endangered Species Act. Marine Fisheries Review, 53:11-22 Citation Tatjana Rosen (Lead Author);Peter Saundry (Topic Editor) "Distinct Population Segment policy (1996) under the Endangered Species Act, United States". In: Encyclopedia of Earth. Eds. Cutler J. Cleveland (Washington, D.C.: Environmental Information Coalition, National Council for Science and the Environment). [First published in the Encyclopedia of Earth June 18, 2008; Last revised Date June 18, 2008; Retrieved February 1, 2013 <http://www.eoearth.org/article/Distinct_Population_Segment_policy_(1996)_under_the_Endangered_Species_Act,_United_States>
http://www.fws.gov/pacific/news/grizzly/esafacts.htm LITTLE KNOWN BUT IMPORTANT FEATURES OF THE ENDANGERED SPECIES ACT Distinct Population Segments, 4(d) Rules, and Experimental Populations There are features built into the Endangered Species Act (ESA) and its implementing regulations that give the U.S. Fish and Wildlife Service (USFWS) flexibility in listing, protecting, managing, and recovering species that need the ESA's protections. Distinct Population Segments In addition to the listing and delisting of species and subspecies, the ESA allows the listing/delisting of Distinct Population Segments of vertebrate species (i.e., animals with backbones, mammals, birds, fish, reptiles, and amphibians). A Distinct Population Segment is a portion of a species' or subspecies' population or range. The Distinct Population Segment is described geographically instead of biologically, such as "all members of XYZ that occur north of 40 north latitude." The use of Distinct Population Segments is a benefit to species conservation and a benefit to people whose activities may be affected by the ESA's prohibitions. Conservation efforts are more effective and less costly if they are started early and a Distinct Population Segment listing makes earlier listings possible. By listing a Distinct Population Segment, we apply the ESA's protections only to the deteriorating portion of a species' range. Threats can then be addressed in that specific (and smaller) area instead of waiting until the entire species has declined to the point that listing the entire species throughout its range is necessary. Also, the USFWS uses Distinct Population Segment listings to customize application of the ESA across the range of listed vertebrate species. For listed species with improving populations, we can delist or reclassify (from endangered to threatened) a Distinct Population Segment. By doing this we remove or reduce the ESA's protections from part of the listed species' range (where it is doing well) while keeping full ESA protection for the Distinct Population Segment of that species that has not yet experienced recovery. The USFWS's policy for designating Distinct Population Segments is sometimes called the Vertebrate Population Policy. This policy contains the criteria that must be met for a portion of a species' population to be designated as a Distinct Population Segment. Those criteria include the requirements that a Distinct Population Segment must be discrete and significant. This policy was published in the Federal Register (61 FR 4722-4725; February 7, 1996) and can be found on the Web at http://www.fws.gov/r9endspp/pol005.html . Examples of currently listed Distinct Population Segments: the northern population of the copperbelly water snake the interior population of the least tern the northern population of the bog turtle Section 4(d) Special Rules Section 4(d) of the ESA allows the USFWS to establish special regulations for threatened (not endangered) species, subspecies, and Distinct Population Segments. These "4(d) rules" take the place of the normal protections of the ESA and may either increase or decrease the ESA's normal protections. The ESA specifies that 4(d) rules must be "necessary and advisable to provide for the conservation of such species." One use of 4(d) rules is to relax the normal ESA restrictions to reduce conflicts between people and the protections provided to the threatened species by the ESA. A 4(d) rule can be used in such a situation if those conflicts would adversely affect recovery and if the reduced protection would not slow the species' recovery. This type of 4(d) rule is already in effect for gray wolves. Under authority of a 4(d) rule, Minnesota wolves that have preyed on domestic animals can be trapped and killed by designated government agents. This 4(d) rule was developed to avoid even larger numbers of wolves being killed by private citizens who might otherwise take wolf control into their own hands. (For more details on this example of a section 4(d) special rule, refer to Title 50 Code of Federal Regulations 17.40(d).) Experimental Populations Re-establishing a threatened or endangered species in areas of its former range is often necessary for recovery. However, residents and businesses frequently oppose such reintroductions because they fear the presence of the species will also bring severe restrictions on the use of private and public land in the area. To overcome this serious obstacle to species reintroductions, Congress added the concept of experimental populations to the ESA. Experimental population designations are sometimes referred to as section 10(j) rules. An experimental population is a geographically described group of reintroduced plants or animals that is isolated from other existing populations of the species. Members of the experimental population are considered to be threatened under the ESA, and thus can have special regulations written for them under section 4(d). In addition, if the experimental population is determined to be "nonessential" to the survival of the species, for some activities the experimental population is treated like a species that is proposed for listing as threatened or endangered. In other words, the nonessential experimental population is not given the full protections of the ESA. Among numerous examples of experimental populations are the Colorado pikeminnow, the southern sea otter, the gray wolf, and the black-footed ferret. Summary These three aspects of the ESA all can promote the recovery of declining species by fine-tuning the protections of the ESA. This fine-tuning minimizes adverse impacts on people and society while maximizing the likelihood of eventual recovery and delisting of the species. Thus, humans and rare species both benefit from their careful use. -FWS-
Dec. 21, 2012: home page story, Small research station provides immense value to scientific advancement and marine exploration Pacific salmon and steelhead are salmonids, of the scientific family Salmonidae. They are anadromous fish, which means that they migrate up rivers from the ocean to breed in fresh water. Pacific salmon are in the scientific genus Oncorhynchus, which includes pink, sockeye, chum, Chinook and coho salmon, steelhead and rainbow trout. These fish have a complex life-cycle that spans a variety of fresh and saltwater habitats. Salmon are born in inland streams and rivers, migrate to coastal estuaries, and then disperse into ocean waters to grow. Once mature, they reverse their course, returning through the estuaries, fighting their way back upriver to the very streams where they were born, to reproduce, die and begin the cycle again. In 1991, NOAA Fisheries received a petition to list Pacific Northwest salmon runs under the Endangered Species Act (ESA). In response, the Northwest Fisheries Science Center and the Southwest Fisheries Science Center launched a proactive, systematic review of all West Coast salmon runs. To do this, however, the agency first had to determine how a “species” of salmon was defined under the ESA. The ESA allows listing of “distinct population segments” of vertebrates. NOAA Fisheries, through the scientific leadership and expertise of its science centers, developed a technical document to describe how it will apply this definition in evaluating Pacific salmon stocks for listing under the ESA. A policy (PDF 902KB) was then developed that establishes a group of salmon populations to be a distinct population segment if it is an “evolutionarily significant unit,” or ESU. Scientists established two criteria for ESUs: 1) the population must show substantial reproductive isolation; and 2) there must be an important component of the evolutionary legacy of the species as a whole. From 1994 to 1999, NOAA Fisheries, through biological review teams (BRTs) convened by its science centers, reviewed the ESA status of all anadromous salmon species on the West Coast. (BRTs are groups of federal agency scientists with expertise in the species being reviewed. They solicit and review all pertinent data and assess risks to the viability of the species.) During these reviews the BRTs identified 52 ESUs, and evaluated whether they were at risk of extinction and should be considered for listing as threatened or endangered under the ESA. The final BRT reports provided a solid scientific foundation for NOAA Fisheries to make ESA listing determinations. Before beginning the coast-wide status review, the agency had listed two salmon populations in the Snake River basin and one in California's Sacramento River. Following the reviews, NOAA Fisheries had listed a total of 26 salmon and steelhead populations; five as endangered and 21 as threatened. In 2005 the agency completed a periodic review and update of the status of the 26 ESA-listed populations. The agency later listed Oregon coast coho and Puget Sound steelhead as threatened, for a total of 28 populations. NOAA Fisheries' Northwest Region issued the results of another periodic review of listed salmon and steelhead in August 2011. The agency made no changes to the ESA status of any populations.
NOAA Fisheries has identified 4 evolutionarily significant units (ESUs) of chum salmon in Washington, Oregon and California. Each ESU is treated as a separate species under the Endangered Species Act. Click the links below to get information about a specific ESU, its status, and other relevant information. ESU ESA Listing Status ESA Critical Habitat Hood Canal Summer-run Threatened 6/28/05 (70FR37160) Designated 9/2/05 (70FR52630) Columbia River Threatened 6/28/05 (70FR37160) Designated 9/2/05 (70FR52630) Puget Sound/Strait of Georgia Not Warranted NA Pacific Coast Not Warranted NA ESU Maps Federal Register Notices
As a newby to the GH Advisory group a couple of things came out that are worth mentioning. First is the information distributed and the notes can ( and will ) be made public. A shift but not a 8.0 shaker.
Now this is. Staff outlined the public meetings requirements of the different advisory groups and those that applied to the GH Advisory Group. The members of the public have the right to attend GH Advisory Group meetings and observe, key word observe. The public can NOT participate in the processes or discussions just OBSERVE. If anyone has a desire to set in and observe by all means do so as it is a public process concerning a public resource. All that said I would urge you to give Region 6 staff the courtesy of letting them know in advance you are going to attend to insure the facilities utilized can accommodate everyone.
Ah ................... you know I do not know for sure. Off hand I would say no, as my thoughts only. I can not see how that would work as Ron Warren was very clear non advisory board ( observers ) could not participate or have input in the discussions. Now the Montesano meeting for the general public input and meeting in Olympia to finalize the NOF for Grays Harbor are open to public participation.
Depending on the meeting, there can be provisions for public comments and they are usually at the end of a meeting. Depends on the what the committee chair or meeting facilitator decide.
Here is a link to the WDFW "Operating Protocols and Guidelines for Advisory Groups". Depending on the group, a chair may be elected and the group then sets its agenda.
The WDFW staff coordinator "....will assist each advisory group in understanding whether the OMPA applies as a matter of law. Nevertheless, the Department encourages...advisory groups...to conduct their business in an open, transparent manner, consistent with the intent of the act."
The NOF schedule for GH NOF and Willapa NOF is up on the FTC home page. It also has the NOF WDF&W Team Meetings, PFMC, and WDF&W Tribal meetings in it so read carefully to not mix dates up.
I was asked to identify what information in the Fishing The Chehalis library would be the simplest and best to get a quick read to understand the NOF data. The information exist primarily in a usable form in Excel spread sheets, Preseason and FRAM. While the FRAM maps out the harvest it also has a substantial amount of other information in the pages. You would want the Preseason Forecast spreadsheets that are separate for each of the three salmon species and are a wealth of historical information. Oh yeah almost forgot you want the 2012 sheets.
That was the easy part! If you want to view them go to the Library / WDF&W PDR Responses / PDR Responses Sorted and they are listed. To be honest folks you will still wander around a bit trying to find the year and sheets you want and then down load it. The simplest way is to send a request to me and I will find it for you.
Also the spread sheets when viewed in the library are separated into the many pages of the Excel sheets as that simply is the way the data base is viewed. If you down load them they are intact but some have trouble with them as they xlsx sheets which are compressed Excel.
About had enough of that bit? Don't blame you as breaking out all the information in the PDR was a real pain. So as I said contact me and I will get it to you in a useable form!
I have not viewed all the videos, but what I saw was disappointing, disturbing, and depressing. Truly unbelievable. I realize FishDoc, RiverGuy, Carcassman, SuperFly, and others have been concerned about this for decades, but it's startling to see it firsthand. Thanks to all who put this website together, and the folks who continue to fight the good fight.
However, I see a close link between this issue and the current issue of revamping the F/W Commission (HB1189). Whenever the commercial folks don't get their way, they run to their representatives to trot out a proposal to rig the Commission or dismantle it entirely. These bills don't usually get very far, but they still serve their purpose - which is to intimidate the F/W Commissioners. A shot across their bow. Send a message that the commercial folks are politically powerful, and that unless the Commissioners "get in line", the intimidation will continue.
It's clear the commercial folks have a great situation on GH and the Chehalis (but not so great for the fish nor the recreational anglers). The Commission knows this; so their instructions to WDFW leadership are likely very clear - "Do whatever you need to do to maintain viable commercial fishing on GH". That might include rigging the computer models, using phony numbers in the spreadsheets, back-calculating the survival estimates needed to justify the commercial fishery, ignoring the actual escapement levels, and developing PR stunts like survival boxes and "selective fishery" methods without actually requiring their use.
Ideally, more and better transparency through videos and public engagement will turn things around. The website is a terrific start.
Sorry for the rant, but this situation is disturbing.
The latest video is up on FTC addressing the national history and events that preceded the federal courts intervention in Washington States salmon harvest. Known to most as simply Boldt, it is the defining decision regarding salmon harvest in the Pacific Northwest and Native American treaty rights.
Here is a link to the GH Management Plan and the Tiered Harvest Plan. Both are labeled Draft, never had public review, never had scientific review, and have not been formally adopted by the commission. These are the foundation and implementation vehicle utilized by WDF&W for that ugly thing they called the 2012 season. I might add even some of the supporters of the plan were ( find polite words ) ............ were horrified to see.
I was asked to explain how is information presented to the public for NOF and how it is used. It is primarily in a Power Point presentation that boils down a rather large amount of data into something that is easily viewed. Link below for 2012 Montesano meeting.
Is anything set in stone at this point? No, yes, and maybe. The Harvestable numbers yes, seasons no, who gets what % of the available fish maybe, as by this time WDF&W staff pretty much know what the final harvest picture will look like. The harvestable numbers are put into the tier plan and it dictates some basic things happen. Link below for 2012 Tier Plan.
To the question is it a waste of time to attend? Not no but hell no. It is a dog and pony show to be sure but WDF&W records your input FOR THE RECORD. In 2012 only 5 written proposals for the inriver sport season were submitted, so it is of real value for citizens to demand the restoration of the inland communities traditional sport fishing opportunities at the public meeting. In addition you can set in ( but not participate ) in the Grays Harbor and Willapa Advisory Group meetings, which I think many of you would find to be a real eye opener. Otherwise you get 2012 a season with the vast majority of the harvestable fish removed by the 101 Bridge in Aberdeen. Or to put it another way you get to take multiple walks to the river or boat rides enjoying nature and friends, and not catching many fish. Schedule link below.
Now then it is time for the rest of the story. The Grays Harbor Management Plan ONLY applies to the non treaty sport & commercial. The Quinault Tribal ( QIN ) commercial fisheries operate under a totally different set of rules that are never presented to the public as to negotiated harvest impacts. Are negotiated after the Non Treaty ( state ) harvest plan has been presented to the public. Then the final bit of deception is that the final harvest plan agreed to by the state and QIN is never made public, impacts clearly defined, or the rational utilized in the finalization of the combined harvest plan explained.
Here is a link to FTC Dave's Rants. In it you will find my thoughts on the NOF Chinook harvest of paper fish. If you don't want read the whole thing hit the link to the 2012 Chinook Impacts. The FRAM 2012 spread sheet data was utilized to produce the numbers of PROJECTED PAPER CHINOOK to be harvested. Just as a teaser how many know that WDF&W agreed to allow the QIN to harvest 18% of the escapement goal or 2426 Chinook. If your blood pressure is rising remember WDF&W AGREED to allow this.
Wee Edit: I was asked why not a direct post here? In multi sheet Excel and other documents you loose the formatting plus a bunch of other things when pasted in on PP. It is simply easier with a issue that has a lot of research time involved and multiple links in it to link to FTC work. If it is just one document, or something similar, I usually just write up on PP. It is all about the work required.
Yes, its a tragedy that the supposed "CO"managers do not cooperatively manage out of the same playbook. Without mutually agreed-upon objectives, the resource is ultimately made to suffer.
QIN does NOT acknowledge/accept that GH chinook stocks should be segregated as separate Hump stock and Chehalis stock.... simply that they are an aggregate GH chinook stock. Nor do they acknowledge/accept that weak stocks with no harvestable surplus should be managed with a 10% impact cap. These are the most basic conservation-minded principles built into the GH Advisory's vision of a responsibly-managed salmon fishery in Gray Harbor.
The Tier Plan directs the state fishery be managed by the lesser of 1) half the harvestable surplus of the WEAKEST harvestable stock or 2) half the allowable impact (5%) on the NON-harvestable stock(s).
In contrast, the QIN basically targets half of the STRONGEST harvestable stock, all other stocks be damned. In 2012, they fully asserted their guaranteed treaty right to take half the harvestable surplus of an abundant Tier 4 coho run-size, irrespective of casualties to chinook and chum.
This is the very reason they were so willing to fish Chehalis kings more than 2400 fish into escapement.
The way the co-managers spend paper fish is like a financially dysfunctional couple sharing the same checking account. Without a mutually accepted budget plan, one spouse's irresponsible spending can't be kept in check by the other..... and the account is chronically overdrawn.
Talked to an oldtimer on the Satsop for several hours that must know you a bit, gave me several flyers and cards for the site. Mentioned the site and provide flyers to our RMEF chapter and regional, posted a flyer at TSC and Cabelas, handed out a few cards on the river. It's not much I guess, but doing what I can to help you.
Suppose some might wonder, what difference does this make to a conservation group like the RMEF, but imho it has the potential to impact everything the WDFW manages.
Great thread. I definitely appreciate learning more about the GH area fishery facts.
Doc, or others, do you know of any calendar for WDFW to address any Chehalis or Hump or other GH issues where it would be useful for people to show up?
The link is to the WDF&W NOF calendar for 2013. The Montesano & Olympia meetings for Grays Harbor ( Humptulips, Chehalis, & The Harbor itself ) are open to public participation. While not generaly known the Grays Harbor Advisory Board Meetings ( also Willapa ) are also open to the public BUT only to observe the proceedings not to participate in the discussions.
I did not catch that the high lighting had changed as it is the way R-6 provided it, sorry about that and we will try to do better in the future. The meetings for the GH Advisory Group on February 28th, March 6th, and March 20th identified as Montesano are at the Region 6 offices. Remember the public can only observe not participate in the discussions.
The meeting March 14th is Montesano City Hall for public participation & input as is the March 29th meeting which is at the Natural Resources Building in Olympia as shown. The March 29th meeting is about who catches what / when.
Thank you for what you bring. I suggest that if you can list 2 or 3 talking points then maybe some folks on this list (like me) could show up for that Mar. 14 meeting and offer supporting comments. Even a simple, "I support identifying separate returning runs," or however that could be better phrased, can be useful. Numbers count! Rivrguy or Francis, can you help us frame the message?
I work until about 4:30 but will plan on coming down to support you and Francis and our fish friends.
Folks, it is very easy to drive to a meeting and be present; just be there to be present. One of the things that is happening is that these local issues, like GH, are coming up on state and regional radar. Rivrguy and Doc Eyefish have worked long and hard on this and they set the tone for how we can help.
What do we want Region 6 to hear? How's this for starters...
1) Let's be intellectually honest about our harvest models. They've been low-balling the true fishing power of the fleets, both rec and commercial, particularly for chinook. At low abundance returns, the rec fleet has a priority allocation. By being honest about how many fish it really takes to fuel the rec fishery, it leaves us with a more realistic figure of how many fish are actually available to fuel any gillnet days.
2) Let's be intellectually honest about the mixing of stocks in the marine area. The model counts nearly 1/2 the kings in the bay as Humptulips stock, effectively diluting the true impact on Chehalis stock. On paper this permits many more fishing days to be added to the season.
3) Let's be intellectually honest about chum. The other species of fall salmon are segregated into Hump stock and Chehalis stock. Why are chums treated with a double standard? Because lumping them together in aggregate allows more fishing days to occur.
Bottom line, let's stop spending phantom fish that don't exist. While it all may work out on paper, there is no buffer to protect against models that don't pan out in real life. The escapement shortfalls are no where to be seen on paper in the final NOF documents, but year after year, they are certainly evident on the gravel.
Not to bad as a starting point on the conservation side Francis. I will add that we get the preseason forecast at the Advisory Group meeting the 28th, then one can begin to look at what is or is not possible for harvest for 2013. I replied to your PM DR just a little running behind on the e-mail thing.
Little edit: The one thing I can say with certainty that will happen this year is everything that happens in the Grays Harbor NOF and the allocation process will be made public. No exceptions.
Management results from last year can only be considered tragic. Tragic from the standpoint of the destruction of the Chehalis Chinook run and tragic from the standpoint of missed recreational opportunity for Chum.
From my perspective there are four key failure areas:
1. Disfunctional co-management with two different harvest plans for one resource. (Probably not much we can do about it at NOF.)
2. A NOF plan that starts with an imprecise run size estimate and and plans to kill every last theoretically available fish. (The term imprecise is a ephemism for a WAG.)
3. No in-season adjustments are ever intended regardless of new information about actual run size.
4. The harvest model that was used to kill the last theoretical fish had so many arithemetic errors that it was not capable of predicting actual harvest.
Out of this list I think we could make the best improvement by starting with a conservative view of the run size and then making in-season adjustments if the run actually materalizes. I am coming from a perspective that recovery of weak Chinook runs is a desirable result.
I vote to ask that the NT commercial days be spread out evenly across the season. I'd much rather, as primarily an upstream participant, have three or four days per week with nets in the water over the entire season than lose three entire weeks of prime time opportunity, as we did last October. That way, we can fish the tidewater when the nets are out and fish up higher when they go in. Gives us a legit chance to hook up almost every day. Seems to me this scenario would also ensure that at least some of the wild kings will have a chance to get upstream each week.
Granted, if the weather had cooperated last September, we would have had a great time for those 2-3 weeks, but I've decided that counting on Mother Nature is a recipe for disappointment more often than not.
I also would favor more restrictive seasons that could be adjusted as the runs materialize, including no retention of Chinook outside the Humptulips before Chehalis escapements are either met or imminent.
Lost the forematting on this, it is fine in the preveiw but toast here but you should be able to pick out the numbers. Gzzzzzzzzzz So here are the Chehalis and Humptulips Preseason Forecast numbers. Coho is way up there, Chinook not so and the Chum numbers are combined for the Harbor. More later as I have asked for the preseason forecast Excel spread sheets.
2013 GRAYS HARBOR PRE-SEASON FORECASTS SUMMARY
Spring Chinook Forecast 2247 Goal 1400 Harvestable 847
If memory serves, that's a lot more chum than they forecasted last year. Probably at least another couple days of NT gillnetting and double for QIN. With chinook and chum in the mix, this could get ugly.... Hoping for a positive outcome, and I will be at the Montesano and Olympia meetings again this year.
I am in this for one reason, to break the continuing institutionalized discrimination of WDF&W toward the inland communities and inriver sports fisher. Hopefully in the process help the fish.
Just to give folks an idea of how bad the upriver guy got screwed on the Chehalis, just look at the creel counts from Cosi, Monte, and Fuller....
Cosi - 9 days creeled averaging 1 king and 13 coho for 16 boats per day.... thats about 0.06 kings per boat and 0.81 coho per boat.
Monte - 11 days creeled averaging 0.91 king and 16.5 coho for 32 boats per day.... that's about 0.03 king per boat and 0.52 coho per boat
Fuller - ONE glory day creeled (so take it for what it's worth)... 3 kings and 89 coho for 46 boats. That's about 0.06 king per boat and 1.9 coho per boat.
Let's just say the bay guys did a "little" better.
I still wonder about the non reported catch that is sold directly off the gillnet boats right in Aberdeen at the Walmart parking lot and at the mouth of the Wishkah, and near Weyerhauser in Cosmopolis.
Been there, done that........QIN fishermen, can take home X amount of fish, the individual fishermen can now "sell out of the net" but, as I understand it, the sales numbers are reported to the tribe.
Click on the address below, page 2 talks about "sales"
So, what is our strongest argument at these meetings to convince the co-managers to avoid another "curtain of death" netting in October. Last year was over-the-top ridiculous and as bad as I've seen in all the years I've lived here.
Chinook aside, with the numbers presented, there's going to be substantial netting again. I've seen nor heard anything from the dept. that convinces me they will shift to a more rec-friendly management scheme and, frankly, don't expect they will short of a court order. So let's just assume there's going to be a lot of netting.
What I see as critical to better upstream opportunity is to break up the net schedule....say max of 4 days a week during peak run timing, both tribal and non-tribal. You've GOT to have more than 1 day a week net-free to let something swim upstream. So how do we get that? Is the lower Chehalis chinook forecast(tier 2) going to achieve that with all those coho and chum swimming around out there?
I realize reduced netting per week on high harvestable numbers will disperse the net schedule out over a longer time but what's worse? That or another October wall of death like last year?
I wish we could get the QIN to participate in the NOF process. Even if their schedule is whatever they want to make it, knowing it in advance would give us an idea of their planned impact throughout the season, and it would allow us an opportunity to negotiate over which days the NT gillnetters will fish so that we don't lose entire weeks to nets.
You may say I'm a dreamer, but I'm not the only one....
When you look at 2012 it is easy enough to see the in river fishery got screwed big time as did the the fish. The co-managers targeted the Coho harvest on the front 40% of the run which just plain wrong. Disregarded the Chum populations above Fuller Hill and continued to destroy the upper Chehalis Chum stocks by targeting the higher producing hatchery supported lower river stocks. Agreed to allow the QIN to harvest 18% into Chinook escapement, then the fish did not show so massive over harvest.
2012 in the Chehalis Basin violated about every rule in the book for conservation driven harvest allocation. It was about sacrificing Chinook & Chum stocks & the in river sport to drive commercial fisheries on abundant Coho. Somebody want to tell me again how great of a job Mr. Anderson is doing?
To anyone reading this, Have you been interested in how these Wonderfully Wacky Washington fisheries work? Have you wanted to learn more? Have you wondered if your participation matter? Have you wanted to attend a democratic process in action? Or maybe to participate in one?
If you can answer "Yes" to any of the above then here is a great opportunity. Here is a great place to jump in without drowning.
March 29, Fri: WDFW Willapa Bay and Gray's Harbor Fisheries Final Planning Olympia Olympia Room 172 9 am to 4 pm http://wdfw.wa.gov/fishing/northfalcon/ scroll down in the link
For background, go to the OP's site, fishingthechehalis.net site and drive around. View the vids, they are great.
EyeDoc, Rivrguy, and Flicker of Fleas, and others are working hard in this fishery, and they have proven that they love to share that with the rest of us. So, let's show up and support them.
What do we want Region 6 to hear? How's this for starters...
2) Let's be intellectually honest about the mixing of stocks in the marine area. The model counts nearly 1/2 the kings in the bay as Humptulips stock, effectively diluting the true impact on Chehalis stock. On paper this permits many more fishing days to be added to the season.
Bottom line, let's stop spending phantom fish that don't exist. While it all may work out on paper, there is no buffer to protect against models that don't pan out in real life. The escapement shortfalls are no where to be seen on paper in the final NOF documents, but year after year, they are certainly evident on the gravel.
I believe we've obtained the proverbial smoking gun regarding this problem.... ho'boy, and how!
Gonna make sure this gets counted right in the 2013 harvest model
All very preliminary at this time but this should give you some reasonable expectations.
Chehalis: Should look a lot like last year but even more generous for wild coho... OODLE's of them to be caught... expectations are 4W:1H Tier plan ensures a rec fishery for kings, but smaller than last year Some of you will even get to keep some chums.
Hump: Should look identical to last year except that chum will be bonkable.
The first Advisory meeting was " hi how are you " and the second was throw ideas as to seasons in the hat plus some issues. Will add moving the Chehalis opening two weeks forward was put in the mix. The commercial seasons the NT nets put forward was more or less like last year on steroids.
Folks in all honesty I ( or Francis ) could put a lot more feathers on this bird but it would mean little. I will add this, on the issue of the inriver sport getting paper fish and then corked off by the nets was brought forward. Additionally the fact that many traditional fisheries ( such as the late summer Chehalis jacks and tributary Chum ) had been sacrificed in past years and that had to stop was also brought forward. Oh and one more thing, the issue of the mainstem Chehalis commercial fishery on Chum chronically over harvesting mid and upper Chehalis tributaries Chum was discussed.
As a proponent of the public's right to know even I am hesitant to say much more as this was simply the advisers pushing forward broad proposals but will add that two gentlemen from East County attended and observed the meeting with out the sky falling. So it is NOF at Montesano March 14th up next and folks need to attend and push for the sports fisheries. ALL sport fisheries not just your pet. So you do not fish the bay or do not fish tide water or do not fish Chum, well the list is as diverse as the sport fisheries are but what we all must argue for is a complete restoration of all the traditional sport fisheries on harvest of all three spices of salmon. After that as public input is brought into the process with options then wide open discussion time.
Been there, done that........QIN fishermen, can take home X amount of fish, the individual fishermen can now "sell out of the net" but, as I understand it, the sales numbers are reported to the tribe.
Click on the address below, page 2 talks about "sales"
Nice write up of FISHINGTHECHEHALIS.NET in the current The Reel News.
Regarding Gray's Harbor, escapement goals seems to be the hinge issue across all the species' fisheries. Honesty and transparency in escapement goals. Doc and Dave, do you agree?
FWIW, I finally watched the rest of the tutorial videos, and "Where did all the Salmon Go" is my favorite of the whole series. The "Boldt Decision" is a close second.
I will be driving from Seattle to the Montesano City Hall meeting and can stop and pick up and deliver folks along the way. PM me.
DR I would say the failure to make escapement goals is a primary issue but it is stock specific not so much as the Basin as a whole. Now that said what we have is a harvest driven problem plain and simple. In the effort to kill every paper fish possible, WDF&W ( and the QIN ) are willing to sacrifice the weaker stocks. It is that simple. It is not that the vast majority of the streams can not make escapement but rather they can not sustain the commercial harvest levels applied.
As to transparency, what transparency? I would like to point out last years NOF with no this / no that then WDF&W agrees to allow the QIN to take 18% of the Chinook escapement and never made it public. In fact if it had not been for Softbite's effort it may not have ever been made public. Transparency is a WDF&W policy? Nope but if you believe that transparency is WDF&W's policy in the Chehalis Basin I have a bridge I want to sell you.
Just so you don't think that the Basin is being picked on for a lack of transparency, check out the thread on the recent adoption of sport regs and the open, clear, above board, etc. cabezon regs.
As long as folks stay in their own little worlds (watersheds. fisheries, etc.) this stuff will continue to happen.
Jim " Tug " Tuggle did an great article for Reel News on the FTC website. Any and all help is greatly appreciated as we continue down the road of letting the public understand how the Chehalis Basin salmon harvest is managed by WDF&W. Link below to the article.
One last heads up to the NOF public input meeting at Montesano City Hall 6 to 8 this Thursday the 14th. It is your chance to let the agency know your thoughts on the 2013 seasons be it good, bad, or ugly!
Well it was a interesting meeting in Montesano to say the least. Still digesting the process a bit but somethings jumped at me. That said I am just going to do a link to FTC because frankly this is Bob's BB and I do not feel comfortable using it as a platform to express my personal views. Will add this bit though, twice WDF&W's Kirt Hughes put forth the assertion that available Chinook for harvest would likely be used in the gillnets mortality harvesting Coho. Not buyin that Turkey for minute and that had to be the most outrageous thought put forward by WDF&W
Last year I went to the Willapa Bay NOF and I heard the words fair and equitable mentioned a couple of times. I never expected to hear those words considering the net seasons down there. Did anyone hear that this year? I fish a couple of days early October out by the Hoquiam airport. It looks like the river is going to be barren unless things change dramatically. Did WDFW say the commercials get to keep the kings they catch fishing for coho or are they going to do the sling? If they are going to hit the Chinook harvest in their coho catch does that mean there will be no king season for sports? I wanted to attend the Montesano meeting but I got the flu and thought I shouldn't give it to all of you therefore the questions. Thanks
The battle is not done......If you have some recommendations, crank up the email ability of your computer, send to WDFW, what you'd like to have for a fishery in Region 6.
If you are a "in-river" fisherman, NOW, is the time to let your WANTS be heard......In-river fishermen definition...ABOVE 101 bridge, Chehalis, Wishkah, Wynoochee, Satsop!!!! This could be the year, to get our CHANCE, for the fair share, that is taken from us!!!!!!!
What Kirt said was the harvestable Chinook would likely be used up in mortality release http://fishingthechehalis.net/chehalis-fling in the NT Nets but it is likely the NT Nets would retain marked Chinook. He did not say that no in river or bay Chinook directly but it would suggest that or into the 5% of escapement that the Non Treaty is allowed and a drastically reduced targeted sport Chinook sport fishery.
We are at round two of a ten round brawl. It is not give up time but rather dig in and fight like hell time.
So what is the prognosis for a chinook fishery in the bay? That's the one I want! Missed it last year cause it was too short and conflicted with archery season. So I haven't been able to fish chinook in the bay for years.
As a member of the Grays Harbor Advisory Group and out of respect for the other advisers participating the best I can say is this. There is not a consensus on seasons or days or species for any of the three user groups. The three are Fresh Water Sport, Marine Sport or Non Treaty Commercial and we meet again the 28th. The silence that is deafening comes from the courtesy one offers others participating in a stake holder process where different priorities and views leave the issue unresolved.
As a "sitter on the side", at the Advisory Group meeting, 3/22/2013.
Sitter.....Not allow to speak!!!!!
Observation---- Dog and Pony Show in Region 6 is alive and well
If you don't know what a Dog and Pony show is......the following is a good definition of what I see happening !!!!!
"Dog and pony show" is a colloquial term which has come to mean a highly promoted, often over-staged performance, presentation, or event designed to sway or convince opinion for political, or less often, commercial ends. Typically, the term is used in a pejorative sense to connote disdain, jocular lack of appreciation, or distrust of the message being presented or the efforts undertaken to present it.
So what is the prognosis for a chinook fishery in the bay? That's the one I want! Missed it last year cause it was too short and conflicted with archery season. So I haven't been able to fish chinook in the bay for years.
As f4b posted, count on 2012-minus.
If we could just get GN's in the same "2012-minus" frame of mind, we'll be able to move this thing forward.
Left the GH discussion at NOF more dejected than anyone can imagine.
Despite all our objections, the NT gillnetters sailed outta the meeting with 14, yes that's FOURTEEN, days of netting in 2A/2D.
Paper fish created out of thin air. Imagine delaminating a three ply roll of Charmin toilet tissue.... suddenly one square becomes three! How is that possible, you ask?
Tangle nets!
Instantaneously, a 45% paper release mortality was transformed into a paltry 14.7% release mortality.... effectively fueling more than three times the gill netting than previous harvest models!
This year I thought that recreational fishers had won the lottery. A Tier 2 Chehalis Chinook fishery should provide enough fish for a limited direct recreational fishery. The commercials would be left with impacts so long as they did not restrict the recreational fishery. Because any gill net impact mortality would reduce the recreational fishery it looked like Tier 2 would dictate no commercial net days in September or October.
WDFW claimed that Tier 2 only dicates recreational start dates and does not define what a limited direct fishery is. Obviously they think it should be limited enough to fuel a significant commercial fishery in 2A/2D.
WDFW sprung a new plan on the meeting that includes a first time use of tangle nets with a 14.7% release mortality and about three times as much netting opportunity. We did not even talk about 2C net days or impacts on Humptulips fish. When they imposed the tangle net plan at least they did not ask for consensus like in past years. Most of the sport group in attendance seemed shell shocked about the outcome.
There is a lot of smoke and mirrors to give the NT nets more days on the water at the expense of the sport fishermen. I don't see how RW can stand there in front of everyone and say some of the things he does. You can roll the same turd in sugar over and over, it will never taste good.
The management objective for Chehalis chinook is to meet the escapement goal, only 3 out of 15 years has this happened, and based on what I've seen the last 3 or 4 years I would guess it was pure luck. How long does it take for the manager to be held accountable? Total failure.
Didn't stick around for the discussions about regulations... we could run 6 barbed hooks in front of lead and not catch fish upriver this fall.
f4b: It'll be 3 for 16 after this season. My sense is that Ron and Kurt are the Agrncy's fall guys, and they don't have anything to say about what seasons are set; it's a foregone conclusion each year, and Phil Anderson makes the calls. The commercial bias is really shining through now, though. Sarcastic remarks like (paraphrasing) "What do you want me to do - jump in the river and put a salmon on a hook for you?" are starting to wear thin. "I AM the Department of fisheries" (a direct quote) was a good one, too.
Wonder how many days the QIN will take after they see that schedule? I'll be surprised if we don't see somebody's nets in the water 6 out of 7 days a week from October on. This may be the year I can take my mind off salmon and spend some serious time fishing late summer runs....
Interesting thoughts so far and I want to think a bit before I jump in with both feet but I will say this. Meet Phil Anderson, the real Phil Anderson! No more he helps with conservation, looks after the sport fisher, just what WDF&W is under his direction. http://fishingthechehalis.net/wdfws-historical-bias
After thinking things over in general I took some time to put my thoughts down on FTC. ( link below ) It is a fast run by of events but I think it captures what happened be good, bad or ugly. I think I will go with bad leaning toward a real ugly!
RW, KH, and Phil Anderson cooked the books.........The bias for the commercial NT fishery, reared its ugly head again.......Region 6, Management team needs to be "replaced with a new team"......Phil Anderson, shame on you...wonder what % of sports money goes to pay your salary?????? You sure don't earn it......
I wonder what Ron Warren told the director when he went up to his office? You think he accurately conveyed the sports' opposition? Don't think so. He seemed to already have his mind made up before it started. An observation I made is that RW is very unprofessional in the way he conducts the meetings.
Scroll to page 59 to read the discussion about finding NO difference in post-release survival of fall chinook from tangle vs gill nets.
It goes on to point out the SHARP contrast with results found in the CR on spring chinook.
Using the CR results for tangle nets and applying them to GH is TOTALLY inappropriate.
Agreed. Apparently, the "best available science" is that which helps WDFW Region 6 make its bogus case for yet another commercial screw job.
I wonder what the mythical "96%" of citizens the gillnetters so nobly serve would react to learning that the few thousand extra coho available in markets this fall as a result of these irresponsible fisheries came at the expense of all but an entire run of wild chinook.
Would anybody out there care to argue that hatcheries or habitat will be the ultimate cause of the extinction of the Chehalis Basin's chinook and chum?
I have never seen much of a difference between gill nets and tangle nets in actual practice. Both snag fish and then they drown. Any potential improvement in survival is based on ideas of short soak times and recovery boxes, both useful in theory but not actually a factor in the fisheries.
From a netter's perspective, there are just too many things to keep track of and to do in the middle of a busy fishery. Thus, a fish fling happens. Any fish that survives the first experience will most likely encounter another net in short order. And so it goes.
We are kidding ourselves if we think tangle nets are the answer. We have to move from non selective harvest methods to selective ones.
Edit: This e mail thread is from the FTC library and is intended to show the internal WDF&W conversations but not endorse anything but rather further the discussion. The last post by Kirt is informative just as to how they came to the 45% mortality on normal gillnets and what was utilized to arrive at it.
Kirt Hughes response is the last post in the e mail chain on net mortality.
For NT GN fisheries in WB and GH we are using 45%. The Nisqually used 50% last year and will end up near that for 2012. The 45% is a fairly long standing value that Flint identified based on the work Vanderhagen did on the Columbia. Ashbrook was involved in some of that stuff at the end.
From: Thiesfeld, Steven L (DFW) Sent: Wednesday, February 01, 2012 11:04 AM To: Barkdull, Brett C (DFW) Cc: Phillips, Larry C (DFW); Hughes, Kirt M (DFW) Subject: RE: Tangle net survival estimates
Hi Brett,
I'm not aware of any NOF wide agreed-to mortality rates for tangle nets. There was some work done about 10 years ago with tangle nets in Area 10 with the Suquamish Tribe, and I think there was something for the Nisqually fishery, and there must be some agreement on mortality rates for gill net release in Grays Harbor. So it might be worth while checking with Jay Zischke, Larry Phillips, and/or Kirt Hughes to see what was used for modeling in those areas. Cheers
From: Ashbrook, Charmane E (DFW) Sent: Wednesday, February 01, 2012 9:05 AM To: Barkdull, Brett C (DFW) Cc: Thiesfeld, Steven L (DFW) Subject: RE: Tangle net survival estimates
Yep, I’m sure you’ve seen those estimates. They are for spring Chinook released from tangle nets in the Columbia River just above the estuary. The caveats include: cold water, spring Chinook, freshwater. These are important because we were unable to make post-release survival estimates for fall Chinook and coho captured and released from Willapa Bay but the fish were in significantly worse condition at capture, and this indicates to me they did not survive as well. In the Willapa, the water was warmer, and the fish were in the midst of physiologic transformation in the estuary. All that said, I think the estimate for you to use is the one that has been informed by my work and then gone through policy consideration –Steve Thiesfeld has a list with mortality values that are assigned so I’ve cc-ed him. Stevo, will you send Brett your list? If Steve doesn’t have tangle net info, then the post-release survival estimate based on my groups’ work is 86.2%. I attach the BPA report with this info and more provided. The table with post-release survival estimates and their confidence intervals is on p. 1-21. Also, in the appendix on p. 1-64, you’ll find a summary of the Willapa results. Cheers! Charmane
From: Barkdull, Brett C (DFW) Sent: Tuesday, January 31, 2012 5:29 PM To: Ashbrook, Charmane E (DFW) Subject: RE: Sport Rules: Latest WAC changes and Trout Pamphlet Day
Hey, got an unrelated question for ya’ since you are the tangle net queen! LOL!
Somewhere, I have seen your estimates of tangle net mortalities on Chinook released. At least I think I have. I’m drawing a blank where to get those numbers. Got the paper you wrote handy or link or???? I’m lazy, and getting tired. Thanks, getting ready to do battle with Lummi!
From: Ashbrook, Charmane E (DFW) Sent: Tuesday, January 31, 2012 11:28 AM To: Bosworth, Aaron (DFW); Whitney, Jennifer L (DFW); Barkdull, Brett C (DFW) Cc: Hoffmann, Annette (DFW) Subject: FW: Sport Rules: Latest WAC changes and Trout Pamphlet Day
Here you go, Region 4 District Bios!
From: Hoffmann, Annette (DFW) Sent: Tuesday, January 31, 2012 11:25 AM To: Ashbrook, Charmane E (DFW); Frazier, Patrick A (DFW); Whalen, John T (DFW); Easterbrooks, John A (DFW); Warren, Ron R (DFW); Hughes, Kirt M (DFW); Korth, Jeff (DFW) Cc: Long, John A (DFW); Bramwell, David R (DFW) Subject: RE: Sport Rules: Latest WAC changes and Trout Pamphlet Day
You will want to sent the doodle pool to the Region 4 District Bio’s who know their rivers to look at these WAC’s. So, please include them in these emails (Aaron Bosworth, Jenni Whitney, Brett Barkdull).
From: Ashbrook, Charmane E (DFW) Sent: Tuesday, January 31, 2012 10:59 AM To: Frazier, Patrick A (DFW); Whalen, John T (DFW); Easterbrooks, John A (DFW); Hoffmann, Annette (DFW); Warren, Ron R (DFW); Hughes, Kirt M (DFW); Korth, Jeff (DFW) Cc: Long, John A (DFW); Bramwell, David R (DFW) Subject: Sport Rules: Latest WAC changes and Trout Pamphlet Day
Hi Everyone, Here is the document that will be given to the Commission for this weekend’s rule adoption. I expect the Commission may have a few tweaks before it is filed as the CR103. At next Monday’s meeting and in a follow up email, I will update you regarding any changes.
Regarding the trout pamphlet day –please decide which of your staff will attend and have them fill out the Doodle Poll (http://www.doodle.com/md3htu9n7umf37eb) by this Friday. I’ll plan to announce the day of the meeting at next Monday’s meeting and send a follow up email that includes the date and who will be attending by region. Or, if none of the dates on the Doodle Poll work, please let me know what weekends work and I’ll follow up on Monday with a weekend plan.
The objectives for this meeting are 1) to get all the gamefish rules in the pamphlet; 2) to improve the pamphlet and pamphlet process; and 3) to have all gamefish rules in the pamphlet before the NOF pamphlet weekend. Please know that I have heard from many people, including regional staff, that this meeting is much needed. We are going to try and improve efficiency by making changes in “real time” with meeting rules that include 1) focus on content and not format until the end and 2) where there are disputes, one person will be the lead for determining and instructing Dave about the change. Dave plans to send the pamphlet draft in mid-February to help provide everyone prep time.
Thank you for all your help, Charmane
Charmane Ashbrook ESA Response, Scientific Collection Permits and Sport Rules Unit Leader Washington Department of Fish & Wildlife 360-902-2672 [i][/i][color:#C0C0C0][/color]
Key words regarding chinook release mortality from tangle nets...
Quote:
Yep, I’m sure you’ve seen those estimates. They are for spring Chinook released from tangle nets in the Columbia Riverjust above the estuary. The caveats include: cold water, spring Chinook, freshwater. These are important because we were unable to make post-release survival estimates for fall Chinook and coho captured and released from Willapa Bay but the fish were in significantly worse condition at capture, and this indicates to me they did not survive as well. In the Willapa, the water was warmer, and the fish were in the midst of physiologic transformation in the estuary.
In my mind, the only meaningful chinook savings in using tangle nets is PERHAPS a lower encounter rate as the gear may not be as efficient in capturing the fish.
Once encountered, the release mortality comes from the unavoidable physical handling of an already stressed fish. Suspending entangled fish mid-air while busy dealing with other fish already on board... yeah that's real healthy. Just bringing fish over the roller is another added stress. If the fish isn't moving/thrashing, it's probably good as dead. If it is still thrashing, it must be manhandled to disentangle it from the webbing, further contributing to the stress factor. A rec guy isn't even allowed to remove a salmon from the water!
OK it's out of the net, now what? Live boxes? Well, we've all seen how consistently they were (NOT) used in the video. And with all the coho they will have to be dealing with, how much time and care do we expect them to spend on handling/reviving the economically worthless (to them) wild chinook bycatch.
Finally, there's the issue of recapture. Let's be intellectually honest here. When 20+ nets are strung completely across the migratory channel, a released king is as good as dead. This is especially true in the narrow bottleneck we know as area 2A. If he's not dead the first time, he will be by the second or third recapture. The only lucky ones are the ones released from the closing set of the fishing day.
Because many fish needed to be revived, a successful commercial selective fishery in this setting is expected to require a high ratio of marked hatchery to wild fish.
For the record, the mark rate for Chehalis fall chinook is exceedingly LOW
We did observe that many coho and Chinook captured in tangle nets and gill nets in this environment were lethargic and needed to be revived. This differs from similar studies in the Columbia River, where most spring Chinook and steelhead were in vigorous condition at capture.
Fish are going to be much more stressed by this gear type in warmer estuary water
Based on the condition at capture and method of capture results, a net that is appropriate for a tangle net coho fishery will also act as a tangle net for fall Chinook bycatch. Similarly, a net that acts as a gill net for a coho fishery will also act as a gill net for fall Chinook bycatch.
As mentioned earlier, we did not detect a difference between the tangle net and gill net for Chinook post release survival.
These results contrast sharply with a similar evaluation of the post-release survival of spring Chinook salmon on the Columbia River (Vander Haegen et al. 2004). In that study, spring Chinook captured and released from tangle nets did not differ in immediate survival from gill net captured fish but did survive at significantly higher rates following their release than Chinook released from gill nets.
Different species are known to have different responses to the same stressors (Schreck et al. 2001), and so may not respond to the nets in the same ways. A given species may also display a different response in a more stressful environment than a less stressful environment. Another possibility is that environmental stressors may override and mask survival benefits provided by the tangle net. In our study, the estuarine environment was likely unfavorable to capture and release because the water was relatively warm during the coho migration. Fishing in better conditions (e.g. cooler water, fewer predators) would most likely increase survival, although we do not know the magnitude of the difference. On the Columbia River, spring Chinook salmon were captured after they had migrated about 140 miles upstream, and were presumably habituated to the river environment.
To date, WDFW personnel have conducted several studies to evaluate the usefulness of different gear types in reducing the release mortality of non-targeted stocks in commercial selective fisheries. A three-year study in the Columbia River found statistically significant differences in long-term survival among fish released from a tangle net versus those caught and released from gill nets. This study found no statistically significant differences in long term survival among fish caught and released from tangle versus gill nets.
As I read further into the data I get a little smarter and more aggravated and discouraged at the same time. It seems that good science is being intentionally or ignorantly disregarded. I more fully understand Francis' post about being discouraged, but I have no doubt he will persevere.
"This study found no statistically significant differences in long term survival among fish caught and released from tangle versus gill nets."
OK, True Dat, so why then are we forcing our commercial fishers to use this outdated technology that cuts off recreational fishers from catching opportunities and harms non targeted stocks at the same time?
This current WB/GH commercial fishery is a sinking ship, destined to go down. I mean, that as this is brought to light it will not continue. I predict that Region 6 will be heavily, heavily scrutinized going forward. It used to be that local areas stayed local, but those days are gone. this is a regional issue, if not national wrt harvest and sustainability, and we need to up the ante. Time to work those smart proposals and talking points.
"Dovie'andi se tovya sagain" "Time to roll the dice."
I think that emails, letters, and personal conversations with WDFW staff and administration are all good. And I think that it is sage advice to "Keep our words sweet, lest we have to eat them." That does not mean the words cannot be focused, just that we should all leave here as "friends." I believe the WDFW staff are concerned and want "all this" to work, doing good things while staying employed and providing for their families.
This took up more bandwidth than I intended. I hope it is useful.
This Policy will guide Department staff in considering conservation, allocation, in-season management, and monitoring issues associated with the annual salmon fishery planning process known as “North of Falcon.” When considering management issues, Department staff will ensure that decisions are made consistent with: the Department’s statutory authority; U.S. v. Washington, U.S. v. Oregon, the Endangered Species Act; the Puget Sound Chinook Harvest Management Plan; the Pacific Salmon Treaty; the Pacific Fishery Management Council’s Framework Salmon Management Plan; pertinent state/tribal agreements; and the applicable Fish and Wildlife Commission policies.
The Department will implement this Policy consistent with the purposes and intended outcomes described in the 21st Century Salmon and Steelhead Planning Project including: •Salmon and steelhead will be managed to recover and assure sustainability in a way that is science-based, well-documented, transparent, well-communicated, and accountable. •Fisheries will be managed to meet or exceed ESA, recovery, and conservation goals; and harvest management measures will protect and promote the long-term well-being of the commercial and recreational fisheries.
Fishery Management
General •On a statewide basis, fishing opportunities will be provided when they can be directed at healthy wild and hatchery stocks. •Selective fishing methods and gears that maximize fishing opportunity and minimize impacts on depressed stocks will be utilized to the fullest extent possible taking into consideration legal constraints on implementation and budgetary limits associated with required sampling, monitoring and enforcement programs. •When assessed from a statewide perspective, fishing directed at chinook, coho, pink, sockeye, or chum salmon will not be exclusively reserved for either sport or commercial users. •When managing sport fisheries, meaningful recreational fishing opportunities will be distributed equitably across fishing areas and reflect the diverse interests of fishers, including retention and catch and release fisheries. •The Department will seek non-treaty fishing access to unutilized portions of treaty harvest allocations through the implementation of pre-season agreements, taking into consideration changes in abundance, fishery conflicts, and factors that may influence attainment of spawning escapement objectives.
Sockeye, Chum, and Pink Salmon •For fisheries directed at Fraser River-origin chum, pink, and sockeye stocks, the majority of harvest will be provided to the commercial fisheries. •For fisheries directed at harvestable Puget Sound-origin chum stocks, the majority of harvest will be provided to the commercial fisheries. •For fisheries directed at Lake Washington sockeye, the first 200,000 non-treaty harvest will be provided to recreational fishers. If the allowable non-treaty harvest is greater than 200,000, commercial harvest directed at this stock may be considered. •For fisheries directed at harvestable Puget Sound origin pink salmon, seasons will be established that provide meaningful opportunities for both recreational and commercial fisheries while minimizing gear and other fishery conflicts.
Chinook and Coho Salmon •The Puget Sound harvest management objectives for chinook and coho stocks, in priority order, are to: (1) provide meaningful recreational fishing opportunities; and (2) identify and provide opportunities for commercial harvest. When managing sport fisheries in this region, recreational opportunities will be distributed equitably across fishing areas, considering factors such as: the uniqueness of each area; the availability of opportunities for various species in each area throughout the season; the desire to provide high levels of total recreational opportunity; and the biological impacts. •Grays Harbor harvest management objectives shall include opportunities for both the recreational and commercial fisheries. •The Fish and Wildlife Commission’s policy on Columbia River Salmon Management (POL-C3620) shall guide pre-season and in-season planning of Columbia River salmon fisheries. Columbia River harvest management regimes shall be developed in cooperation with Oregon Department of Fish and Wildlife representatives. •Willapa Bay harvest management shall be consistent with Willapa Bay Framework management objectives. The following general intent shall apply: Willapa Bay harvest management objectives shall include meaningful opportunities for both recreational and commercial fisheries. •Pacific Ocean harvest shall be managed consistent with the Pacific Fishery Management Council’s Framework Salmon Management Plan and the National Standards that provide for fair and equitable allocation of fishing privileges among various fishers.
In-Season Management •When in-season management actions are taken, they will be implemented in a manner that is consistent with pre-season conservation and harvest management objectives, and the fishery intent developed through the North of Falcon process.
Monitoring, Sampling and Enforcement •Monitoring, sampling and enforcement programs will be provided to account for species and population impacts of all fisheries and to ensure compliance with state regulations. •Fishery participants will be required to comply with fishery monitoring and evaluation programs designed to account for species and population impacts.
Gear and Fishery Conflicts •Recreational and commercial fisheries shall be structured to minimize gear and other fishery conflicts. Unanticipated fishery interaction issues identified in-season, including conflicts with fisheries directed at other species, shall be resolved by involving the appropriate sport and commercial representatives in a dispute resolution process managed by Department staff.
Incidental Mortalities •The Department will manage fisheries to minimize mortalities on non-target species (e.g. rockfish, sea birds, etc.). Management regimes will include strategies to limit seabird mortalities consistent with the federal Migratory Bird Treaty Act.
Communications •The Department shall strive to make ongoing improvements for effective public involvement during the North of Falcon planning process and annual salmon fishery implementation, incorporating the following intents: ◦North of Falcon participants will be included as observers during appropriate state/tribal discussions of fishery issues. ◦all decisions made during the North of Falcon process will be recorded in writing. ◦variety of tools will be used to effectively communicate with the public, to receive input on pre-season planning or in-season fishery issues, and to make available the record of decisions. Such tools will include: recreational and commercial advisory groups; public workshops to address key issues; the WDFW North of Falcon Web site; and in-season tele-conferences.
Other Species •The Fish and Wildlife Commission’s policy on Lower Columbia Sturgeon Management (POL-C3001) shall guide pre-season and in-season planning of Columbia River and coastal sturgeon fisheries and related incidental impacts. Management of Willapa Bay sturgeon fisheries will be further guided by Willapa Bay Framework management objectives.
Delegation of Authority
The Fish and Wildlife Commission delegates the authority to the Director to make harvest agreements with Northwest treaty tribes and other governmental agencies, and adopt permanent and emergency regulations resulting from the agreements made during the annual North of Falcon process.
Update time but on April 1, 20013 Hamilton vs WDF&W was filed in Thurston County Court. After many months of efforts to obtain information and make it public and being stymied few options remained. A link to the information is http://fishingthechehalis.net/want-to-help
Reading this got me to thinking that the Gray's Harbor fishery management exercise needs to be subjected to a trial-type hearing, complete with pre-trial discovery, sworn witnesses, and rules of evidence. And then along comes Rivrguy! Way to go!
Just catching up. Thanks for the vote of confidence but folks this is not a Dave bit as ain't no way I have all the skills needed. From my brother Tim to Ron S. from Elma to Randy B. at Rochester to a huge number of folks pitching in it is simply a grass roots thing. It is time to speak out and object to having your rights trampled. That simple but to prevail far more complex and will take all of us.
If I recall correctly the line in the movie was " I am mad as hell and I am not going to take it anymore".
I would gladly post up a raffle/auction of one of my homemade stainless Steel Clam digging tubes and donate the proceeds to this cause. It is very important to anybody who fishes the two Bays and rivers mentioned and I commend you for doing what you are doing.
Can you get it approved with Bob or Corey and I'll get it made and start the auction? Highest bidder gets it but the winner will be responsible to pick it up in Hoquiam or maybe someone could deliver it wherever.
I have never done anything like this but somehow I will help all I can.
Will PM Bob and ask the question Fred. Thx for the support guy!!
Rivrguy,
As soon as I can get a Clam tube put together I will put it up for an auction. High bidder gets it no matter what the price is and all the money raised will go to your, or should I say "our", FISHINGTHECHEHALIS.NET fund? Hope it does well. Somebody might get the tube for 5 bucks or 500. Ya never know!
Anybody wanting to donate to FISHINGTHECHEHALIS.NET this will be a good way to get a free Clam tube and they work great.
Our FishingtheChehalis fund Fred. Our is a good word Fred as FTC staff is all volunteer. Due to the efforts of many sport fishers from the Chehalis Basin and across the state FTC it is becoming the Chehalis Basin's citizen's voice for change. That is what it is about the average citizen's right to available harvest and the protection of the resource.
I haven't even got it built yet. Guess I better get out in the shop and get it done today, take a picture and start a thread on the auction. It looks like it will go to a great cause.
Thought I would put this link up so all can view the Region 6 presentation to the Commission February 8, 2008 regarding the Chehalis Basin. It is interesting to say the least!
Also the link below is to a letter of June 6, 2012 addressing many of the issues associated with Grays Harbor and Chehalis Basin management to the Commission. Oh almost forgot, not one of the Commissioners responded.
Well another thread running on seasons but I thought I would put some feathers on it here. Last night was the last advisers meeting and it had it's moments. Seems the NT commercial guys were unaware that the 14 day season proposed at NOF in Olympia went down to 7 and ............ ah..they did not take it well?
So as it stands now no 2 C or Hump netting. Chehalis bound Chinook limited things so if the NT's fish there it cuts back on Chehalis time.
Here is the Chehalis netting schedule for NT nets and keep in mind this does not include the QIN. Should work out with nets in the river 6 days a week for the month of October.
Chehalis with 25 % mortality on released wild ( unmarked ) Chinook. 25% mortality is from " soft data " not a study.
Let me understand what just happened! At the end of NOF the WDFW imposed a season with 14 net days in 2A/2D and perhaps 5 days in 2C that were not shown at the meeting. Now it is 7 tangle net days in 2A/2D only.
At first I thought the gill netters realized the huge economic value of recreational fishing and gave up 12 days for the good of the community. Then Rivrguy said they did not know about the change until last night.
So did WDFW realize that the final NOF season was a mistake? Not a chance. Something good happened and I would guess we owe the rec advisors or a few in the rec community big time. This year has the potential to be the best recreational river fishery in years. A big thank you to those involved on our behalf.
Something good happened and I would guess we owe the rec advisors or a few in the rec community big time. This year has the potential to be the best recreational river fishery in years. A big thank you to those involved on our behalf.
As you are well aware, it can be a mundane, frustrating, maddening and often unrewarding process. This year was different, and the Chehalis chinook were saved from a potentially devastating net schedule. Not singing "Everything's Coming up Roses" just yet, but at least we finally got the pendulum to swing a bit in the other direction.
That's good news. Maybe the documentation on the website, a good turnout by recreationals, and the hard work of the advisors made a difference. Thanks.
Thank you all for your hard work and bullheadedness. I was considering golfing in october until I heard that netting days got dialed back. You saved me from a life of suburbia. See you on the water. Take Care, Ken
wow, new here thanks for all the info. I grew up on the eastside and had the privalige of fishing the upriver Chehalis for the fist time this winter. Found it very alarming every fish I landed was scarred by nets. eeeeek.
Several of us have been tracking the WAC process for both the commercial and recreational fisheries for the harbor and rivers. The link below is to a bit I did up on the FTC website that has a bunch of links in it that will allow you to see the current status of both. Rather interesting as neither the rec or commercial WAC's have been adopted by the Commission.
Well the supplemental CR 102's were put out today with some on sports for coast bottom & PS. Nothing on Willapa / Grays Harbor commercial but I will do a link once it is posted on WDF&W's website. So here is all I have.
"We did not file anything today re: NOF WB/GH or NOF recreational salmon rules. The next filing deadline is May 22. We may be filing the NOF WB/GH CR-102 Supplemental then. We are still a few months away from filing the NOF recreational salmon CR-102.
Just checked with my source on the process. After filing the CR-102 they have to schedule a public hearing, take testimony, make a decision, file the CR-103, and 31 days later the regs are "legal".
This sure looks like the 2013 salmon seasons will be done by Emergency Reg. It also means that none of the salmon fisheries done in NOF that are in the pamphlet are actually real rules.
It also means that none of the salmon fisheries done in NOF that are in the pamphlet are actually real rules.
Real rules?
Really?
I was under the impression the paper rec impacts have been spent and the season is a done deal, hence the move to go to final print after advisers were asked to help proofread for errors/typos a couple weeks ago.
I am talking about what is actually a legal rule, meeting the requirements of the Administrative Procedures Act. What was agreed to, proofed, and all that may well be "correct", just not legal.
Francis the bit you referred to has zero to do with the current WAC or the proposed supplemental. What the adviser's say or anything from North of Falcon IS NOT binding on WDF&W in fact they can just set and let the current CR 102 for commercials go to the commission for approval. http://wdfw.wa.gov/about/regulations/development.html#13-01-064 or they can do a supplemental but either way it is the WAC not anything said or NOF speeches that sets law. As of now it is the current CR 102 that is linked above.
The sports WAC is the pamphlet, so to speak, but it does not match the WAC so the emergency and supplemental WAC's are needed to keep the pamphlet and WAC straight. More to come as each time a season or something is different from the 2012 WAC ( which is still running ) does not match the new pamphlet WDF&W will do something to be legal. Most likely supplemental but as CM said they can try a end run with an emergency WAC.
The problem WDF&W has is as DW said, NOF is a " dog & pony show " that never matched the WAC process which is the law. Commercial or sport the manner in which R-6 has done business for years can be seen easily be seen http://apps.leg.wa.gov/wac/registerfiling.aspx?cite=220-36-023 If you take the time it research it this is clear WDF&W has it's mind made up to as to impact numbers for marine sport / fresh water ( river ) / commercial and how much of harvest goes to who / where in February as they prepare the original notice in or around March dependent on the QIN agreement. Now they do move around on species, days, ect but in the end come close to the original numbers they post in the CR 102 which was March this year. http://wdfw.wa.gov/about/regulations/2012/wsr_13-01-064.pdf The CR 102 is the first break out on the commercial seasons is seldom much different than the permanent rule that the commission adopts and if it is requires a supplemental WSR filing. The rest that comes with NOF is pure BS as it means about zip.
So look at it this way on the GH / Willapa commercial WAC. If they post it May 22nd it has a 20 day comment period so we are at June 20th. The next meeting of the Commission would be July 5th as the May 22nd posting puts them one day past the Commission schedule http://wdfw.wa.gov/commission/meetings.html. Then the 31 day bit to take effect puts you to August at a minimum. Now if you are a believer in " Murphy's Law " then one could envision a scenario that backs WDF&W up to a time line that would leave few options for supplemental WAC for Willapa and GH so it is emergency rule time. http://wdfw.wa.gov/about/regulations/emergency_rules.html
Link is to D's Rant on the FTC website. http://fishingthechehalis.publishpath.com/is-nof-dog-pony-show- In our recent PDR we received some very interesting pieces of information ( which are linked to ) regarding the NT Commercial WAC. Bottom line R-6 staff were informed that they were violating the WAC process in 2011 and they simply ignored it. No need to read the Rant if you do not care to but the links will provide insight in how R-6 does business.
https://docs.google.com/folder/d/0B2tWjgmgVy3yTXZ6UmNHZkUtWFU/edit This is a link to the first installment on PDR 13108 we just received. The larger files are multiple e mails ( hundreds ) so when you open the file you will have to do a down load ( usually on a prompt ) and get a warning that the file is to large to scan but the files are virus free so just hit a download. You will see a list of e mails at the top of the page and it scrolls and you can open each up. Adobe Reader or Adobe is required and some of what I outlined will differ dependent on how your computer is set up. Interesting reading.
Yesterday I listened to a group of steelhead anglers who were upset at the way some steelhead proposed regs were politicked for and snuck back into the process. Couple that with the whole Cabezon situation and it looks like there are a lot of games being played with the regulation process.
Anyone else have anything to add that they know about the reg / WAC process not being followed. In Willapa / GH that utter disregard is documented, as is the Cabezon fiasco. Seems to be a pattern of manipulation of the WAC / public hearing process to get and outcome that is not necessarily what WDF&W staff says it is. Thoughts?
For my part the following links take away any of the " " we are confused bit " often used. This link is to an email thread where Lori Pruess clealy identifies to R-6 staff that you can not make major changes to the CR 102 https://docs.google.com/folder/d/0B2tWjg...Q0VBcG56bG1HZTg which is how the regs / seasons are set. Why is this important? Take this year the CR 102 was in March 8th before even the Advisers met which means no major changes allowed with out a supplemental WAC or redo is another way of putting it.
Bottom line is as put forward before, the NOF process for sports and commercial fisheries is smoke and mirrors in and attempt to meet requirements for public input. Most folks have given up on that process but few have grasped just how WDF&W did this year after year. The reality is they do a public NOF that is little more than a " rope a dope " then pretty much do whatever they want which has been in recent years screw the fish and in river sports.
The link provided is to a document that was attached to a e mail in the latest PDR response. Why is this interesting one might ask? Well it concerns Wynoochee Mitigation and not the funds from TCL but the ORIGINAL dam mitigation. Twice before WDF&W has attempted to cut the Steelhead Mitigation in budget reductions and the local folks nailed them. Seems old WDG used the funds to upgrade Aberdeen Lake Hatchery and guaranteed they would make up future shortfalls out of pocket. Now WDF&W appears to be out rummaging around again.
The thing about both the original mitigation and the failure to produce the additional fish that were funded at the time the dam power plant went in 1993 is utter lack information they provide even when asked point blank.
Was asked to update on the commercial seasons so here it is ........... got me. The silence is deafening but sooner or later WDF&W has either to move the current CR 102 forward http://wdfw.wa.gov/about/regulations/development.html#13-01-064 or drop a supplemental WAC for a redo. The last word was seven days @ 25% mortality with tangle nets but that takes a supplemental WAC and as as I said nothing yet. As to the QIN seasons their are lots of rumors swirling around but nothing formally announced.
As to the question regarding the accuracy of the preseason forecast, they are seldom correct. https://docs.google.com/folder/d/0B2tWjg...d2NJRHV4Sm5SSkE for 2013 Coho and https://docs.google.com/folder/d/0B2tWjg...SXE0Rnd6SFlRNUk for 2013 Chinook. The best way to view the spreadsheets and down load them ( just hit the down load arrow ) as the data base stores them as they were constructed and by down loading you get the functioning sheets. Their is a considerable amount of information in each spread sheet including performance graphs. Just walk through the tabs at the bottom of the sheet.
The paper below is a briefing paper created for the WDF&W Commission by R-6 staffer Kirt Hughes. Now lets not get side tracked on a hatchery good or bad thing as this was a conceptual briefing but that said look to the thoughts involved. In particular how the proposal is completely aimed at creating another commercial fishery and maybe the sports might catch some. ( I will highlight the spots ) Now I do not think this ever went anyplace but the mind set and thought process on assigning values does come out. Often words while not intended to do so show the bias in a persons thoughts unintentionally and brother this little ditty does. I will try to get a link to the Power Point presentation that went with this soon.
“GREEN SHEET”
Meeting dates: August 8-9, 2008 Meeting (briefing)
Agenda item #: Willapa Bay SAFE Program – briefing
Staff Contact: Kirt Hughes, Region 6 Fish Program Manager (Fish Program)
Presenter(s): Kirt Hughes, Region 6 Fish Program Manager (Fish Program)
Background:
In June 2008, WDFW staff received an official request from the Washington Fish and Wildlife Commission, to investigate the benefits, risk, logistics and costs associated with the development of a hatchery spring Chinook (SAFE type project) program to provide additional fishery opportunity in Willapa Bay. Staff has discussed the merits of this type of program and outlined the details associated with developing such a program in the Willapa Bay watershed. The following is a brief synopsis of those discussions.
Meaningful Fishery The first item to consider is whether a meaningful fishery would be created. From a commercial perspective the threshold for a meaningful fishery was measured in terms of ex- vessel value a range of program sizes were determined by back-calculating price/pound, average weight of returning adults, contribution to fisheries and smolt release to adult survival rates. Assumptions utilized in these calculations are an average 15 pounds per fish, $7.50 per pound with 72.9% of the adult return contributing to the local commercial fishery. An average of 0.88% smolt to adult return rate was used to estimate the number of fish available to the fishery. The contribution to fisheries and return rate are averages for similar programs in the lower Columbia River. A pilot or proof-of-concept program with a 50K yearling smolt release would provide a projected return of 440 adults and approximately $36,000 ex-vessel value annually after the third release year; a full production level release of 300K – similar to Deep River net-pens – would yield 2,640 adults with a projected ex-vessel value $217,000. Defining a meaningful fishery in recreational terms is a bit more abstract although availability of returning adults in abundance that support commercial harvest generally provides for recreational opportunity at some level.
Facility Location Any of the three existing Willapa hatchery facilities (Forks Creek, Nemah and Naselle) could rear spring Chinook, however that production should not displace current production. However, because of the additional water needs and pond space required for rearing spring Chinook, current programs would be impacted if this new production was anticipated to occur at existing facilities. With that in mind, a net-pen facility offers the greatest possibility of success. Net-pen production would be developed in a similar fashion to the Columbia River Select Area Fishery Evaluation Projects (SAFE projects) at Deep River, Youngs Bay and other locations in the lower Columbia River. Additionally a net-pen facility would concentrate returning adults in the vicinity of the pens thereby maximizing the contribution to harvest. Net-pen site location requires certain physical conditions such as water depth, high levels of tidal exchange or freshwater flow, and a host of parameters associated with permitting a site. Within Willapa Bay the best locations appear to be near Toke Point or in the lower Willapa River between towns of South Bend and Raymond; other sites continue to be explored.
Broodstock Source There are no natural spring Chinook stocks in Willapa Bay, therefore a hatchery brood stock would require an out-of-basin source. As with any hatchery program there are disease considerations that must be taken into account. Development of a hatchery Spring Chinook program in Willapa Bay would need to be done consistent with fish health standards and in compliance with the co-managers disease policy. Sources considered in this evaluation: • Willapa Bay; does not have natural spring Chinook stock. • Chehalis River springs Chinook; closest stock geographically, however the absence of spring Chinook hatchery programs within the Chehalis system would require brood stock collection from natural spawning stocks within the upper river. • Sol Duc River spring Chinook, which were historically introduced have integrated genetically with the Sol Duc River summer Chinook and as a result have a later run timing. • Puget Sound has a number of spring Chinook hatchery programs, however these are recovery projects and as such not available for transfer to out-of-basin locations. • Cowlitz and Kalama hatcheries in the lower Columbia River basin, both have spring Chinook program; these are considered to be the most viable sources.
The most likely brood stock source would be Kalama Hatchery because of their ability to provide early rearing of juveniles needed to meet program goals. A proof-of-concept size program might represent a first step. Fingerlings would be transferred to the site after initial rearing at a land-based facility in the lower Columbia, again Kalama in the most likely brood source. It is assumed that a proof-of-concept level of production could be absorbed into Kalama’s current program. However at the receiving facility on additional hatchery worker would be required to feed and care for the fish while there are in the net-pens. To reduce disease loss due to temperature of the receiving water it is recommended that fingerlings be transferred in September or October and reared to release in May.
Non-target Stock and Species Interactions Hatchery net-pen operations and fisheries management have the potential to have unintended implications on non-target stocks and species. The full extent of fishery impacts on non-target stock and species are unknown. This is the case for any new fish production project and those which have not operated for the length of time necessary to evaluate through data collection and monitoring. Proper fishery management requires that all fisheries are monitored at some level. Monitoring and evaluation of fisheries targeting a spring Chinook in Willapa Bay would be critical to understanding the impact on non-targeted stocks and species and the success of the program. To facilitate monitoring and evaluation all releases would need to be coded-wire tagged and externally marked. The commercial component would require on-board observer coverage and dockside sampling. Additional spawning ground surveys and hatchery sampling would be needed. This information would provide estimated catch, bycatch, estimated escapement back to the release site and the spawning grounds to obtain survival rates, as well as potential information about interactions with natural spawning stocks.
Enforcement This fishery would be conducted during spring and early summer, during a time when fisheries had not been previously occurring in Willapa Bay. This would require additional enforcement. It is likely that this would result in some additional enforcement costs and potential conflicts with other enforcement priorities.
Cost Net-pen and associated cost of set-up are estimated at $7,000 per net-pen (except permitting); loading densities and size of net-pen evaluated here have a capacity of 50,000 yearling smolts averaging 10 fish/pound. Annual fish food cost currently $4,300, per year per 50,000 yearlingsmolts being reared from fingerling to an average of 10 fish/pound at release. Salary and operating costs (vehicle, vessel, etc.) for a temporary worker to care for and feed fish while in the net-pens are approximately $63,000. The cost of initial rearing at the source facility has not been evaluated. For the initial acquisition of permits, sighting of the location, installation of required markers, buoys, and other associated hardware, plus the aforementioned actual rearing costs, the pilot projects estimated first year budget impact would be approximately $120,000; subsequent annual costs would be about $75,000 at the pilot project level of fish production. The total cost of this program if initiated would require new funding from the legislature. Additional cost will be associated with monitoring and evaluation once adult begin to return and fisheries are initiated.
Policy issue(s) you are bringing to the Commission for consideration: Should WDFW staff continue to pursue this activity?
Public involvement process used and what you learned: It will be important to involve the public should WDFW Regional Fish Program staff be asked to move forward with investigating this concept further. As part of that staff would look to the Willapa Bay Fishery Advisory Group to gain initial insight and comments from both recreational and commercial interests and from the local Regional Fisheries Enhancement Group. Staff would also request that the Hatchery Scientific Review Group review and comment. Should those discussions result in a favorable outcome relative to this concept; staff would begin discussing logistical aspects of this program with other agencies at both the state and federal level, such as: Washington State Department of Ecology, United States Army Corps of Engineers, and NOAA Fisheries to name a few.
The value of a recreational fishery is participation. The "perfect" fishery is lots of anglers and no catch; notice how sports fisheries are all about "opportunity"? That mindset has been around WDF/WDFW for a long time.
This posting is a letter obtained in PDR 13108 directed at the Commission in 2010. Not a lot has changed since, well they moved the NT Nets back a bit in the bay but that is all. I have blocked out the gentleman's name as a courtesy
. From: To: Commission (DFW); Subject: Willapa Bay and Grays Harbor Date: Wednesday, March 16, 2011 12:25:36 PM
Commission Members,
I thought you might be interested in this situation.
Westport/Grayland Chamber of Commerce
I am contacting you on behalf of recreational fishers in Willapa Bay and Grays Harbor. Business owners should be able to support both commercial and sport fishing. They should not be bullied into making a choice. Most of the gill netters in this area are fine people. There is a very small fraction that want the sport fishers out by any means. There has been name calling and harassment on the Tokeland docks. Here is an example, a man was walking down the dock to his boat in the morning. He passed by a few gill netters standing by one of their boats. He said nothing to them but after he walked by one of them shouted "we gotta get these ---- suckers outa here". They threaten business people with the loss of their dollars if they support us in any way. My wife and I stayed a month per year in Tokeland for 18 years and spent a considerable amount of money from South Bend to Westport. We don't fish there anymore because of what I have encountered. I won't elaborate on what I have been called.
In past years, we had to struggle but both sides got a decent season at the annual salmon meetings. In 2010 the WDFW made no pretense of fairness. The sport fishing representatives that attended thought it was not a legitimate negotiation. They held private meetings with the gill netters before each of the last two meetings. Towards the end of the last meeting, one of the commercial fishers said something like, "we've wasted enough time, isn't it time to tell them how it's going to be?" Soon after his statement the DFW did just that. In recent years the gill net fishing started around mid September in Willapa Bay. In 2010 They received a so called "test fishery" with not many boats but quite a few dates. They got two full fleet openers in August just when the recreational season is beginning. They started their regular season about four days earlier than the recent average.
The DFW also required us to release all unmarked Chinook and coho. This is very frustrating, many anglers reported a 50% release rate. With Chinook, the naturally spawning and hatchery salmon are all the same stock. The native silvers that are scarce don't come in until nearly a month after the marine sport fishery is basically over. They required the gill netters to release the unmarked salmon also. Catch and release gill netting makes no sense. At the mortality rate they are assessed at, they wasted 940 kings and 9,544 silvers, then add the sport fishing mortality. This is an awful waste of food and I was told it was a disgusting sight, the dead salmon drifting down with the tide.
Westport spends a lot of money attracting us to this area. The DFW and the gill netters appear to be trying to get rid of us. The Department totally ignored the letter the Chamber sent last year. If this doesn't change there will be a constant decline in recreational fishing. I was told the South Bend launch was down about 50% last year, Tokeland was down too. Some members of the Legislature seem to have some
leverage on the DFW. You probably know a lot more about that than I do. We do not want to take over, we just want what is fair for us and for the business community. I am sending a copy to the 19th District Legislators.
On the subject of South Grays Harbor, as you know a great Chinook sport fishery has been lost. It was good for us and for you. The DFW still allows a non tribal gill net Chinook mortality and they have allowed a sport fishing Chinook mortality with a coho fishery. With Tribal fishing, I wondered if you had tried talking directly to them. This could be of interest to sport and commercial fishers also. There is also the habitat destruction in the Chehalis headwaters. I really hope we can make some progress on all these problems.
As we have all waited for the CR 102 Supplemental for Grays Harbor & Willapa that will define the Non Treaty Commercial seasons one had to wonder how WDF&W would get the implementation timelines in sync with the legal requirements. TaDa .................. now we know how, you separate Willapa from Grays Harbor with a CR 102 Supplemental. http://wdfw.wa.gov/about/regulations/development.html#13-01-064
From WDF&W the notification below:
Today we filed a CR-102 Supplemental for Willapa Bay and river-mouth definitions. You can view it by going to this page, http://wdfw.wa.gov/about/regulations/development.html, and clicking on the item for NOF Willapa Bay/Grays Harbor. Our Fish Program tells me they do not know when they will be ready to file a CR-102 Supplemental for Grays Harbor. I’ll let you know if and when we do file one.
With mid August for the Willapa Commercial start up and supposedly the first week of October in the Chehalis something had to give as the timeline for public comment / passage / implementation on the combined Grays Harbor and Willapa WAC was about to be out of reach for the agency. To be honest this is not really a surprise for the reasons stated above and at first read looks to follow what Region 6 staff put forward at the Olympia North of Falcon meeting March 29th.
Grays Harbor? Darned if I know but they do have a CR 102 on the books filed March 6th ( same Link provided above ) that could be voted on by the Commission or they can do a CR 102 Supplemental. Anyway you look at it the separation of Willapa and Grays Harbor did little to solve any of the issues revolving around the 2013 Commercial Seasons just simply got the Willapa timeline in compliance with the law.
Come to think of it that is a new one .............. being in compliance with the law ............... look at the progress!
I forgot to add that another individual was told by R 6 staff that the CR 102 supplemental for the GH commercial fisheries will be submitted July 3rd. As to the QIN, all I know is that the word is they have a " big disagreement" with the agency. Time will tell but until the commercial CR 102 supplemental is filed and the QIN commercial days are announced one has no idea on the lay of the land this fall for the in river sport.
At last WDF&W Region 6 ( R-6 ) has put the CR 102 Supplemental for the Non Treaty Commercial Nets ( NT ) for Grays Harbor in play and here is the link to take a look at it. http://wdfw.wa.gov/about/regulations/development.html#13-01-064 As outlined at the March 29th North of Falcon ( NOF ) by R -6 Fish Program Manager Ron Warren at the meeting in Olympia it is seven days on the Chehalis with tangle nets. To achieve this the Humptulips 2 C is not targeted because that fishery would harvest a substantial number of Chehalis bound Chinook but as last year the Quinault Nations ( QIN ) commercial fishery will in all likelihood pick up the slack.
So simple terms what does this mean to the inriver sport fishery and the fish. Now not knowing the QIN's netting schedule for the 2013 one can only make a educated guess that with the similar run size to 2012 it will closely resemble the 2012 effort. So folks you should see nets of one kind or another in the Chehalis six to seven days a week for the entire month of October. Which means the inriver sport is getting paper fish just as the last four years but real opportunity is not there because the fish will be killed at the 101 bridge in Aberdeen. The same old inept and corrupt management of Region 6 marches on!!!
So what to do? Well to start you can object to the CR 102 Supplemental by e-mailing your comments opposing this horrific giveaway to the commercial fishery to Lori.preuss@dfw.wa.gov. and urge others to do the same. Fishing The Chehalis will begin a in depth review of the CR 102 Supplemental after the Forth of July holiday so more to come to be sure!
(a) For Areas 2A and 2D, soak time must not exceed 45 minutes. Soak time is defined as the time elapsed from when the first of the gillnet web is deployed into the water until the gillnet web is fully retrieved from the water.
(b) Any steelhead or salmon that is required to be released and is bleeding or lethargic must be placed in a recovery box prior to being released to the river/bay. The recovery box must meet the requirements in (d) of this subsection.
(c) All fish placed in recovery boxes must be released to the river/bay prior to landing or docking.
(d) Each boat must have two operable recovery boxes or one box with two chambers on board when fishing Areas 2A and 2D. Each box must be operating during any time the net is being retrieved or picked. The flow in the recovery box must be a minimum of 16 gallons per minute in each chamber of the box, not to exceed 20 gallons per minute. Each chamber of the recovery box must meet the following dimensions as measured from within the box: The inside length measurement must be at or within 39-1/2 inches to 48 inches, the inside width measurements must be at or within 8 to 10 inches, and the inside height measurement must be at or within 14 to 16 inches. Each chamber of the recovery box must include a water inlet hole between 3/4 inch and 1 inch in diameter, centered horizontally across the door or wall of the chamber and 1-3/4 inches from the floor of the chamber. Each chamber of the recovery box must include a water outlet hole opposite the inflow that is at least 1-1/2 inches in diameter. The center of the outlet hole must be located a minimum of 12 inches above the floor of the box or chamber. The fisher must demonstrate to department employees, fish and wildlife enforcement officers, or other peace officers, upon request, that the pumping system is delivering the proper volume of fresh river/bay water into each chamber.
In a nutshell the new CR102 REDUCES commercial time from 14 days spread over the entire Hump/Chehalis estuary using std gillnet mesh and condenses the fishery to 7 days prosecuted ENTIRELY on the Chehalis side with small mesh "tangle" nets.
The old schedule which was approved at NOF on March 29 was as follows
Five 24-hr days in 2C (Hump estuary) on Aug 20, 24, 28, 30, and Sept 6.
Eight 12-hr days in 2A/2D (Chehalis estuary) on Oct 1, 2, 12, 14, 19, 20, 22, 24.
One 24-hr day in 2A/2D on Oct 21
...
The new revised schedule submitted in the CR102 yesterday reflects a recalculation of the assigned tangle net mortality for this fishery. With a bit of pressure WDFW was persuaded to increase the release mortality by an additional 67% compared to that proposed on Mar 29 at NOF. That recalculation logically increased commercial chinook impact by 67% resulting in a massive scale-back of the original GH gillnet schedule above.
The new and improved schedule is as follows:
Seven 12-hr days in 2A/2D on Oct 7, 8, 14, 22, 24, 29, 30.
Note that the final opener on Oct 30 allows them to fish an expanded area for the entirety of 2D (all the way west to the marker at the mouth of Johns River)
As Rivrguy states, even though the reduction in GH gillnet time went from a total of 240 hrs down to only 84 hours, ALL 84 HOURS WILL BE PROSECUTED ON THE CHEHALIS SIDE.
This does not include the tribal schedule, which has yet to be published.
In a nutshell the new CR102 REDUCES commercial time from 14 days spread over the entire Hump/Chehalis estuary using std gillnet mesh and condenses the fishery to 7 days prosecuted ENTIRELY on the Chehalis side with small mesh "tangle" nets.
The old schedule which was approved at NOF on March 29 was as follows
Five 24-hr days in 2C (Hump estuary) on Aug 20, 24, 28, 30, and Sept 6.
Eight 12-hr days in 2A/2D (Chehalis estuary) on Oct 1, 2, 12, 14, 19, 20, 22, 24.
One 24-hr day in 2A/2D on Oct 21
...
Well those are the proposed days that were revised in the text of the CR102 filed y'day. As I was typing my post, my 50 yr old brain kept telling my fingers, "Damn, I remember something more along the lines of 14 days on the Chehalis side"
Not sure how I managed to remember that, but hey.... the ol' noggin' was right!
I took an iPhone image of the final package (in Excel format) that was approved at NOF on March 29, and here it is...
As you can see, Region 6 was ready to go with a 14 day package on the Chehalis side.... and that doesn't count the 5 days on the Hump side. So a total of 19 days has been reduced to only 7.
Count our blessings? I'd like to think so but the bigger (and all important) unknown is how does the tribal side respond?
Quoting Riverguy from an earlier post...
Quote:
I forgot to add that another individual was told by R 6 staff that the CR 102 supplemental for the GH commercial fisheries will be submitted July 3rd. As to the QIN, all I know is that the word is they have a " big disagreement" with the agency.
Pretty easy to surmise what that disagreement is.
So, the scaling back of the NT commercials to 7 days could definitely be a blessing IF the tribe doesn't fill those lost NT days with days of their own above and beyond what they are already planning. If they do, it will be the same obscene net schedule as the last several years with no marked improvement or hope for the in-river fishermen having decent numbers to fish on.
The reduction from 14 days to seven happened at the last Advisory meeting AFTER public participation ended as the sport side Advisers objected in writing to the Commission. In fact when one Adviser brought forward in an Advisory Meeting that the numbers needed to reflect reality Ron Warren responded that " he should be careful what you wish for " and it is on tape you can request it and listen yourself. It was a warning to the Adviser that if you corrected the numbers it would impact the season ( alter / shorten ) the bay sport fishery. Besides will you folks quit listening to what WDF&W says but rather look at what they do. The key thing is R 6 knows the numbers are not correct as the model in the last four four years hugely under estimates the bay sport & NT net impact and over estimates the inriver sport catch shown in the model. The real model impact error over the last four years numbers have been posted in the past on this website and FTC. In addition the mortality on releasing Chinook from the Tangle nets is a joke and the agency knows it. Take a look at it in action http://fishingthechehalis.net/chehalis-fling as WDF&W's own staff recognized in studies that a warm water estuary is nothing like the Columbia and the release does not work as most of the fish are dead. The idea that there is a reduction from that SWAG ( Wild Ass Scientific Guess ) 45% mortality to a lower percentage is just pure BS and WDF&W knows it. Falsifying math to achieve a harvest scenario is called " cooking the books ".
As I said before if you feel nets 6 to seven days a week are sound management you should be happy. Frankly this is little more than the same shell game that R 6 staff has done for years under the present staffing which have shown and unbelievable ability to utilize facts and numbers they know to be wrong and grossly misrepresent to citizens their ability to participate in the decision process. NOF itself is nothing but a " dog & pony show " and you pick the definition of someone that stands in front of a room full of citizens putting forth information that is completely inaccurate and misleading and they know full well it is. I know what my father called it .
Oh almost forgot, " Count your blessings " ? Nah I for one am not going to accept this load of crap. Opposition to the continuing institutionalized discriminatory policies toward the inland communities / inriver sport by WDF&W Region 6 policies is growing and folks have learned they can object to the CR 102 and the WAC right to the Commission as they adopt and more. It is game on.
WDFW (its predecessor WDF) have institutionally supported marine sport fisheries over freshwater since at least the early 80s. Once salmon get in the rivers they are supposed to be left alone to spawn. What is happening in R6 is really nothing new. Getting them to put the freshwater fisheries and communities at a higher priority will be difficult.
From a purely economic benefit standpoint which dead fish in the boat brings more economic value; the coho taken on a Westport Charter or that same coho taken by a Satsop bankie?
We like to argue that recreational fish generate more economic value than commercial catch; that same argument can and will be used to divide up the sport fisheries.
Escapement policy is the real question here, isnt it? The goals are way too low for that system and they are seldom achieved anyway. MSY is an evil mistress.
Based on the way they manage, WDFW would agree that the goals are too high. Otherwise, they would develop management strategies that would show a higher rate of achievement.
What matters in not what the managers say about the resource or their goals. What matters is the end result. And the most important end result for GH fisheries is meeting the Bay net needs, with Bay sport next.
Funny how WDFW and the tribes scated by the ESA and their own wild salmonid policy to do whatever they want, wherever they want.
While ESA does not apply yet to the chehalis except for bull trout, the WSP says they will meet and/ or exceed escapement goals unless they demonstrate poor habitat capability to benefit from those spawners. So lets see the data demonstrating poor habitat quality to excuse the current dismissal of wild escapement needs. They cant do it, unless they load their models with their own assumptions about habitat capability. And that isnt science, it is fitting models to suit their pre-held assumptions.
Every now and then insight comes roaming through the e-mail world. I found this a rather insightful read.
Here's a thought on the whole harvest thing. May have mentioned it before but it may explain at least some of the why and the powers behind it.
In Hoh v. Baldridge the tribe sued the Feds because they approved of ocean fisheries (the WA sport and troll) that took so many Hoh fish that the Tribe was closed for conservation. The Court held that the Tribes could not be shut down for conservation if the reason was prior harvest essentially, the tribes can't be corked. WDF response, from the technical folks, was OK-close the ocean. Escapement still being the #1 priority. Both the Tribes and Feds said no, just share the harvest. If you take 50 in the ocean, the tribe gets 50 in the river. WDF "went" along. This was begun under Wilkerson; Co-management and sharing the pain.
So, the Tribes are in favor of the ocean and bay fisheries (essentially in front of them) because it guarantees them a fishery. If the management paradigm was no fishing until we confirm runsize (some update fisheries) then the schedules would have to reflect something closer to reality. They tribes, and state, would have to manage in-season (more expensive) and might actually have to be close. The river sport is not only the bastard step-child but would put the tribe(s) in the uncomfortable position of having to be responsible managers as they could not cork the sporties if there was a significant fishery that came after them. This is what the court (Boldt) said about steelhead. The tribe can't cork the sporties.
So, ultimately, getting a significant increase in the river fishery will likely be opposed by not only QIN but many other WA tribes who prefer to see the non-Indians take their fish ahead of the tribal nets, so those nets can fish unfettered and if the run comes in stronger all the benefits are reaped by the tribe because the non-Indians took the shot they wanted.
Well as I have been going after the management of the Chehalis Basin for sometime I thought I would post up my comments on the proposed Grays Harbor Commercial CR 102 Supplemental. For those who do not know it is the legal process used to create a Washington Administrative Code ( WAC ) rule used to legally create a sport or commercial season. Bit long winded but there was a lot of ground to cover. If you want to comment the CR 102 can be at viewed http://wdfw.wa.gov/about/regulations/development.html#13-01-064 and your comments can be e-mailed to Lori.preuss@dfw.wa.gov
July 10, 2013
Lori Pruess copy by mail Via email, hard copy by mail WDFW Rules Coordinator, 600 Capitol Way North, Olympia, WA 98501-1091 Fax: 360-902-2155
Ms Pruess,
I am writing to express my opposition to the CR 102 Supplemental for Grays Harbor filed as WSR 13-14-123 on July 3, 2013 for the following reasons.
1. The commercial non treaty net fishery outlined continues the policies of institutionalized discrimination by WDF&W Region 6 ( R-6 ) toward the inland communities and in-river sport fishers. The proposed commercial harvest will remove the ability for the vast majority of fishers in these communities to harvest an equitable share.
2. WDF&W Region 6 continues to refuse to recognize and take as a whole the accumulative effect of three commercial fisheries in the Chehalis Basin / Grays Harbor. I fully recognize that the Quinault Nation's and Confederation of Chehalis Tribes share of the commercial harvest are court mandated and not open to discussion. The Legislature has mandated that the WDF&W Commission manage salmon harvest for both sport and commercial harvest is also true but it is my belief that the two tribal fisheries meet the commercial requirement and needs. For WDF&W R-6 to attempt to maintain and continue the non treaty net commercial harvest in the manner and magnitude proposed is to continue rejected past policies of WDF&W that identify fishers by race and ethnicity rather than accept that the court mandated tribal fisheries are the Chehalis Basin / Grays Harbor preeminent commercial fisheries.
3. During Public process know as North of Falcon ( NOF ) WDF&W Region 6 intentionally mislead the public by failing to identify and define the WAC processes. Staff described it as " opening the WAC " knowing full well that the CR 101 was filed 12/7/12 and CR 102 on 3/6/13 before the first Grays Harbor Adviser or the NOF Public Input meeting in Montesano. In addition staff were told via e mail in 2010 by the WDF&W Rules Coordinator that their approach to the WAC process was incorrect as substantial changes could not be made to the CR 102. WDF&W R-6 chose to disregard and continued with the practice identifying the process to the general public in a manner that was intentionally misleading.
After the public meeting in Montesano R-6 staff presented a modified non treaty commercial season to Grays Harbor Advisers with a season utilizing tangle nets for fourteen days with a 14.7 release mortality. This plan was again presented at the NOF meeting March 29th which is a daytime meeting that few citizens can attend due to having to work. On April 2, 2013 a number of GH Advisers supported a letter to WDF&W Commission Chair Wecker authored by Adviser Dr. Francis Estalilla outlining their opposition to the revised commercial season identified above. After Dr. Estalilla met with Director Anderson and several Commission Members at the following GH Adviser meeting WDF&W R-6 staff outlined a new schedule of 7 days at 25% release mortality which is reflected in the CR 102 Supplemental. At this date WDF&W R-6 has not released or provided documentation of the baseline data or methodology used to develop either the 14.7% release mortality or the 25% release mortality reflected in the CR 102 Supplemental. Having broodstocked both Chinook and Chum utilizing tangle nets, seine nets, and hook & line for over twenty years I can say with certainty the 25% tangle net mortality is not a valid release mortality anymore than the discredited 14.7% tangle net mortality or the previously utilized 45% gillnet release mortality assumption.
The 2013 Grays Harbor Fall Non Treaty Planning Model provided by WDF&W R-6 does not have the Quinault Nation or Confederation of Chehalis Tribes seasons and projected harvest data entered which is badly needed in any assessment of the proposed Grays Harbor CR 102 Supplemental. In addition WDF&W R-6 refuses to release the date, time, or location of the NOF allocation meetings with the Quinault Nation or Confederation of Chehalis Tribes and simply states the meetings are not open to the public. While I fully understand that a citizen can not actively participate in the meetings with the two tribes they can observe.
Blocking public access to WDF&W R-6 interactions with the Quinault co-managers is not a new issue as WDF&W R-6 staff even took the position that the Grays Harbor Adviser meeting could be held behind closed doors away from the public view without records being kept until this year when a newly appointed Adviser strenuously objected. The allocation meetings between the tribes are part of the NOF process and WDF&W R-6 is violating numerous rules and WDF&W Commission guidelines by denying citizens an opportunity to observe the WDF&W / tribal harvest allocation meetings which are part of the mandated public NOF process.
In reviewing the WAC processes utilized by WDF&W R-6 I that have outlined it is doubtful that any citizen would have the information needed to understand or comment on the commercial CR 102 Supplemental in an informed and knowledgeable manner.
4. It is my understanding that the approximately 48 mathematical errors in 2012 harvest model, identified by citizen John Campbell, have been corrected in the 2013 Grays Harbor Fall Non Treaty Planning Model but not the harvest assumptions that create the baseline impacts in the model. The model performance greatly underestimates 2A and 2D non treaty commercial fisheries, and the Grays Harbor Bay sport fishery. It also overestimates the in river sport harvest and both problems have been brought to WDF&W R-6 staff's attention repeatedly.
On average, the marine recreational harvest exceeds the model predictions by a factor of 350% and in 2006, anglers in the marine area overfished the modeled harvest by over 500%. Moreover, the non-treaty gillnets have historically killed 150% of their modeled paper impact over the past decade. The over-exploitation by non-treaty nets has become particularly acute in the past three years, averaging 250% of the modeled rate.
5. The management of Chinook stocks in the Chehalis Basin is in such disarray that Chehalis fall Chinook have only exceeded the minimum escapement goal twice in the previous 11 years and only 3 of the last 15 years. In other words WDF&W R-6 fails 4 out of 5 years to correctly manage harvest / escapement. This is compounded by the incorrect base line assumptions on Chinook release mortalities as WDF&W R-6 does not require utilization of the internationally accepted release protocols. The survivability of released Chinook in a “selective” tangle net or gillnet fishery is predicated on the following protocols which are 1) avoidance 2) limited soak times 3) careful handling 4) use of revival boxes and 5) gentle release into safe waters. The non treaty commercial fishers simply release netted fish by throwing the captured fish into the river at the time of retrieval of the net at the bottom end of the drift and then proceed back upstream to reset their nets for another drift resulting in the same fish being caught time after time until it perishes, if it was fortunate to survive the first encounter. The use of revival boxes is discretionary and the released fish are simply hurled back into the river be it dead or alive. The end result being that the vast majority released salmon either sink to the bottom of the river dead with those that are alive being very lethargic resulting in the fish falling prey to marauding pinnipeds . Another element of release survival is that Grays Harbor is NOT the Columbia River, these are NOT spring Chinook, and the water temperature is NOT nearly as cool and conducive to releasing stressed salmon. Water temperature in the time and area proposed is 57 degrees F in the Chehalis estuary compared to 44 degrees F in the mainstem Columbia in early spring. That makes the proposed 25% release mortality for tangle nets in Grays Harbor completely invalid as studies in the Willapa have shown. Factoring in what we already know about how the fish are mishandled the proposed tangle net season is simply a continuation of the same WDF&W R-6 policies of falsely representing the impacts of all Grays Harbor Bay marine fisheries with the non treaty commercial nets being the most egregious.
6. WDF&W R-6 identifies Chum stocks not by stream of origin but rather as Grays Harbor Chum, which is not done with any other salmonid species. Utilizing only three spawning reaches on the East Folk Satsop and Stevens Creek, a Humptulips tributary, the combined spawner escapement is extrapolated to provide the projected spawner success for the entire Chehalis & Humptulips watersheds and future harvest opportunity in any given year. This methodology is extremely problematic as it incorporates the returning adults from the 400,000 hatchery released Chum smolt from Bingham and Satsop Springs hatcheries located on the East Folk Satsop that spawn naturally with the wild Chum spawners. The hatchery origin adult Chum spawning are a substantial portion of the naturally spawning population resulting in massively inflated success ratio for wild naturally spawning Chum adults in the East Fork Satsop. This grossly inflated wild spawner recruitment extrapolated for the entire Chehalis Basin and Humptulips River Chum stocks results in a fatally flawed methodology. This methodology has allowed and dictated the continued overharvest / exploitation of Chehalis River Chum stocks above the Satsop River. This problem is not unknown to WDF&W R-6 as it has been identified by WDF&W's Science Division in the Ecosystem Diagnostic Tool potential projects report and others. In simplest terms the current WDF&W R-6 management of Chehalis Basin Chum harvest continues to decimate naturally spawning stocks of Chum and push many Chehalis tributary stocks above the Satsop River to the point of extinction.
5. The management of Chinook stocks in the Chehalis Basin is in such disarray that Chehalis fall Chinook have only exceeded the minimum escapement goal twice in the previous 11 years and only 3 of the last 15 years.
This is complete failure of management. Ron Warren was very defensive and unprofessional when I pointed this out at the NOF meeting.
5. The management of Chinook stocks in the Chehalis Basin is in such disarray that Chehalis fall Chinook have only exceeded the minimum escapement goal twice in the previous 11 years and only 3 of the last 15 years.
This is complete failure of management. Ron Warren was very defensive and unprofessional when I pointed this out at the NOF meeting.
Yup. Probably less telling, but possibly more unprofessional, was Warren's snide response to citizen complaints that, despite what appeared to be banner coho returns, anglers had a tough time catching fish in the rivers. His response was (paraphrasing), What do you want me to do? Jump in the river and put a salmon on your hook?
It's pretty clear that Region 6 staff is directed to maximize the non-tribal harvest. Unlike most of the season setting meetings, the public is allowed to participate in NOF. As Rivrguy demonstrates, we're effectively only observers there, too.
The pilots of the Asiana plane goiung to SFO flew the plane by the (pre-season) models-all the various automatic controls. Even after taking them off they apparently ignored the Real-World data. They were too low and too slow (run not materializing as expected). They took action at the last moment (closed the in-river sport fishery) and still broke off the tail (missed escapement).
In fish management, as in flying a plane, real world data and hands-on management seem to be needed. Unfortunately, this is expensive, time consuming, and may result in "aborting the landing"-closing a bunch of fisheries.
Or, keep flying on autopilot; it works most of the time.
The question was asked of R-6 " Nothing was discussed about the amount of Commercial boats that will be moving North into the Willapa Bay and Grays Harbor fisheries. Could you please tell me what the affects will be? "
Below is the body of the e mail from R-6 in response to the question. Now the model already under estimates NT Nets by 250% the past four years, just imagine what the increased number of boats fishing would do to the models accuracy! Do not know where they would fit them all but silly me did not know where 22 would fit in the river. Oh almost forgot. It took the gentleman several reminders and more than a bit to get the information.
The numbers are not formatted well but you can match them up to the categories.
RESPONSE: As to your question about the potential effect of effort transfer from the Columbia River to Willapa Bay and Grays Harbor, there is no way to know for certain what shift in effort might occur. The critical factor is that of the human dimension and as a biologist not an economist or psychologist I can only speak to data from licenses issued during 2012.
There were 248 salmon gill net licenses issued for Willapa Bay and Grays Harbor. Of the 248 licenses issues, 201 were active, the remaining 47 were voluntarily placed in a suspended status by the owner. Additional detail is provided in the table below.
License status
Grays Harbor Net / Willapa Bay / Total Active 47 154 201 Suspended 12 35 47 Grand Total 59 189 248
Possession of either license allows the owner to operate in the Columbia River. It is worth noting that of the 201 active licenses only 24 owners possess a license for both Willapa Bay and Grays Harbor. From that you can infer that there are 177 WDFW license owner that could operate in the Columbia River. As to the magnitude of a potential effort shift, in 2012 there were only 39 license holders who had no landing outside the Columbia River, in other words 39 of the 201 licenses operated exclusively in the Columbia. Of these 39 license holders 28 held a Willapa Bay license, so at most we could see an increase in the Willapa from 126 vessels to 154 or about 22% more than in 2012. For Grays Harbor the potential increase would be from 47 to 58 or about 31%. With the closure only affecting a portion of the Columbia and full opportunities in the SAFE areas it is unlikely that we would see a full shift in effort but some shift is possible.
Hope this helps, and again I apologize for the delay. Sincerely
I was asked to provide the models and here they are in the links below. Now the links take you to the FTC library and the manner in which they are displayed is confusing and not that great. Our data storage is bulk by pages but if you down load them off the website ( hit the little down arrow ) they come in as fully functioning Excel spreadsheets.
Here is template going around for objecting to the CR 102's for Willapa and Grays Harbor. As always it is best to draft your own objections but as so many are not familiar with the WAC process that sets seasons I thought I would put this out. Change or whatever you feel is needed or use this template but one should object. You can hard copy your objections to Lori Pruess at
WDFW Rules Coordinator 600 Capitol Way N Olympia, WA 98501-1091 Phone: 360-902-2930
Or e mail at lori.preuss@dfw.wa.gov
July 19, 2013
To: Washington Department of Fish and Wildlife
Re: Proposed CR 102 Supplementals for commercial gill net seasons in Willapa and Grays Harbor
I am a recreational license holder that fishes in Willapa Bay and Grays Harbor and their tributaries. I believe my license entitles me to fish and retain salmon just as much as does a license issued to a commercial gill netter. I do not believe it is proper for the Department to intentionally discriminate against one category of license holders in favor of another.
WDFW has historically allocated 75% to 100% of the Chinook, Coho, and Chum available for harvest in GH and the Willapa to commercial gill netters. At the same time, the number of fish actually reaching the spawning grounds continue to decline creating significant risks for future fisherman of all kinds. The current proposed season continues these improper practices by over-fishing with nets to the point the sportsman and the spawning grounds are shorted fish.
I and other sport fisherman purchase products and services from local small businesses in the areas where I am able to fish. The seasons currently proposed will prove as disappointing this year as it was last year. Many sport fisherman have stated they are not willing to spend the money to travel to fish in Willapa or Grays Harbor if these gill net seasons go forward as planned. The proposed seasons act to discourage tourism in the local towns around Twin Harbors and adversely affect the economy of the region.
It is disappointing that hundreds of citizens can say the same things over and over in meetings, hearings, and letters or petitions and have a public institution like WDFW simply ignore them. The two new proposals do not address the concerns that all those citizens raised with their objections to the first proposals announced earlier this year. Once again, WDFW has chosen to simply ignore the public.
I ask that you do not pass the proposed seasons and develop new proposals that are fair and equitable to those who hold recreational fishing licenses. I sincerely hope an agreement that ends the discriminatory treatment of sports fishing and the favoritism shown commercial gill netters regarding harvest allocation can be found.
Most importantly, for all fishing in these areas, are seasons that no longer over fish with nets. We must allow the fish needed to preserve and maintain the runs to actually complete their journey to the spawning grounds and/or to the hatcheries. Without allowing this cycle to function, the complete fishery in these areas will collapse.
What a travesty this would be, to see no more salmon running in these rivers.
I know it is not the Chehalis but it is last call to comment on the CR 102 Supplemental for Willapa. It is Grays Harbor on steroids as to mismanagement. Over 82% of the harvest will go to the commercials, nearly 9% of the TOTAL Chum run will be moralities tossed over the side and we are talking the total run not harvestable numbers. Pretty much more of the same. What is not normal is the reaction of the local community in objecting to and taking on the agency. Had a full room at the Monte hearing ( such as it was ) on the CR 102 and they are learning they do not have to take it.
From Barbara A Mcclellan WDF&W Region 6
We wanted to inform you that the written comments for the public hearing scheduled for July 23rd for the rules proposed in the CR-102 Supplemental filing for commercial salmon fishing in Willapa Bay has been extended to July 25th, which is two days after the public hearing. The Dept. wanted to provided additional opportunity to comment.
Today is the final day to object to the CR 102 Supplemental for Grays Harbor Commercial Gillnets for 2013. The information and links are back up this thread along with enough information to cherry pick yourself over the edge. Bottom line last year one individual ended up on the permanent record objecting to that fiasco ( and it was not me and that is embarrassing to say the least ) Look all your have to do e mail Lori Pruess and identify your objecting to the CR 102 Supplemental for Grays Harbor Commercial Gillnets for 2013. Use your thoughts or others but get in the debate. This problem with the commercial nets is a self inflicted wound on the sports side. As so many are willing to set on their butt bitching and unwilling to take 5 minutes to join the effort to roll back the commercial harvest abuses by Region 6, then the end result is what you see now.
As I have been known to do, to a fault, I wrote a novella. The subject line and opening paragraph clearly stated my intentions, so if that's all they read, it should get the job done.
The link is to FTC's North of Falcon page and the updated write up and documentation. http://fishingthechehalis.net/nof-process At the top of Latest Documentation are the comments on the Grays Harbor CR 102 Supplemental for the Grays Harbor Non Treaty Commercial Net Fishery authored by Tim called " Tim's Grays Harbor Opposition Presentation ". Interesting read as in Willapa it is the first time a blow by blow description of what WDF&W does in Grays Harbor has been put in writing!
This last call for the public process on the Commercial Gillnet Fishery CR 102 Supplemental which creates the WAC that is the commercial gillnet seasons. It is good to be present and object, it is far better to object and submit your written objections to the permanent record.
A public hearing for Grays Harbor rules will take place on August 6, 2013, at 10:00 a.m. Region 6 Fish and Wildlife Office, Conference Room 48 Devonshire Rd. Montesano, WA 98563
Lord, it is somewhere back in this thread but the proposed I assume your talking about is what was modified in the rules GH Commercial CR 102 on March 6th that was modified to the current CR 102 Supplemental which has to go through the formal process and be voted on by the Commission. http://wdfw.wa.gov/about/regulations/development.html#13-01-064 In written comments submitted at the hearing in Monte Tuesday the agency must respond to ALL citizen comments on the record to legal standards ( no smoke & mirrors ) in the required Concise Statement BEFORE the Commission can vote. Once the Commission votes off to the Code reviser and it becomes a WAC then 31 days for a citizen to legally challenge any or all the WAC before it becomes law.
It is a process that governs fisheries in GH & Willapa not the Dog & Pony show NOF.
From the Willapa thread as both Harbors are linked so a dual posting.
Was asked to explain a bit why Willapa is important. Well first if you do not separate commercial fishers by race or ethnicity both Willapa & Grays Harbor are managed about the same. No tribal in Willapa over 80% of the fish to commercial. Qin + Chehalis + NT nets = the same over 80% to GH commercial fisheries. The courts mandated 50% of the harvest to tribal fisheries in GH, no discussion, but the courts did not mandate over 80% of the harvestable fish to commercial fisheries. That is WDF&W and might I add I know of no place where the local communities have been bullied, ignored, just plain s--- on by WDF&W like Willapa.
Second up is WDF&W uses a completely fabricated mortality mix in the numbers to empower the commercial fleet in GH and Willapa. This thing where someone decides this is it, this is what we will use for mortality numbers with just plain zero relevance to reality needs to stop and right damn now! As luck would have it Willapa is first up this year.
From Swanson & Young in BC to Ashcroft in Willapa studies have shown that ain't no way no how that Chinook encountering a gillnet and then released survive at 55%. It they may be that 55% ( 45% mortality ) barely alive going over the side when released by the netters but the vast vast majority do not make maturity and spawn. It is no different for tangle nets with the unbelievable near 75% ( 25 % mortality ) WDF&W claims. Hell folks GH was where broodstocking Chinook with tangle nets was developed and then abandoned for one reason, MORTALITY.
Third is in both Harbors the models WDF&W is using are incorrect and they know it. It is intentionally disregarded in R-6 madness to comply with the old adage " the only good fish is a dead fish, on the dock, in a tote, and sold " . You put the definition on it but what do you call it when and individual stands in front of a roomful of citizens and proceeds to out line a course of action that he or she knows intentionally misleading, factually false, and intended to disguise the true end results. My Mom pretty much had a definition for that particular conduct when I was a kid and tried it which resulted in me getting my butt seriously kicked.
The hearing and how did it go? Well it was better organized, ran fairly close to the rules, and we even had LE present! As to content Willapa reared its head in testimony as the Gillnetters wanted to know seasons or lack of. Then the usual but even they are catching on that the so called Management Plan is nothing but a sham.
Sports side good input from all but the defining moment came when Softbite laid out a documented, in detail, with photos & drawings of the Gillnetter that puts his net in three feet of water allowing the lead line to anchor it on the mud ( essentially create one huge set net ). SB even submitted the E mail string to enforcement objecting! Bloody good job I think.
So it is up to WDF&W now as they have seven weeks to finish up the process which includes responding to all objections in the Concise Statement, adopted by the Commission, filed with the Code Reviser, and then 31 days before it takes effect. This should be interesting to say the least.
Now GH as outlined but Willapa is different. The time frame is the same to implement Willapa's Commercial CR 102 so the the answer is yes. Now the BUT factor and it is that the Commercial season is set to start the August 12th ( I think I may be off a day or so) and they have screwed around for six months and have run out of time to complete the WAC process. Here is a link to the entire process. http://wdfw.wa.gov/about/regulations/glossary.html
So now what? The only two options are no commercial Willapa season until the WAC is finalized or for the Director to attempt a Emergency WAC to open the Willapa Commercial Net season anywhere from this very moment to anytime he more or less chooses in the proposed season. Now that opens up a whole can of worms as there are legal requirements to how & when a Emergency rule can be utilized.
Doesn't sound like there is much justification to deem this an "emergency"
If the emergercy rule option is exercised, there is a provision to object within 7 days.
"Within seven days after submission of the petition, the governor shall either deny the petition in writing, stating his or her reasons for the denial, or order the immediate repeal of the rule. "
That still leaves a window to allow the first 84 hour opening to happen before rescinding the emergency rule.
This link is to the Concise Explanatory Statement requirements in the WAC process. In 2008 ( I think ) the Legislature altered requirements that agencies utilized ( they would cherry pick & ignore citizen input ) so they have to respond to each subject. They can group things up from different sources ( citizens ) but must respond to each issue placed into comment on the record.
I was asked to update the Chehalis fall season process and not much to say really. Nothing, not a peep from the co managers since the Montesano hearing on the Commercial CR 102 Supplemental. As to the QIN netting schedule I do not have a clue. So it is still wait and see time as after that innovative bit of rule making Mr. Anderson did in the Willapa I am finished with guessing.
Now to this little ditty below and as in many things it is the thought process that gets you there not what is said. This is a meeting between WDF&W & QIN technical staff in 2010. Nothing special until you get to Escapement Item 1 & 2. Now to item 1 in Red , " is there an issue? " You got to be joking has to be your first thought! Chinook seldom make escapement and the same with Chum. Steelhead ain't got a picnic coming either.
Item 2 in Purple "e.g. when we have underescapement, does this mean we are not meeting our escapement goal or that we are not obtaining enough data?" Good lord when you short the gravel with Chinook year after year and wipe out up river Chum stocks it is because they did not get out of the office and do enough redd counts?
The bloody fish do not stand a chance in R-6 with this management approach.
Technical Meeting: QIN and WDFW Scheduled Data and Location: August 20, 2010 in Taholah Please schedule for 9:30 or 10 am at the earliest; shall we work through lunch and everyone brings their food? WDFW participants will be Curt Holt, Barbara McClellan, Rick Ereth, Charmane Ashbrook, and likely Kirt Hughes
Management Related 1. Coho marine survival estimation used to forecast 2010 coho return, Larry Gilbertson 2. WDFW presents timeline for steelhead accelerated management a. Cooperation with QIN? Ability to get data sooner, scale data. b. Pre-season forecast on Sept 1 3. How can management process at technical level be improved? a. Scale data obtained and analyzed sooner b. Meeting deadlines (steelhead & salmon) c. Bingham Creek CWT collection at hatchery, was this an issue in 2009-10? d. Communication style –email, phone, prior notice?
  Escapement/ spawning survey related (note: many of these topics will be discussed by Rhoads and Holt previously on August 4th, 2010, and they will update us on their conversation) 1. By species, is there an issue? a. Chum b. Coho (e.g. WDFW sampling of Chehalis tribal catch) c. Chinook d. Steelhead 2. Data quality (e.g. when we have underescapement, does this mean we are not meeting our escapement goal or that we are not obtaining enough data?) 3. Maple Glen Chum HPA & and request for help trapping beaver and taking out beaver dams. 4. Chum escapement methods a. Curt provides one page handout on what was done before b. Charmane provides some initial results from analysis c. Plan a meeting to focus on just this topic? 5. 2008 Chehalis coho escapement, method change issue (Wynoochee Satsop or subunit) 6. Other suggestions? (i.e. How can escapement/ spawning surveys be improved?)
Other 1. Grays Harbor HAIP process and stock designation 2. Green sturgeon and ESA, WDFW has sent letter of intent to NMFS about WDFW fishery impacts 3. Lamprey estimates –WDFW received funding from UWFWS to extend steelhead surveys, trend for this year is downward
Good Lord. Don't know how they did it in GH but for PS the escapement goals were based on specific spawner survey arrays. In reality, the escapement number is really only an index of the actual number of spawners but if you do the same surveys every year the relationship between years would be similar.
Here is what an old WDFW scientist told me, regarding chum. The agency was finally recognizing that the escapement number used was actually a third to a hlaf of the real number. So, if we actually get the total escapement number we will have more fish to catch as the goal will stay the same. I asked him if he knew where the goals came from. He didn't. They were developed based on the spawner surveys that were giving the underestimates of the actual number. So, if the estimate is a half to a third of the real number, so is the goal as it was based on the estimate. Conclusion, a more accurate estimate does not give you a single additional fish to kill.
Obviously, by asking that question they don't understand how the numbers they are managing by were developed.
Link is to CR 102 supplemental and that is all officially acknowledged so it is wait to see what Mr. Anderson tries next. After the Willapa bit of BS we all have quit guessing.
To follow up a little here is the link to WDF&W Commission meeting August 2nd. In the Public Input section about three minutes in you get the GH Gillnetters bitching their collective asses off. My favorite bit is the one that objects to the harvest model understating the sports catch and omitting it does the same for the gillnetters and OVERSTATE the inriver sport catch.
After the that you just have listen to Mr. Anderson in the Directors report. Now the first few minutes is Joe Storh doing budget stuff then come Phil. First up Grays Harbor then Willapa. Typical Phil to the Commission or " lets baffle them with BS"
Thought I would take a minute to put up some info from the Willapa Management Plan regarding Chinook harvest as the sports / commercial / conservationist camps do the annual " kick the crap out of each other two step " in both the FTC & Willapa threads. So below is a statement in the plan by WDF&W regarding Willapa Chinook harvest and the numbers are similar for Grays Harbor.
Anyone see anything wrong with the numbers? Millions and millions of dollars spent both private and your taxes in the coastal regions ( Willapa & Grays Harbor ), land restrictions, jobs lost, growth management, water quality improvements all of these things for what? 68% of the Chinook returning are harvested before they even get to coastal waters. Add the Washington marine fisheries ( charter and troll ) and what you have is the local communities sport and commercial interest ripping into each other over the remaining 29%. The big loser? The fish! Conservation is always pushed to the side as the agency attempts to maintain harvest under extreme pressure from a wide variety of interest. You see the fish does not vote, cannot hire an attorney, does not contribute to the politicians campaigns that are elected to write our laws. It is frequently said " the system is broke " and offhand I would say the fish and local communities pretty much agree.
FISHERIES MANAGEMENT Fundamental to fisheries management in Washington is involvement in the PFMC and North of Falcon processes. The annual series of PFMC and North of Falcon meetings is the foundation for the development of all fishing in Washington including the Pacific Ocean, Columbia River, Strait of Juan de Fuca, Puget Sound, inland rivers, and coastal harbors and rivers. There are, however, more northern fisheries occurring in the coastal waters of Canada and Alaska, which substantively impact Chinook and coho originating from Willapa Bay. Agreements for these fisheries are governed through the Pacific Salmon Treaty where overall harvest limits on Washington stocks are negotiated. These fisheries in Canada and Alaska have historically accounted for 67% of total Willapa Bay Chinook harvested (figure 2). When coupled with terminal harvest rates that exceeded 70%, the overall harvest or total exploitation rate of Willapa Bay origin Chinook was near 90%.
Canada 44% Alaska 23% Willapa Bay Commercial 23% Washington Marine 1-4 6% Willapa Bay Recreational 3% Oregon 1%
Well folks the dance started August 15, 2013 on the Willapa legal action challenging the Commercial Gillnet Season. Here is the link http://fishingthechehalis.net/nof-process to the page on FTC that has a write up by Tim Hamilton, one of the petitioners. In reading Tim's write up you will notice the Willapa Bay Gillnetters Association filed a motion to enjoin the asking the presiding judge to allow the association lawyers to team up with WDFW to represent the interests of its members that fish the Willapa during the season.
Sorry about not posting sooner but everyone has been a little maxed out getting the legal issues corralled and then getting everything to the website for you.
On the PM side. No today is not a full blown hearing for a Temporary Restraining Order ( TRO ) but rather we file documents responding to the state's response to our filing the lawsuit. I think I just confused myself but I will do my best to get things out as soon as possible.
I just received notice that the judge has delayed the hearing on the Willapa Commercial Gillnet Fishery legal challenge until next week. WDF&W and Willapa Bay Gillnetters Association (WBGA) have worked cooperatively to flood the court with motions and briefs and it didn't allow the judge time for review. I will update everyone as soon as possible with the court's new schedule.
Not that I know of for either the QIN / Chehalis Tribal or NT Nets. Now the proposed CR 102 Supplemental for NT Nets is on the WDF&W website http://wdfw.wa.gov/about/regulations/development.html#13-01-064 but it sets as the Commission has not voted on it. Draw your own conclusions on that one as after Mr. Phil's shameless antics in Willapa I refuse to guess anymore!
Just got an oral report that this morning Thurston County Judge Wickham, who is hearing the Willapa challenge filed by Tim, Art, & Ron just threw out the gillnetters case filed earlier this year objecting to changes in the 2013 gillnet season in the Columbia. In that case, the CCA enjoined to argue along with WDFW to defend the changes made to the gill net fishery in the Columbia designed to prevent damage to the fishruns. Same judge as our case in the Willapa, just that WDFW is arguing on opposite side and "on the same team" with the gillnetters in the Willapa case. As they say....."The plot thickens...... More to come.
Just got an oral report that this morning Thurston County Judge Wickham, who is hearing the Willapa challenge filed by Tim, Art, & Ron just threw out the gillnetters case filed earlier this year objecting to changes in the 2013 gillnet season in the Columbia. In that case, the CCA enjoined to argue along with WDFW to defend the changes made to the gill net fishery in the Columbia designed to prevent damage to the fishruns. Same judge as our case in the Willapa, just that WDFW is arguing on opposite side and "on the same team" with the gillnetters in the Willapa case. As they say....."The plot thickens...... More to come.
That is disappointing that the court cancelled the hearing on Friday regarding the temporary restraining order. Unfortunately, the commercial fishing season is moving on as scheduled.
CCA intervened in the CR lawsuit- not enjoined. Enjoin has a very different legal meaning. Just saying…
Oh OK LL just put forth what I was given on the Columbia. As to Willapa that has been pretty much the agencies strategy from the git go. From the CR process to the courts just drag it out so you can not get at the season. Nothing new and most certainly not unexpected.
Little edit: Got back to my source and a oh oh moment and you hit it LL but it is paper blizzard time and things sneak by. Thanks for catching it.
There has been a flurry of motions and briefs filed by the Willapa Bay Gillnetters Association (WBGA) and WDFW's counsel from the Office of Attorney General. The AG handling the case for WDFW has comfirmed he is working as if on the same team with the firm representing the WBGA. The paper flying is amazing. As an example, WDFW has just filed new briefs amending its responses and the declaration of Region 6 manager Ron Warren to correct numerous errors in Mr. Warren's intitial declaration. The WBGA has filed a motion to strike portions of my declaration claiming, as one example, I don't have any personal knowledge that the public was upset over WDFW ignoring them in NOF and other proceedings used by WDFW to pass the season (I personally delivered petitions with hundreds of signatures and numerous individual letters of opposition to WDFW during the season setting process).
The revised filings will be posted on this page once we can sort through the growing mountain of paper being thrown at our side by WDFW and the WBGA.
Asked the guys pursuing the legal side of things for a update on the hearing and they forwarded the following.
The injunction hearing is set for Thursday August 29th at 9 AM at Thurston County Courthouse before Judge Wickham. It's only the beginning of the legal road and the only question at this point is whether or not the judge will close the season early this year or let it go on while the legal action plays out. Typically, it is a very short process. Judge delayed hearing date so he has had some time to read the lengthy briefs filed by both sides. Then, a judge will typically allow our side to go first for 10-15 minutes and then the other side the same. Asks questions and then gavels it down. Sometimes the judge will announce the decision orally from the bench and in other cases, let us know later. In this case, the judge will probably first decide whether or not the Willapa Bay Gillnetters Association will be allowed to intervene at this point in time. If he agrees to let them in, their attorney will be allotted some time as well. [i][/i]
Sorry I did not get this out sooner but the hearing challenging the Willapa Commercial Net Season was yesterday and Judge Wickham did not issue his ruling until today. Tim has a complete write up on FTC http://fishingthechehalis.net/nof-process along with all the documents. Look through everything if you wish but even if you do a quick read of the documents the complexity of this issue will be rather apparent. Boiled down Judge Wickham rejected a injunction as the request did not meet the legal standards required. He then indicated in his oral comments that the rejection of the injunction was not the end of the road but rather the issues are complex and will get a complete review and scrutiny as legal process moves forward. I urge you to read the posting on FTC that I linked to previously to get the full picture of the past two days in Thurston County Court.
My thoughts? I have many to sort out but at this stage I think it is a big THANKS Mr. Frawley, our attorney, for the huge effort he has put together for this effort and the PDR legal action. The same kudos for Tim, Art, and Ron for taking the issue on after so many years of pillage of the fisheries resource in the Willapa Estuary.
Well here is something I find interesting. This link https://docs.google.com/file/d/0B2tWjgmgVy3yT18zcktaQThHX0k/edit is to a spread sheet for Grays Harbor 2013 dated April 4th 2013 if I remember correctly and has the QIN proposed 2013 netting season. NOW THIS IS THE FIRST RUN NOT THE FINAL SO THE NUMBERS MAY HAVE AND IN FACT HAVE CHANGED. You will need to down load the spread sheet to get it fully functional and head to the page labeled MGMT Summary. What you will see is if it had been adopted along with WDF&W's proposed seasons the Chinook escapement would have been minus 1998 for a escapement of 10366 which is well below 12364. This was with NT Nets at 14 days with a 14.7% mortality for the released wild Chinook. The CR 102 Supplemental ( WAC ) modeled 7 days at 25% but I do not remember the impacts on the states side changing much.
So the read I get from the status of April when the QIN came to the table is that neither Chinook or Chum will make escapement on the Chehalis if both QIN and State fish their respective proposed schedules. Oh yeah almost forgot, the model spread sheet was obtained in a PDR request attached to a e mail. WDF&W Region 6 staff have refused to release the 2013 model with the QIN commercial schedule.
Here are the thoughts of another who reviewed the sheet:
It was interesting.
Comparing the total GH harvest of both Wild and Hatchery for the Quin April 4 schedule with the final Tangle net NT schedule gets the following percentage of the total harvest: Quin Chinook = 65.9% Quin Coho = 57.1% Quin Chum = 72.4%
I used total harvest because the NT and the Quin do not count the same way when allocating fish between rivers. The Quinn are just by location fished while the NT use CWT splits at each location.
I think the Quin net days are about the same as last year, at least in Sept and Oct. The Quin intend to take nearly the total harvestable Chum again and we plan to harvest another 3,607 NT Chum.
Idaho, and this is from a letter, outlined their fishing plans/history. Although this applied to trout, i think that you'll see a resemblance to salmon.
First, Fish Until Community Collapses Under Pressure (FUCCUP) then, Planning As Needed In Crisis (PANIC) followed by hatcheries Synthesis In Nature (SIN) and finally Restore Excellent Populations Emphasizing Native Trout (REPENT).
according to the author, they would go through regular cycles of FUCCUP, PANIC, SIN, and REPENT.
Looks like WA has the first part down pat, when do we REPENT?
Thought I would provide a link to a Montesano Vidette article on the legal action opposing the Willapa Non Tribal Gillnet seasons. It is a interesting read.
Those fishing Willapa have had limited success and I think I have the reason. So far this year the commercial nets have taken 9576 Chinook http://wdfw.wa.gov/fishing/commercial/salmon/landings.html and last year the total Commercial take was 9726 for the entire fall season. This time last year the Commercial catch was 6227 so you do the math. These are just the fish sold now and the agency does not care to release to the public the TOTAL impacts as the Wild Chinook captured in the nets and released have a 45% mortality in the harvest model. The true impact numbers are seldom released to the public and never put up on the WDF&W website.
Bottom line is little is getting through the Gillnet Armada! So much for Kirt Hughes provided court documents stating he would curtail commercial efforts if over harvest appeared to be a problem.
Salmo g - If the WB commercial fishery is a "wipe-out" fishery why are both the recreational and commercial fishers required to release unclipped Chinook?
With substantial wild coho and chum returns with established escapement goals and a new found concern about wild Chinook (especially from the Naselle) wipe-out fisheries are not compatible with wild fish management even on Willapa Bay. Maybe that is part of the problem; continued feeding the commercial seasons/catches has to come at the expense of the recreational fishery or the wild fish.
Based on what I saw last week (Sunday, Monday and Tuesday) the current commercial season structure has contributed to a substantial reduction in the recreational effort. The pressure I say last week was 1/4 to 1/3 of what I would have seen 4 or 5 years ago. The South Bend launch was never full (in past years there would be lots of trailers parking along the highway). On Labor launching shortly after daylight we were the 4th trail in the lot. On Tuesday at high tide slack (the traditional peak catch period) I counted only 28 boats between South Bend and to the point west of Tokeland.
A WDFW administrator once told me, in reference to the Legislature, not to look at what they said or what laws they passed; look at where they put money. Those were the true priotities and showed "Legislative Intent."
If the achievement of escapement goals was truly a WDFW priority then the goals would be achieved more frequently than they are.
I hear ya' about the "intent" to manage for wild Naselle chinook and WB wild coho and chum, but it's hard to me to take it seriously when I see the commercial GN schedule. Like Carcassman points out, if wild escapement were a management priority, it would happen. It's still a wipe-out fishery to me.
Here is the CES that was filed with the CR 102 Supplemental creating the fall Non Treaty Gillnet seasons. Little different than they presented to anyone.
 Area 2A - Will be open from 7 am to 7 pm (12 hours) on one-day during the week beginning October 6, 2013 using tangle net gear only; 7 am to 7 pm on two-days in the week beginning October 20, 2013 using gill net gear; 7 am to 7 pm on one-day in the week beginning October 27, 2013 using gill net gear; and 6 pm to 6 pm each day for two-days each week in the weeks beginning November 3, 2013 and November 10, 2013 using gill net gear. This schedule for Areas 2A results in a total of 4 12-hour openings and 4 24-hour openings; these opening will occur concurrently with openings in Area 2D.  Area 2B – closed. Area 2B is situated at the mouth of Grays Harbor. It has been closed since 2005 due to impacts to Grays Harbor chum and Chehalis River origin fall Chinook.  Area 2C – Will be open 7 am to 7 pm (12 hours) each day for 2 days in week starting October 27, and 1 day each for weeks starting November 3 and November 10. The schedule in Area 2C is a total of 4 12-hours days.  Area 2D - Will be open only in that portion of Area 2D east of a north-south line from the confluence of the Hoquiam and Chehalis rivers to Renney Island and north of an easterly line from Renney Island to Range Marker G located on the south shore of Grays Harbor from 7 am to 7 pm on one-day during the week beginning October 6, 2013 using tangle net gear only; remaining opening will occur in the entire area from7 am to 7 pm on two-days in the week beginning October 20, 2013 using gill net gear; 7 am to 7 pm on one-day in the week beginning October 27, 2013 using gill net gear; and 6 pm to 6 pm each day for two-days each week in the weeks beginning November 3, 2013 and November 10, 2013 using gill net gear. This schedule for Areas 2D results in a total of 4 12-hour openings and 4 24-hour openings; these opening will occur concurrently with openings in Area 2A.
Here are the changes side by side. Sorry about the lack of formatting but the first dates in each week are the proposed we knew about. The second is the latest.
Some commenters from the commercial fishing sector claimed that proposed WAC 220-36-023 as outlined in the final CR102 supplemental notice does not provide a meaningful opportunity to fish. They contend that Humptulips River Chinook are forecast at abundance large enough to provide full fishery opportunities. However, the current schedule does not provide any commercial fishing days in areas 2C, the northern portion of the Harbor. This is the area of the Harbor were Chinook impacts are primarily on Humptulips River origin Chinook. In response to the lack of commercial fishing opportunity on abundant Humptulips River Chinook, an alternative Grays Harbor commercial fishery schedule was submitted that provides opportunity for a commercial fishery in area 2C. An alternative commercial fishing schedule was submitted to WDFW during the August 6, 2013 public hearing. The alternative schedule deviates slightly from the WDFW proposal by moving days later in the season resulting in a 2 tenths of 1 fish increase in impacts to Chehalis Basin natural spawning Chinook. In doing so, a total of 60-hours of fishing time were added in Areas 2A and 2D, and four 12-hour opening in Area 2C. This change would alter the schedule in terms of days of fishing (increased slightly), areas of fishing (increased) and change the type of gear (more gill net and less tangle net gear). When modeled, the proposed revisions to the season keep the conservation outcomes within the total Chehalis Basin natural spawning Chinook impacts available for the WDFW managed commercial fishery. Below is a side-by-side comparison of the two alternatives. Daily openings in Areas 2A and 2D during October will occur 7:00am – 7:00pm (12 hours), during November the openers are 2 consecutive 48 hour periods which open and close at 6:00pm. In Area 2C, daily openings will occur 7:00am – 7:00pm (12 hours)
Areas 2A and 2D: WDFW Proposal Alternative Week beginning (statistical week): (41) October 6 2 (tangle net) 1 (tangle net) (42) October 13 1 (tangle net) 0 (43) October 20 2 (tangle net) 2 (gillnet gear) (44) October 27 2 (tangle net) 1 (gillnet gear) (45) November 3 0 2 (gillnet gear) (46) November 10 0 2 (gillnet gear) Total openings (hours) 7 (84 hours) 8 (144 hours)
Area 2C: WDFW Proposal Alternative Week beginning (statistical week): (44) October 27 0 2 (gillnet gear) (45) November 3 0 1 (gillnet gear) (46) November 10 0 1 (gillnet gear) Total openings (hours) 0 (0 hours) 4 (48 hours)
I was asked just what happened? WDF&W put into play a rule that had not been seen by anyone in the public hearings or NOF, that expands Chehalis netting from 7 days tangle nets (84 hours) to 8 days (144 hours) with only one day of tangle nets. Added four days in ( 2C ) which is the the Humptulips River area of the bay. So folks meet Grays Harbor fisheries management courtesy Mr Anderson.
If anyone had doubts as to how Region 6 functions under Ron Warren or the management philosophy of Jim Scot and Phil Anderson the doubt should disappear now.
I was asked just what happened? WDF&W put into play a rule that had not been seen by anyone in the public hearings or NOF, that expands Chehalis netting from 7 days tangle nets (84 hours) to 8 days (144 hours) with only one day of tangle nets. Added four days in ( 2C ) which is the the Humptulips River area of the bay. So folks meet Grays Harbor fisheries management courtesy Mr Anderson.
If anyone had doubts as to how Region 6 functions under Ron Warren or the management philosophy of Jim Scot and Phil Anderson the doubt should disappear now.
Thank God... I think Grays Harbor just avoided an economic disaster of epic proportions, much like Pacific County did when WDFW heroically saved their immensely valuable commercial fishery in Willapa Bay last month. The law of the land said they were too late, but they came through, just the same, just as they always do.
It's a good thing WDFW is there to protect the well-being of our communities. Without the dozen or so brave souls wielding their gillnets out there, our economy would surely be in shambles. Were they not out there, we would have had sport fishermen from places far and wide crowding our hotels, buying tackle at local sporting goods stores, eating in local restaurants, buying gas from local retailers... The list of horrors goes on and on. Thanks to Warren, Hughes, Anderson, and all the little people, we will once again be spared.
In all seriousness, more and more, I think the reason we never get anywhere with our arguments that sport fishing generates far more revenue across the state than commercial fishing is that no matter how bad they screw us, we keep spending our money anyway, just for the CHANCE to catch a fish. Until that well dries up (and they are right to assume that, as long as there might be one fish swimming, it won't), our arguments about economic impacts will only make them laugh. Our passion for the sport we love is our ultimate weakness.
North of Falcon process is nothing but a sham. Lot's of meetings, then to have Phil and his State paid dilo's do what ever they want...and the want is heavy on the side of the non treaty netters.
Don't anyone tell me that the North of Falcon process is a fair way to divide up the resource. Hell, Region 6 blows all the smoke about the goals of fish management then to have many of the rivers in Region 6 not make escapement year after year.
I was at the North of Falcon meetings and even some of the "special hand picked group meetings"........the schedule as it is now WAS NOT TALKED about.....
Shame on you Phil, Ron, Curt and Barb.......Hope all of you "back up to the pay window"...cause you sure don't deserve the monies you supposedly work for.
North of Falcon process is nothing but a sham. Lot's of meetings, then to have Phil and his State paid dilo's do what ever they want...and the want is heavy on the side of the non treaty netters.
Don't anyone tell me that the North of Falcon process is a fair way to divide up the resource. Hell, Region 6 blows all the smoke about the goals of fish management then to have many of the rivers in Region 6 not make escapement year after year.
I was at the North of Falcon meetings and even some of the "special hand picked group meetings"........the schedule as it is now WAS NOT TALKED about.....
Shame on you Phil, Ron, Curt and Barb.......Hope all of you "back up to the pay window"...cause you sure don't deserve the monies you supposedly work for.
"No negative impacts to recreational harvest opportunity were identified."
Sounds like river recreational fisheries continue to be at best secondary fisheries that are only given access to those fish that are not caught in the "nets" or marine recreational fisheries.
Thought the following was insightful -
"The principal reason for adopting the changes is that they are responsive to comments provided by commercial industry representatives during the last comment period associated with the rule making process, while maintaining appropriate conservation and harvest opportunity allocation objectives."
Have to wonder if they would nearly as responsive to comments provided to the recreational during the last comment period.
I was there.........none of what I remember "sports" asking for.....got in..
It is very apparent to me that "Region 6 WDFW and the cowboys" are sleeping in the same bed......that includes PA.
I mean to go from 100% tangle nets, no cowboy netting on Humptulips side, to the gill season as it is now ....... "the fix was in".
QIN and WDFW can't get together, on netting season....latest ever on posting......We have major problems in Grays Harbor and Willapa. Commission needs to take a VERY close look, at allowing 1 person, PA, to have the power to control fisheries. Lot's of games being played, thousands of hours spent, thousands of $$$$$$$ spent only to be told, BASICALLY, F. YOU, we are going to weight the fishery, toward the cowboys.
Drifter - I agree given the current situation the best option to get serious discussion on priority changes for the two bay recreational fisheries is via the Commission's North of Falcon policies.
While this looks like a fight among the non-Indian users, consider that the Tribes would look bad to the public (remember that they are The First Conservationists) if they were the only non-selective fishery or the only ones fishing, period (close the Straits to rockfish, for example).
Recreational fisheries can be very targeted, release non-target fish, be off the water if conservation so demands it.
Consider how many problems would be caused in the rest of the State if Willapa had sport only, no wild retention, no chum retention unless there actually were harvestable fish. Sets a really bad precedent.
Drifter - I agree given the current situation the best option to get serious discussion on priority changes for the two bay recreational fisheries is via the Commission's North of Falcon policies.
Curt
Commissioners are well aware of the contentious fisheries in GH and WB.
They stepped up this past spring.... only to be trumped by the latest CR-103.
They have been duly notified of the latest development.
" The principal reason for adopting the changes is that they are responsive to comments provided by commercial industry representatives during the last comment period associated with the rule making process, while maintaining appropriate conservation and harvest opportunity allocation objectives."
That statement was the most ridiculous one in the CES. The hearing was to comment on the proposed CR 102 Supplemental and only that. Ron Warren at the March 29th meeting said Phil approved 14 days at 14.7 %release mortality all done no more input. Then at the following Advisers meeting came with 7 days at 25% release mortality and stated all done and will / did file CR 102 Supplemental. So everyone at the hearing testified as to the proposed CR 102 Supplemental commercial season. Here is the process on WDF&W's website. http://wdfw.wa.gov/about/regulations/how_to_participate.html This is HOW IT IS SUPPOSED TO WORK. http://wdfw.wa.gov/about/regulations/glossary.html
The APA process is rather straight ahead in most government agencies other than WDF&W. http://apps.leg.wa.gov/rcw/default.aspx?cite=34.05 One thing about it WDF&W R 6 it is innovative at the least but rather doubtful that they are in compliance with the APA guidelines but that never seems to bother them much. Following the law that is.
Drifter - Please note I said NOF policies - not NOF.
Every year the Commission asks for comments on that policy (C-3608).
The current version for Chinook and coho states -
"•The Puget Sound harvest management objectives for chinook and coho stocks, in priority order, are to: (1) provide meaningful recreational fishing opportunities; and (2) identify and provide opportunities for commercial harvest. When managing sport fisheries in this region, recreational opportunities will be distributed equitably across fishing areas, considering factors such as: the uniqueness of each area; the availability of opportunities for various species in each area throughout the season; the desire to provide high levels of total recreational opportunity; and the biological impacts.
•Grays Harbor harvest management objectives shall include opportunities for both the recreational and commercial fisheries.
•The Fish and Wildlife Commission’s policy on Columbia River Salmon Management (POL-C3620) shall guide pre-season and in-season planning of Columbia River salmon fisheries. Columbia River harvest management regimes shall be developed in cooperation with Oregon Department of Fish and Wildlife representatives.
•Willapa Bay harvest management shall be consistent with Willapa Bay Framework management objectives. The following general intent shall apply: Willapa Bay harvest management objectives shall include meaningful opportunities for both recreational and commercial fisheries.
•Pacific Ocean harvest shall be managed consistent with the Pacific Fishery Management Council’s Framework Salmon Management Plan and the National Standards that provide for fair and equitable allocation of fishing privileges among various fishers."
It seems to me a good strategy would be to try to get the "Willapa Bay Framework and the Grays Harbor harvest objectives on the table for discussion and potential modification. If indeed as eyeFISh suggest the commission is aware of the situation and the late modification in the CR-103 that was something other than what was thought to be agreed to we might be able to argue that more detail direction needs to be provide in policy C-3608.
Something more along the Policy guidance for Puget Sound where recreational fishing (and the economic value that produces) is the first priority would be a great start. That obviously would be a tough sell but that is the process that I see has the best chance of developing meaningful changes (from the recreational perspective).
Wk 40 2 days Wk 41 3 days Wk 42 4 days Wk 43 2 days Wk 46 3 days Wk 47 5 days
Now the ugly part. The QIN exercised their right to half across the bar but good ole WDF&W tried to stack in the Chehalis rather than pick up the slack on the Hump. ( numbers only now not if is a good or bad thing ) This resulted in 1987 Chinook to the minus for escapement with only 10,377 adults to the gravel. For those not familiar the Chinook goal is 12,364.
Straight talk time. The QIN have rights by treaty and confirmed by the courts. Done deal, period. The problem is not the QIN but rather WDF&W's absolute refusal to recognize that the QIN and Chehalis Tribe ARE the GH commercial fisheries. This thing that WDF&W R-6 is determined to maintain the " non Indian " commonly know as the ' White Boy Commercial " at all cost has gone way past ridiculous the last two years. If ever there was a doubt as to the total lack of any management of the resource by R-6 it should be gone gone gone. These guys could not manage writing instructions on how to use toilet paper without screwing it up.
If anyone wants the Fall Planning Model with the QIN dates in just PM me and I will send it to you.
I don't see anything on 2-c of the Hump updated on either the link or on the State's site. Anybody have any info on that? Am I just missing it somewhere?
Not absolutely sure, but I think this is actually better than what we had in October last year. November, however, when those nice, big coho are running strong, looks like an absolute slaughter. The NT nets will be done after their last day in November, but the QIN will be in 6 days per week the rest of the way for their "winter steelhead fishery."
I agree that the Tribe is only doing what the law allows in the fall salmon fishery, but I will NEVER be convinced that nets in the water 6 days a week amounts to 50% of the available catch in what is, despite being labeled a steelhead fishery, none other than the rape of the highest quality component of the coho run. This, in my mind, is where they should be challenged about their supposed commitment to sustaining salmon.
As for the NT gillnetters, well, Rivrguy has it pegged. They are legally entitled nothing, but their fishery is the one that cuts into our opportunity the rest of the season. Sickening.
Back out so no fishing but I did input the QIN seasons for the Hump into the model. Sooooooooooooooooo starting late in the game with the tangle net fiasco the state was running behind on window's of opportunity so they leave 905 paper Chum unharvested. Not to fear though as the QIN will harvest 8465 on paper to a deficient of 3607 but the states screw up let the paper fish 905 come off the impact for a total of 2702 or 12.9% BELOW minimum Grays Harbor Chum escapement. As the actual preseason forecast is not accurate due to counting hatchery Chum and naturally spawning Chum as the same fish one can assume the tributary stocks above the Satsop are just going to get nailed. Another year, another disaster, another dollar as Region 6 ambles down the path of destruction.
I knew there was a reason I stopped my home delivery of the Daily World.......so I wouldn't have to read bull xhit "letters to the editor", like that one.
September 20, 2013 Contact: Ron Warren, (360) 249-1201 Grays Harbor anglers required to release chinook Sept. 22; fishery to close for nearly a week Sept. 23 OLYMPIA - To help ensure spawning goals and management objectives are met for wild chinook salmon, anglers will be required to release all chinook beginning Sept. 22 in Grays Harbor Area 2-2 (east of the buoy 13 line) where the fishery will close for nearly a week the following day (Sept. 23). The salmon fishery will reopen Sept. 29 with a daily limit of three salmon, but anglers will be required to release all chinook. Ron Warren, regional fish program manager for the Washington Department of Fish and Wildlife (WDFW), said the changes were necessary to help meet spawning goals for wild chinook salmon returning to the Grays Harbor basin. "Angler effort and catch have been much higher than we anticipated since the fishery opened Sept. 16," Warren said. "With those increases, it was necessary that we take these steps to ensure enough wild chinook salmon make it back to the spawning grounds." Warren reminds anglers that Grays Harbor Area 2-2 (west of the buoy 13 line) is already closed to salmon fishing. For more information, check the emergency rule change at https://fortress.wa.gov/dfw/erules/efishrules/erule.jsp?id=1363 .
The rec community may feel dissatisfied over the loss of fishing access but many of us have beaten up WDFW over the wild Chehalis Chinook rarely making escapement. I think sports probably have exceeded the M.A. 2.2 modeled sport harvest of 572 total Chinook (530 wild). I also think there were few fish counts to back up the harvest estimate for this critical run. Overall I believe we should support this first attempt at in season management and any attempt to meet escapement.
Now contrast this action with Willapa where the modeled Naselle wild Chinook limits the overall fishery. The nets have taken 9,945 hatchery Chinook against a modeled 5,020 hatchery Chinook through September 8. The modeled season total of 8,046 hatchery Chinook has already been exceeded. This would indicate over harvest of the Naselle wilds as well. So what was the WDFW response? They quit posting the harvest numbers while the nets fish on!!!
OK this is the lay of the land as to escapement and the Fall Harvest Model. With the QIN seasons in ( R-6 refused to provide the model with the QIN in it so I put their season in ) Chehalis Chinook are minus 1987 and Hump is plus 1023. WDF&W does not separate Chehalis & Hump Chum Chum are minus 2702 for all of Grays Harbor and Chinook are 964 short Grays Harbor as a whole.
The root of this mess is the QIN get half of what comes across the bar by court decision. They are not required to manage separately for the two watersheds only for Grays Harbor as a whole. It was WDF&W that separated the two streams some years back in its management plan and these two methods are not necessarily compatible. When the QIN choose to max their harvest rights WDF&W must mold their impacts around the QIN court mandated harvest. WDF&W continues to choose not too but rather continue down WE STATE THEY INDIAN BIT road. Or to put it another way the state continues to try and impose their system upon the QIN's which is court mandated.
So we get this mess. QIN's fault? Don't think so. Can they do better? Oh he-- yes but with the attitude of WDF&W if I was a QIN fisher I would fly the bird right at them also.
I definitely agree that the Chehalis Chinook management is a mess, but there is really nothing for WDFW to mold to. If the department shut down all NT fishing in the bay and in all the Chehalis system rivers the QIN would still plan to take 3,370 wild Chehalis Chinook against a total harvestable 2,768 fish. It may be their legal right but an extra thousand Humptulips fish will do nothing for this years Chehalis escapement or for the future of the Chehalis system wild Chinook run. Two managers with different agendas just does not work for one resource.
Not sure I agree SB. To frame it right one has to factor in that the Chinook hatchery production is of broodstocked parents and most returning adult from that program spawn naturally. Same with the Hump and on average near 50% of the Humptulips Chinook are from hatchery origin parents. So the wild / hatchery separation is bogus as well the separation of wild / hatchery being very misleading. In fact WDF&W does not distinguish any difference in Chum at ......... all H or W same fish. Something I strongly disagree with by the way.
So we have in the Chehalis 3392 Chinook to harvest and Hump 5641 for a total of 9033 available for harvest. Now the Chehalis with the QIN in the model show 3370 QIN harvested Chinook or 20 left for the non treaty. Now on the Hump after QIN harvest 4378 are available for harvest AFTER the QIN have their seasons.
Then comes the moment of truth. The QIN know full well the state impact numbers are pure BS. It has been up on this BB and others including in writing to the Commission. The bay impacts are WAY under modeled, the NT Nets WAY under modeled and the inriver well you poor suckers will get about half what it says. Add to the huge hatchery cuts that gutted the Hump Tribal Coho fishery and does anyone really think they should believe anything WDF&W says? Be willing to compromise? I think not.
From designing a separate management plan to posting state seasons in March ( before meeting with the QIN ) to just plain fabricating harvest impacts WDF&W created this mess. While I do not agree with many many current QIN policies I certainly understand why they view things as they do. The QIN did not create this mess and it appears they have grown tired of dealing with a duplistic right close to dishonest R 6 staff.
The rec community may feel dissatisfied over the loss of fishing access but many of us have beaten up WDFW over the wild Chehalis Chinook rarely making escapement. I think sports probably have exceeded the M.A. 2.2 modeled sport harvest of 572 total Chinook (530 wild). I also think there were few fish counts to back up the harvest estimate for this critical run. Overall I believe we should support this first attempt at in season management and any attempt to meet escapement.
They have told us for years that in season management is not an option. They have continuously underestimated the catching power of the sport fleet even though they have been asked year after year to look at it and compare to the model. With a dismal king escapement failure of 13 out of 16 years, they should err on the side of conservation and not open for king retention when there are only a few hundred "paper fish" to fund the fishery. Those kings should be used for funding as liberal of a coho fishery as the plan allows. We are getting manipulated by their "generous" offer of king retention, but the real deal is that if we fish for kings, it gives tacit approval for the gillnetters to have more days. Once the model is updated to reflect the improved catching power of the sport fleet, meaning if we can get away from using "the 20 year average", and start using "the 5 year average", chinook retention will be a thing of the past until they manage to get the run healthy. Regarding this closure, their intentions may be viewed as good by some, yes they are protecting kings, but if the model was correct, and the management was proper, it would not have opened for retention in the first place, and the sports wouldn't be left with a bad taste in their mouth again, shut down for coho fishing on one of the largest coho runs in history.
F4B Yes and no. If the bay and the inriver sport had not taken those Chinook R - 6 would have simply made them available to the NT nets for increased Coho netting days. At this moment in time this is the simple rule. " All Paper Harvestable Fish Must Die " which drives the conversation on seasons front to back. Now if the model was made to reflect reality then yes but probably no sport Chinook bay season. Then again probably not much NT nets either as the 45% release mortality is just a pure fabrication. The two primary GH marine fisheries both have problems with accuracy in the model. QIN is the most accurate as to reflecting truly they will harvest. Inriver gets screwed and modeled well past what will really be caught but the two marine fisheries? Not even in the realm of reality.
After a little jiggle R6 has the Willapa commercial harvest up. http://wdfw.wa.gov/fishing/commercial/salmon/landings.html 15551 commercial Chinook caught so far and the model showed 13512 total sport & commercial harvest. Now there could be more fish or they were early, or they really had a lot of commercial effort or ............... well you can pick.
Now compare to GH and wella sports bay running ahead / shut it down. Strange how that double standard works.
I have to think the QIN has more than a little effect on the differences between the management of the two basins. If the State overfishes Grays Harbor, tribal fisheries are impacted (in terms of catch- not effort). In Willapa, only the fish suffer when overharvest occurs. The QIN can sue; fish cannot.
Had a little jump in PM as how this happened / what can we do? As to what just happened, WDF&W R 6 posted the Willapa landings after inquiries this weekend about why they weren't posted. http://wdfw.wa.gov/fishing/commercial/salmon/landings.html As of Sept. 22nd, the nets have landed and sold to buyers 13,551 hatchery Chinook.
The model shows shows WDFW had anticipated 8,047 net impacts and 3,015 Rec impacts (Marine & FW combined) for a season total for both user groups of 13,512. The commercial nets at this point are 5,504 over the predicted net impact at this point exceed and exceed the entire anticipated impact of both Rec and net seasons in the model for the entire year and we still have a way to go.
"Hughes, Kirt M (DFW)" <Kirt.Hughes@dfw.wa.gov> is the Fish Program Manager that filed a declaration in the court case stating he could make an "inseason adjustment" if the commercial season began to overfish and undermine the escapement goals. I'd suggest he be reminded of his assurance and CC the at commission@dfw.wa.gov
Lots going on with the Chehalis issues and I will update as soon as I can link to the documents on the FTC website.
Now this bit below is something else. Gary e mailed Kirt Hughes on the Willapa seasons and Kirt responded. ( best to read it bottom post up ) and nothing in his response was not true. What it was is pure 100% BS! The response from Kirt Hughes was intended to mislead and leave a COMPLETELY inaccurate picture of the issues and agency actions with Gary. As luck would have it Gary sought out help and that information is also in the thread.
So folks I would urge you to in the future do not go at R-6 and CC the Commission but rather go right at the Commission and CC R-6. That way R-6 has to meet the Commissioners standards for being forthright and honest. I think it is a better approach as it is clear that the standards the Commissioners have attempted to maintain do not exist in the District 17 ( Willapa & GH ) R-6 staff.
The E mail thread:
Not surprising. The dip in stuff is crappola. Here's some info for a response if you are so inclined.
The dip-in fishery is shown in the FRAM as July 22nd-August 15th. The FRAM predicted they would catch 1833 and they landed 2572. During the dip in they were over prediction by 739 fish. From Aug 16-Sept 22nd the FRAM predicted they would catch 6506. Instead, they caught 10,979 or 4,473 over expectation with the harvest overage occurring in September after the dip-in was long over. The over-whelming majority of the fish taken over the prediction is clearly Willapa and not Columbia fish.
In it's recent emergency rule WDFW stated "Catch and sampling information to date, suggests that the amount of effort and recreational harvest of Chinook in marine area 2-2 (Grays Harbor) will exceed pre-season expectations with no indication that the runsize is commensurately larger." The returns of upriver brights in the Columbia are coming in above the preseason forecast, the joint staff report created by WA & OR dated Sept 12, 2013 finds lower river hatchery returns for Chinook are coming in below expectations (http://wdfw.wa.gov/fishing/crc/2013/crc12sep13_facta.pdf). Willapa Chinook are not "upriver brights" and closely resemble the lower river hatchery Chinook found in the Columbia and those in Grays Harbor where you have already stated no evidence exists that would lead you to believe the run would be larger.
It is obvious your judgement of season conditions changes dramatically depending on whether it is the recreation season or the commercial gill nets that need adjustment.
My response from Kirt
Gary L Johnson -----Original Message----- From: Hughes, Kirt M (DFW) (DFW) <Kirt.Hughes@dfw.wa.gov> To: lk2thlite <lk2thlite@aol.com> Cc: Commission (DFW) <COMMISSION@dfw.wa.gov>; Warren, Ron R (DFW) (DFW) <Ron.Warren@dfw.wa.gov>; Scott, Jim B (DFW) (DFW) <James.Scott@dfw.wa.gov> Sent: Tue, Sep 24, 2013 7:35 am Subject: RE: Chinook Impacts & Overharvest in the Willapa Bay
Thanks Gary. Appreciate the contact. I am well aware of the catch. There is nothing nefarious about not posting the update prior to Monday. This is a time when staff are quite busy and our posting of the information is a lower priority than monitoring and sampling fisheries.
As you and I have discussed a before catch modeling is based on pre-season predicted abundance using recent harvest rates to predict future harvest. In our monitoring of the Willapa Bay commercial fishery we are seeing effort that is similar to our expectation. Early catch of Chinook is higher relative to prediction than later catches. And I can well imagine that you have seen dam counts at Bonneville. Passage has been particularly good, typically this feeds into early season catches in Willapa – the dip-ins.
From: lk2thlite@aol.com [mailto:lk2thlite@aol.com] Sent: Monday, September 23, 2013 6:51 PM To: Hughes, Kirt M (DFW) Cc: Commission (DFW) Subject: Chinook Impacts & Overharvest in the Willapa Bay
Dear Kirt,
Once again we are looking at a failure by WDFW and Kirt Hughes for in season management on the Willapa Bay. The facts are know posted with the numbers and the Commercial Harvest continues! This is not acceptable any more and I would like some answers of why this is allowed to continue and when will it end.
The first attached PDF is what the web site shows. As of Sept. 22nd, the nets have landed and sold to buyers 13,551 hatchery Chinook.
The second PDF is the FRAM cover page. It shows WDFW had anticipated 8,047 net impacts and 3,015 Rec impacts (Marine & FW combined) for a season total for both user groups of 13,512. The commercial nets at this point are 5,504 over the predicted net impact at this point exceed and exceed the entire anticipated impact of both Rec and net seasons in the FRAM for the entire year and we still have a way to go.
Received this in a E mail. Anyone know the details of the incident listed below? As it was dismissed I would think it was a thin charge or something else and I know little.
Yesterday we went to Tokeland & pulled my camper home for the season. We stopped in the Raymond dairy Queen for lunch. I picked up a copy of the Sept 26th Pacific County Press & on the "Police Beat" section, Frank M. Blake Jr. 58, Tokeland, failure to report commercial fish harvest/delivery, failure to record catch on receiving ticket; avoiding wildlife check station/inspection, failed to record catch on fish receiving ticket, dismissed. Why dismissed, unless WDFW agent did not show, or the judge was a brother-in-law?
Now this is about as good as it gets. These are E mail threads with first post bottom so read with that in mind. Now I am retired but if I had told my boss NO when asked to something my butt would have been in a sling. I think maybe Mr. Warren has a bit more than a little personnel problem with some of his staff.
From: Hughes, Kirt M (DFW) To: Warren, Ron R (DFW); Subject: RE: Chum Date: Thursday, March 07, 2013 7:05:00 AM
No!
-----Original Message----- From: Warren, Ron R (DFW) Sent: Thursday, March 07, 2013 6:50 AM To: Hughes, Kirt M (DFW) Subject: FW: Chum Can you develop a draft
From: ---------- Sent: Thursday, March 07, 2013 6:24 AM To: Warren, Ron R (DFW) Cc: Scott, Jim B (DFW) Subject: Chum
Mr. Warren,
After reviewing the Grays Harbor advisory meeting last night, ( March 6, 2013 ) I found the information provided to well short of what is needed to address Chum harvest for Grays Harbor as a whole or the Chehalis Basin. As a member of the Grays Harbor Advisory Group I am formally requesting to be provided the following information.
1. A 2013 Preseason Forecast for the number of returning Chum adults to the Humptulips River.
2. A 2013 Preseason Forecast for the number of returning Chum adults to the Chehalis River.
3. A 2013 Preseason Forecast for the number of returning Chum adults to the Satsop River.
D---
Second E mail:
From: Hughes, Kirt M (DFW) To: Warren, Ron R (DFW); Subject: RE: Chum Date: Thursday, March 07, 2013 7:07:00 AM
Allow me to rephrase that. I formally object to your request, but will draft a response.
-----Original Message----- From: Warren, Ron R (DFW) Sent: Thursday, March 07, 2013 6:50 AM To: Hughes, Kirt M (DFW) Subject: FW: Chum
Can you develop a draft
From: D----- Sent: Thursday, March 07, 2013 6:24 AM To: Warren, Ron R (DFW) Cc: Scott, Jim B (DFW) Subject: Chum
Mr. Warren,
After reviewing the Grays Harbor advisory meeting last night, ( March 6, 2013 ) I found the information provided to well short of what is needed to address Chum harvest for Grays Harbor as a whole or the Chehalis Basin. As a member of the Grays Harbor Advisory Group I am formally requesting to be provided the following information.
1. A 2013 Preseason Forecast for the number of returning Chum adults to the Humptulips River.
2. A 2013 Preseason Forecast for the number of returning Chum adults to the Chehalis River.
3. A 2013 Preseason Forecast for the number of returning Chum adults to the Satsop River.
On September 26, 2013, the second petition was filed objecting to the commercial gill net seasons set this year by WDFW. The second petition challenges the season set for Grays Harbor and the petitioners write up along with the court documents can be viewed here. http://fishingthechehalis.net/nof-process I will continue to update and provide additional information in the coming days.
One thing you may not be aware of is that a few years ago Ron Warren got promoted / transferred ? to Olympia & Kirt took over his R6 Fish Program Manager position. (By the way, Ron's wife works for the Personell Board in Olympia). Then when a personell cut was implimented because of funding cuts, Ron stepped back into his old position at R6, so Kirt then was slid back a notch.
You got RW up & down / left - right about half right & Penny retired.
This is a bit of an eye opener but to understand what is going on in the E mail one needs to get the lay of the land at that time. At the Montesano NOF public input meeting Ron Warren was bounced rather hard on the APA process http://www.ora.wa.gov/regulatory/rulemaking.asp and how he was representing it as one thing when it was really another. Now the sad part about that? In 2010 Lori Pruess notified Ron, Kirt Hughes, and Barbara McClellan that they could not alter the CR process without a redo. There is a set of internal guidelines that staff are supposed to follow also. http://wdfw.wa.gov/about/regulations/
Now that Ron Warren could have forgotten the Email from Preuss in 2010, OK maybe but ain't noway nohow Kirt & Barbara did as they are the District 17 ( GH & Willapa ) staff who fill out the forms many times each year. So they set there in Montesano knowing full well RW was putting out pure BS at the Montesano meeting. So fast forward to the March 29th NOF meeting in Olympia and prior to the meeting the gentleman that got into it with RW at the Montesano NOF concerning the misrepresentation of the legal side of the WAC process & NOF in general sends RW the E mail in the thread.
To the heart of the matter. First RW has no intention of responding at this point? When would he respond then? After everything is done? ( that is the normal WDF&W approach ) Second up is the fact that R -6 Fish Program manager is asking the WDFW Criminal Justice Liaison & Administrative Regulations Coordinator for talking points? What the h--- are we paying the District 17 staff for anyway? To do needlepoint? Third just look at the CC list in RW's E mail. Now that RW would want to make others aware of the difficulties he was encountering in the NOF / CR 102 process strikes me as a rather straight forward approach. Again the question, where and earth are District 17 staff at? Mars? To even start to do the CR 102 for the Commercial WAC they have to know what RW is looking for to present as talking points.
Now to Lori's response which I will highlight but as always read the E-mail thread bottom up. I cannot imagine her surprise when she received that request as it in all likelihood " made her day".
From: Preuss, Lori (DFW) To: Warren, Ron R (DFW); Subject: RE: My position Date: Thursday, March 28, 2013 4:56:00 PM
Hi, Ron. I really am not the appropriate person to ask for speaking points. I have never attended a NOF meeting or a NOF public hearing. Shouldn't your own staff be able to tell you what goes on at NOF public hearings and give you speaking points? Shouldn’t they know how a rule change should be presented to the public? I'm confused.
CONFIDENTIALITY NOTICE: This e-mail message, including any attachments, is intended only for the use of the individual or entity to which it is addressed and may contain confidential information that is legally privileged and exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly prohibited. If you have received this communication in error, please notify this office by telephone at 360.902.2930, and return this message to the Washington Department of Fish & Wildlife immediately.
-----Original Message----- From: Warren, Ron R (DFW) Sent: Thursday, March 28, 2013 4:21 PM To: Preuss, Lori (DFW) Cc: Hughes, Kirt M (DFW); Scharpf, Mike M (DFW); Mcclellan, Barbara A (DFW); Frymire, Bill (ATG); Long, John A (DFW); Thiesfeld, Steven L (DFW); Pattillo, Patrick (DFW); Scott, Jim B (DFW); Culver, Michele K (DFW) Subject: FW: My position
Lori, at least at this point in the process I don't plan on replying to Mr. Hamilton, but was hoping that you could provide me with some speaking points in case this comes up at tomorrow's meeting.
-----Original Message----- From: Tim Sent: Thursday, March 28, 2013 3:20 PM To: Warren, Ron R (DFW) Subject: My position
Ron- As a courtesy, I offer the following comments.
I've never attended a NOF meeting in Olympia before but I've listened to dozens who have. I find their description of past meetings very disturbing. Slide show presentations called "proposals" without any language of a proposed WAC change being made available. This puts the "horse behind the cart". A written proposal is typically laid out for a proposed change in a rule or law, then a slide show helps the viewer understand the effect of the expressed language.
Then, they describe how all present are denied any ability to express an opinion on the slide show presentation broken down individually to match the two separate WACs (rec & commercial). Worst, they describe how all present are pressured to vote on a proposal that has never been expressed in writing and again, both the unpublished proposals are somehow combined into one. In this type process, it can hardly be consider public input on a proposal as no one has ever seen a proposal and a slide show can not be substituted for disclosure of the expressed language of a proposal.
Finally, they describe extreme pressure from WDFW leaving them with the impression all present have to "vote" (not certain how this works as this is not a legislative body with any authority to pass law). Having to vote and combining rec and commercial seasons together denies anyone in attendance the ability to comment in favor or opposition of either WAC independently so no public input is provided on either one as well.
I find these comments similar to those coming from observers in the GH Harbor Advisory Group. So, from beginning to end, the 2013 and previous NOF processes do not conform with state law and procedures used in public input processes.
In closing, it is my position that WDFW has confirmed between 400-500 citizens are now "on the record" opposing the proposed commercial fishing seasons in Grays Harbor and Willapa during the WAC process underway and NOF process as well. Any "vote" held Friday in the NOF process will have to recognize those who have already voted no. One can not be required to be present in the room to participate in a public process. Therefore, unless all those on the record in opposition attend and reverse their position, no consensus can be reached regarding commercial seasons and selective fishing for nets in Grays Harbor and
Willapa unless that consensus rejects a selective fishing commercial net season in both estuaries.
PM requested I put up a example of R-6 District 17 staff being told that problems existed in the WAC CR 102 process. So I dug up this one and I will highlight Lori's feed back.
From: Sent: To: Cc: Subject :
Preuss, Lori (DFW) Tuesday , April 26, 2011 12:28 PM Hughes, Kirt M (DFW); Mcclellan , Barbara A (DFW) Ashbrook , Charmane E (DFW); Warren, Ron R (DFW) RE: WACS for OTS
Yes. I will send the WACs back to you when I get them from OTS, and you can make the changes then. I don't know if you're aware of Puget Sound Harvesters Association's (PSHA's) complaints about Jeromy changing his proposed rules weeks after he filed his CR-102, but you need to hope no one complains about you making substantial changes to your rules so late in the game. The version of the WACs filed with the CR-102s is supposed to reflect the rules as you intend them to be, not a best-guestimate. It is possible that the fallout from PSHA's complaints will cause people to finally pay attention to this. Just a head's up.
CONFIDENTIALITY NOTICE: This e-mail message, including any attachments, is intended only for the use of the individual or entity to which it is addressed and may contain confidential information that is legally privileged and exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, you are notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify this office by telephone at 360.902.2930, and return this message to the Washington Department of Fish & Wildlife immediately .
From: Hughes, Kirt M (DFW) Sent: Tuesday, April 26, 2011 9:00 AM To: Mcclellan, Barbara A (DFW); Preuss, Lori (DFW) Subject: RE: WACs for OTS Importance: High
Lori - I need to make a couple changes to what we sent on Friday. Is that still doable?
From: Mcclellan, Barbara A (DFW) Sent: Friday, April 22, 2011 2:51 PM To: Preuss,Lori (DFW) Cc: Hughes, Kirt M (DFW); Ashbrook, Charmane E (DFW) Subject: WACs for OTS
Lori, Attached are the 3 WACs where changes have been made in track changes from the CR-102 version that was filed in April and need to be sent to OTS for formatting. They are WACs 22-22-020, 220-40-027, and 220- 36-023.
Please send these to OTS to be formatted and send back to me when you get them back from OTS. When I get the formatted versions back from you, I will make sure to get them to John for the website because our hearing is set for May 10 and we are scheduled to meet with the Director on May 12.
I know you are on furlough today but our furlough was moved to Monday, the 25th. So I wanted to get these to you today so you will have it first thing Monday morning .
For those who've never watched the Chehalis Fling video and witnessed selective fishing (catch and release) with a net, I've been provided a remarkable report created by unknown WDFW staff on the behavior of the commercial fishers during a "tangle net" fishery installed in Willapa Bay in 2004. Lists problems with gillnetters by name and details how they are avoiding WDFW observers, not using the recovery boxes when out of sight of observers, offensive verbal commentaries, seals are hammering the fish in the nets and on and on and on. YOU GOTTA READ THIS THING! https://docs.google.com/file/d/0B2tWjgmgVy3yMW1vbEtKUTM3UHM/edit?usp=drive_web
It is a few pages long but if you ever had doubts about what happens when WDF&W staff attempt to monitor the Non Treaty commercial fishery this should end that thought. The first day out this season is " test " Tangle net fishery I might add.
This is a brief narrative of a portion of the 2004 Willapa Bay Tangle net fishery from observations @ Tokeland, WA. Started narrative the second day of the fishery, to record what appeared to be fishery that would be discussed at length sometime in the future, wanting to set down actual occurrences while fresh in my memory. Statements below can be corroborated by Steve Larsson, Steve Wargo, or Suzan Neari ng, Tokeland observers during this fishery. Allan Hollingsworth did not go out (called me the night before and said not worth it, he caught too few fish that day-Thursday@2 l coho and 4 or 5 Chinook vs. 60+ coho and 6 Chinook on Wednesday. Arthor Swanson in South Bend also contacted me after I left a message, saying he was also not going out. Didn 't want to tear up his Col. River net. I had called him because he was the only fishermen going out from South Bend, and I was going to place Steve Wargo on his vessel. Early Friday morning, Larry Christiansen (vessel Kristina) pulled out and headed north, towards Grays Harbor , his net real covered with a tight fitting wrap or tarp.
Friday, Oct 151-Andy Mitby and Eric were the only boats to go out and fish. They left the docks during midmorning. When first observed after launching the support boat, they were all the way west to near the deadline at the rock jetty and fished fairly far apart for the most part. Neither could get most fish in prior to getting robbed by a seal, which started to show up at both boat locations after the first drift. They both caught a few fish (approx 8 and 6 coho and a few chum, (pespectively) before giving up in disgust.
While observing the fishery Steve Larsson and I were impressed with the number of chinook and coho that were imaged on the fish finder offshore at the 65 foot (10 fathom ) line-they were thick from top to bottom of water column at this depth, and many coho were evident in the areas closer to shore (15 to 25 feet of depth)
Of all the boats signed up for the fishery in Tokeland, only Andy or Eric Mitby ever fished the first day. In Nahcotta, only Gary Walters and one other boat went out for a brief time. Only a few salmon caught, Gary Walters shocked the observer by systematically whacking every spiny dogfish in the net against the side of the boat prior to their release (information I past onto Dan Klump when I contacted him that evening). Other than these general recollections, I do not want to try to record further occurrences during first day of fishery from memory, but it was similar to what I observed that occurred on Saturday, the next day of the fishery (at least at my location in Tokeland).
On Saturday, Oct 2, 2004 I was supervising the observer crew assigned to sample the tangle net fishery. Steve Larsson and I arrived at Tokeland Launch at approx 5:15 AM. Suzan Nearing already there, Steve Wargo pulled in right behind us. Talked for a few moments, then settled back and waited for fishermen to show up, as we have since the first day of the fishery. At least twice before full daylight, vehicles drove close enough to observe that we were in fact there waiting, and then turned around and left the area. During the day, checked on several people going to and from their vessels, but were told they were not going out, but would pull out later in the day, getting ready for the Grays Harbor fishery. Viking(?) did pull out later in the day. The Kimberley pulled out, then was re-launched in the afternoon
At approximately mid morning, Andy Mitby came by and asked if he went out, would he have to take an observer. I told him yes, and he informed me it "then was not worth it to go". He told me that " you know that without an observer, he would do much better, but with an observer, it was just not worth it to go out. ...you understand ." He then left. He came back a short time later, with his crewman, and said he was going out. And he then requested that Steve Wargo was who he wanted on his boat. As he was making preparations to go out, I sent Steve to the dock and he got aboard. The Brothers Three then left the dock. I waited approximately 25 minutes, then Steve Larson and I launched the support boat, and went out to observe the Brothers Three in action. As we got within sight of the boat, they were finishing a drift. In the last 100 feet of net, I observed a large Chinook in the net, tail up. Andy Mitby expertly extricated the fish from the net, which was still very vigorous, and slipped it back into the water. A nice job .
When I came around to view the other side of the boat , I could see that the fish box was flowing with water, ready to receive any distressed Chinook (none were in the box) . They shut the pump down and motored back northwest along the beach for another set. They were just above marker 15. However, during the next 2 full sets (both fairly short duration soaks) and a short partial set (also short soak), the pump was NOT on at any time. The box had no water flowing through it while the net was set out or retrieved during any subsequent sets. This was while Andy knew I was observing him from Jess than 200 meters, with binoculars.
During one set, Andy untied from the net, and motored along its length to the midway point, trying to beat a seal to several fish in the web. Later he came back towards the seaward end and retied , after also losing a race to at least one fish at that end . Steve Wargo motioned me over at this time. We cruised up to within a short distance of the fish and Steve asked me what should be done with a CHINOOK that had it's head bitten of by a seal that was in the boat. I told him that it must be put back into the water. At this Andy became somewhat agitated, and said that he thought that was wastage . I told him that the WAC stated all Chinook must be released . He obviously did not like the answer I gave him . I asked him what he wanted me to do. He said that he thought he should be able to keep the fish, that it was wastage (which was against the law) to put it back . I told him he might consider it wastage, but others would not.
We then motored some distance away, and Andy reset. I observed Andy to then put into the water two fish that appeared to be partial fish, as he was getting ready to pull his set. After finishing with this brief set (losing some more coho to seals), he motored out to me on his way back in and continued the discussion of the "wasted" salmon. When he again commented that he thought it was wastage, that he thought he should be allowed to keep the fish. He said since he had a State observer on board, and that I also saw the fish, it was obvious that he was not trying to "work the system" and was being completely honest. He just thought it was wrong to put the fish back. I told him that a seal started on it, and if put back, a seal would finish it, that the fish would not go to waste . He was not impressed by my logic.
Shortly thereafter, he returned to the dock, done for the day. He told me over his shoulder while motoring away that he would be out tomorrow. Andy was the only one to fish the second day of the fishery. Eric Mitby had a ballgame practice with his son, or some other conflict, so he did not go out.
Although this second day is the day I started this narrative (the Oct 1st events in top paragraphs were drawn from memory) upon Dan Klump's strong suggestion , it was obvious to myself, and the other observers, throughout the preceding discussions with Andy, Eric Mitby and others at the parking lot that they believed the tangle net is a failure, as far a fishing in Tokeland anyway. Andy told me the day before, that it is too rough usually to fish a tangle net in the area he was fishing, that fish drop out too easily, and that there were too many seals around to allow any sort of reasonable fishing effort (my wording for his thoughts) . Several times they admitted to their observers that there "were a lot of fish out here", and that they could have done great without an observer onboard and use of a tangle net. It was very obvious that fishermen were waiting to see if we would leave, and then they would go out, without observers .
Andy Mitby admitted as much several times to Steve Wargo,. He could not believe we would wait around for the full 12 hours, just to observe one boat (he and/or Eric or anyone else) for the full period of the fishery. When he asked Steve if Enforcement would also be around , and was told yes, he was incredulous. "You mean they would come out just to check on only one (my) boat out there?" Steve told him yes, and Steve said he seemed disappointed at that prospect.
Additionally, while talking with Suzan Nearing about her observations the day before , she told me that although Andy had set the live box up, checked its operation and primed the pump before taking of from the dock, at no time was the pump and live box operating while he had made his sets the day before. I told her that was a violation of the WAC for this fishery, and she was very sorry that she had not read through all the information I had supplied her with the night before. She said that Andy told her he "didn't need his pump on, because he was not getting any fish in the boat." Andy and Eric lost numerous fish to seals the first day of the fishery (and Andy lost "a lot"today-Saturday-as well), and coho were observed to also drop out of the net prior to coming on board. Andy also had a seal almost take a nice chinook out of his hands as he was carefully releasing it out of the net. This infuriated Andy. Eric and Andy said they could not understand why they were not allowed to use gear like in Grays Harbor fishery, with a damn observer. That these tangle nets just didn't work here, and there were way to many seals to effectively fish this gear. When I asked if a larger number of boats out fishing would have helped keep the seals off the nets somewhat, they would not answer me. This is an important point. The fishermen DID successfully do this during the regular season fishery. During the regular season, after morning checks of fish at Nelson Crab, I observed boats from the area near the western boundary, and near "Pamper Beach" (Buoy 15) near Nelson Crab using the "multiple boat tactics" during the regular season. Boats would be taking turns lining up for a drift. With others waiting their tum, there was enough traffic and movement that the seals stayed way from the nets to a large extent. So why didn't they use the same tactics now?
Similarly, many of the comments from observers stationed in Nahcotta showed that many did not want to participate in the fishery, because "that would prove that the State was right, so were not going to do it, they are just screwing with us again, they don't give us anything." Also, that these net were very expensive, and they were not going to rip them up for only a few fish. Speaking to a sampler prior to finding out who they were, one fishermen said they would have gone out, damn the regulations, but the damn State had observers at the Harbor, and they could get out without being observed. Mnay fishermen at both ports were unhappy with this fishery even being set up, and didn't appreciate Bob Lake or whomever it was that pushed it through.
Contacted Dan Klump and explained situation, asked if Enforcement would be available Sunday, but he said no. However, that they would try to get someone to patrol fishery at Tokeland (my suggestion) for Monday, when samplers would probably be gone. I expressed my desire to have Enforcement make this a top priority, due to the likelihood of illegal activity in the absence of observers. I asked him to launch at Tokeland, and make their presence very obvious. He said he would work to get someone out there for Monday.
Sunday Oct 3rd. The same pattern of the last few days-slow vehicle prowls in early AM to check on our presence, and then no netters going near the docks, except to work on their boats for Grays Harbor, (or the next Willapa Bay opener), or to check on equipment repairs. Discussions with several fishermen-not worth it to go out, too many seals, net rules B.S., etc. etc. etc. Stayed until 5:45 PM. Everyone asked us at every opportunity if we would be there Monday. I said yes. It was obvious to myself (and the observers) that at least some portion of the fleet was waiting for us to leave early, and they would then go out. When questioned about Enforcement, I told them that Enforcement did not clear their plans with me, but I assumed they could be around at any time the fishery was open.
Upon returning to the office, I left messages with Dan Klump, & Sgt. Rhoden about the need to patrol Tokeland on Monday, due to possible absence of observers (into overtime pay due to 3 days at +12 hour days). Called Ron Warren, explained situation, and got verbal authority authorizing overtime for observers IF they felt comfortable doing this without my presence for backup. But he did not want people to feel they were putting themselves at risk, or for undue verbal abuse.
Contacted Steve Wargo, who said he would sample Tokeland on MOnday. Left messages for Suzie Nearing to also have her repeat tomorrow, but had received no answer as of 9:15 PM. Contacted Rannele Reber, but she and Freider Mack were schedules to work for Wendy Beegley tomorrow. Contacted alternate observer Kim Andersen, but she also was to work for Wendy on Monday. However, she was willing to go, and would contact Wendy to ask permission to go to Tokeland. Kim called back at AM, said she could (not) go. I then contacted Ron Warren again to tell him of my efforts, and that Steve Wargo was willing to sample alone if needed. I left for home at 10:15 PM.
Monday Oct 4th, I received a cell phone call from Suzan Nearing at 7:20 AM while on my way to the Montesano office. She apologized for not getting back to me sooner. She had turned off her cell phone the night before, thinking we were done with the observer project. She said she was willing to go out to Tokeland to sample boats, even though it was after 5 AM . I said that I thought it might be helpful if she did that, she might catch a late entry.
OK numbers are up on the WDF&W website for Commercials so far Willapa & GH. http://wdfw.wa.gov/fishing/commercial/salmon/landings.html Early in the morning so the calculator might have missed a number but I do not think so here is what I got. Willapa Coho harvest total this time last year 14,583 / this year 5189. Same time last year GH QIN Coho total 5060 & this year 1688. For the QIN numbers they were impacted by the flood and word is on the incoming yesterday they got fish but we will have to wait and see what the total is when they post next week.
Now this is scary as in the Willapa floods did not effect NT Nets catch that is around 35% of last years. Now the QIN is 33% ( give or take a fish ) and if GH follows the Willapa pattern at all the fish are in deep crap with the combined tribal & commercial catch.
So much for Kirt Hughes sworn statement on Willapa submitted to the court that he could do a in season adjustment if he thought a problem developed. I guess the question becomes just what does he call a problem? When the escapement number reaches zero?
Was asked if in my PDR documents I have not released some. Yup! There were a couple that were hysterically funny to be sure but if the documents were personal interactions between staff, internal personnel administration, or a oops moment I have not put them forward. I have no problem with confronting R-6 District 17 staff on their actions and policies but I stop right there. Our efforts at FTC are about the fish and local communities not the occasional personal differences that any group of people working together will have.
To business. Now this one is good. If you read the paper below it sounds OK but what is wrong? Tangle net moralities in Grays Harbor are WAYYYYYYYYYYYYYYY more than what is represented. How do I know? The local communities volunteers attempted use tangle nets to capture Chinook and ABANDONED that method due to high moralities. If Chinook and Chum survived the initial encounter the majority would not survive to spawn. Females in particular took a hard hit in survival numbers and this is utilizing specially designed platform boats, revival transport tubes, floating recovery netpens. Not dragging them over the bow ripping them from the net and hurl the captured fish over the side of the boat.
What is written by R-6 District 17 staff below is not even close to reality. My favorite is moderate differences between Columbia Spring Chinook river conditions and those that exist in Grays Harbor in the fall fishery. Lord what planet does whoever wrote this live on? The most appalling thing? This unadulterated piece of utter BS and fabrication was for the Commission.
Commission Speaking Points Grays Harbor Management April 12, 2013
Tangle Nets and Mortality o Commercial advisors have proposed the use of tangle net gear for fall commercial salmon fisheries in Grays Harbor this year. o The applicability of tangle nets and associated release mortality rate is based on recommendations of the U.S. v Oregon Technical Advisory Committee for use in Columbia River commercial net fisheries requiring the release of unmarked Chinook. Their recommendation of 14.7% was adopted through the Columbia River Compact process. o There is a significant reduction in the mortality rate resulting in a shift from 6” maximum gill net with 45% release mortality, as used in previous years, to this year’s proposal to use 4-1/4” tangle net and the documented 14.7% mortality resulting from this gear type. o Moderate differences in environmental conditions exist between Columbia River spring Chinook and Grays Harbor fall Chinook fisheries. We have considered these differences and find them similar enough for the application of tangle nets and the associated mortality rate. o However, the uncertainty surrounding the environmental conditions and the first time use of tangle nets in Grays Harbor cause us to take a more conservative approach in Grays Harbor by applying a buffer to the release mortality rate and increase it to 25.0%.
Accuracy of Predicted Fishery Mortality o Given low abundance of natural origin fall Chinook returning to the Chehalis River in recent years, limited harvest opportunity has been available in both marine area and freshwater sport fisheries. At the same time WDFW managed commercial fisheries have been developed for more abundant coho returns while requiring Chinook release in commercial catch areas 2A and 2D. o It is worth mentioning that the fishery planning model used to estimate fishing related impacts has as well as the run reconstruction the model is bases on have been redeveloped for use in 2013. The new models incorporate stock specific allocation of harvest based on coded wire tag sampling that is specific to the commercial catch management area where the fish were caught. Therefore the productiveness for modeling the outcome of historic fisheries has been evaluated to test the accuracy of the new model. Doing so removed potential biases associated with historic models that did not appropriately allocate catch by stock origin. Evaluating performance using post-season runsizes removes biases of forecasting error.
Now take a quick read of this e mail thread and wella you have the scientific rational for the mortality they put in the Commission paper. As always read the e mail thread bottom up.
From: Hughes, Kirt M (DFW) To: la cc: ac Warren, Ron R (DFW); Scharpf, Mike M (DFW); Mcclellan, Barbara A (DFW); Subject: FW: 2013 gh season Date: Wednesday, April 17, 2013 10:44:00 AM
B – I got a bounce back on the address in the message from A---. I have also included Mike in this thread. -Kirt
From: Hughes, Kirt M (DFW) Sent: Wednesday, April 17, 2013 10:42 AM To: 'a'; Warren, Ron R (DFW) Cc: B; Mcclellan, Barbara A (DFW) Subject: RE: 2013 gh season
A--- – Speaking only to the application of 25% release mortality, there was an additional 10.3% added as a buffer. The is nothing scientific about the 10% it is simple a buffer intended as a precautionary approach in bridging uncertainties in the physiology on fish and the environmental conditions they are encountering at time of capture. Specifically we note the difference between spring Chinook in the Columbia River and fall Chinook stocks passing through the Grays Harbor estuary and differences in characteristic of the water including temperature and salinity.
I certainly apologize for not making contact with folks as previously developed schedules were being modified as a result of the change in mortality rate.
-Kirt
From: a------- Sent: Wednesday, April 17, 2013 10:31 AM To: Warren, Ron R (DFW) Cc: B; Hughes, Kirt M (DFW); Mcclellan, Barbara A (DFW) Subject: 2013 gh season
Ron,
When we left our last meeting we had an agreement on the
recreational and commercial GH seasons. If things were to change we were to be called and asked about what changes may occur. In your new proposal we trade thirteen days with regular nets for two with tangle nets. If the Humptulips is tier 4 tier 4 and we have no days in that area we have not met any criteria from the tier system in that area. Who was notified about these changes when they took place at PFMC? The state numbers are 14.7% mortality rate on Chinook in tangle nets. We will be assessed 25%. Where did this rate come from?
Failing to see why we had any advisory group meetings, A---
I posted the bit below ( high-lighted ) in the other thread by mistake so catching up. That said I was asked what is the importance of the WK 41 On Board Observer reports. Well it is about the mortality or number of adult Chinook that will not survive the contact & release from the NT Commercial nets. If you recall first WDF&W R-6 D-17 went with 14.7% and that did not fly so on to 25% in the last model. If you look at the report 67% of the adults were OK ( vigorous ) and 33% either dead or on their way to being dead. Now this is the immediate ( or close to ) mortality. In the best scenario in the Columbia it was 1% to 3% immediate mortality followed by another 13.7% that did not survive to spawn. Some studies have it as a much higher % moralities on the post release survival. Bottom line is the mortality is somewhere 47.7% and 70% of the released Grays Harbor Chinook are goners. Now this is the best as the Chehalis is not the Columbia and Chehalis Fall Chinook are not the same as Columbia Springers. This is important because if the actual impacts are put into the model it means less time for the NT nets. So the NT days based on a 25% figure pretty much are and continues to be pure bs as a lot of people have been saying. It is called " cookin the books"
The link is to WDF&W website for commercial. http://wdfw.wa.gov/fishing/commercial/salmon/landings.html Now as I am NEVER shy about kicking the cra- out District 17 staff I must put this out also. When you get to the website scroll to GH Non Indian and look for the Weekly Observer Summary and hit the WK 41 link ( it is a link ) and it is the encounter ratio Onboard Observer report for Chinook, Coho & Chum. Now I can tell you they did not do this without prodding. That said it was requested and without any fanfare Mr. Warren, Kirt Hughes and staff got it done.
So on this issue I sincerely thank R-6 D-17 staff for the change and effort.
WDFW NEWS RELEASE Washington Department of Fish and Wildlife 600 Capitol Way North, Olympia, WA 98501-1091 http://wdfw.wa.gov/ October 17, 2013 Contact: Ron Warren, (360) 249-1201 Public meetings scheduled to discuss Grays Harbor salmon management OLYMPIA - The Washington Department of Fish and Wildlife (WDFW) has scheduled eight public meetings this fall and winter to discuss and develop a new draft policy for managing salmon fisheries in Grays Harbor. The public meetings are part of a nearly five-month process to develop the new draft policy specifically for Grays Harbor salmon management. The Washington Fish and Wildlife Commission, a citizen panel appointed by the governor to set policy for WDFW, is scheduled to consider adopting the draft policy in mid-February. Salmon fisheries in Grays Harbor are currently managed under a framework that was initially developed in 2007, in conjunction with the commission's North of Falcon policy, said Ron Warren, regional fish program manager for WDFW. "We would like to further refine the management of Grays Harbor salmon fisheries to help ensure we can meet spawning goals for wild salmon returning to the basin, as well as give anglers and commercial fishers a clearer picture of what fishing opportunities they can expect each year," Warren said. The public meetings include three workshops and five Grays Harbor Advisory Committee meetings. The advisory committee discussions are open to the public, and those in attendance will have an opportunity to comment at the end of each meeting. The public meetings are scheduled for: • Oct. 21 - Grays Harbor Advisory Committee, from 6-8 p.m.; public input from 8-9 p.m.; WDFW's Montesano office, 48 Devonshire Road. • Oct. 28 - Grays Harbor Advisory Committee, from 6-8 p.m.; public input from 8-9 p.m.; WDFW's Montesano office, 48 Devonshire Road. • Nov. 1 - WDFW fishery managers will host a public workshop from 6-8 p.m.; Montesano City Hall, 112 North Main Street, Montesano. • Nov. 13 - Grays Harbor Advisory Committee, from 6-8 p.m.; public input from 8-9 p.m.; WDFW's Montesano office, 48 Devonshire Road. • Nov. 18 - Grays Harbor Advisory Committee, from 6-8 p.m.; public input from 8-9 p.m.; WDFW's Montesano office, 48 Devonshire Road. • Nov. 26 - WDFW fishery managers will host a public workshop from 6-8 p.m.; Montesano City Hall, 112 North Main Street, Montesano. • Jan. 13 - Grays Harbor Advisory Committee, from 6-8 p.m.; public input from 8-9 p.m.; WDFW's Montesano office, 48 Devonshire Road. • Jan. 15 - WDFW fishery managers will host a public workshop from 6-8 p.m.; Montesano City Hall, 112 North Main Street, Montesano. WDFW fishery managers are scheduled to brief the Fish and Wildlife Commission on the development of the draft policy during the commission's November meeting in Olympia. Warren said WDFW will develop a range of policy options that will be discussed during the December commission meeting in Olympia. The commission is scheduled to hold a public hearing on the draft policy options during its January meeting in Olympia. The commission is scheduled to make a final decision at its February meeting in Olympia. Throughout the process, WDFW will periodically update its website at http://wdfw.wa.gov/conservation/fisheries/grays_harbor_salmon/ with more information on the development of the draft policy. ________________________________________ This message has been sent to the WDFW News Releases & Weekender mailing list. Visit the WDFW News Release Archive at: http://wdfw.wa.gov/news/ To UNSUBSCRIBE from this mailing list: http://wdfw.wa.gov/lists/unsubscribe.html [i][/i]
Well the process has some major problems......too many of the personnel in the Region 6 office, have a finger on the scale in favor of NT gill netters.......just funny how changes took/take place after the "Dog and Pony Show" call NOF(North of Falcon) was suppose to have ended.
Shame on you Phil Anderson, Ron Warren, Curt Hughes and Barbara McClellan.......Change the rules of the game, AFTER the game was over, heads should roll....time for the Commission to step up to the plate in Region 6.
Really....why do the NT netters deserve to have a season at all?????? QIN has a commercial right to net area 2A, 2C, and 2D. Time for the NT netters to hang up thier nets in the Chehalis/Humptulips area.
Hey folks I am on the run but I think this needs to be said.... bluntly. The meeting schedule above and citizen participation is critical. Now if this process goes forward with the same cast of characters and folks do not take the time to participate then I can guarantee many will not like the outcome. From legal actions, PDR request, to a website the many hundreds of hours put in it has been about getting a fair shake for the fish, inland communities, and sport fishers. So if you do not take the time to participate then do not whine at the outcome, whatever it is. Not trying to be rude ( might have achieved that though ) but rather saying it as it is. As a close friend told me it is " put up or shut up time. "
I'll make as many meetings as I can, but I imagine most of us won't be able to make more than a few. Would you say the public meetings in Montesano would be the most critical for sport fishers to attend?
I honestly do not know which is the most important meeting. I will have a better idea after Monday night's meeting as just what they say in the press vs what they can / will do can be very different.
Just one more invitation to interested folks to attend tonight's meeting at 6PM.... Region 6 HQ, just south of the Devonshire exit in Montesano.
Public may listen in on the deliberations from 6-8 (no public comment permitted in order to allow the advisory group to conduct business uninterrupted) Be respectful and abide by this rule no matter how tempting it may be to interject an inquiry or opinion. To be sure, there will be a question/answer session immediately following. You can speak your piece then.
Below is the WDF&W Region 6 District 17 schedule for the review and modification of the Grays Harbor Management Plan ( GHMP ). So in plain English how does this effect everyone? Well in very blunt terms the GHMP is about who catches what fish (in-river sport / bay sport /commercial ), where they catch the fish, and how ( fishing rod or net ). After completing this process ( outlined below ) the WDF&W Commission will adopt policy guidelines WDF&W Region 6 District 17 will then follow in the allocation of harvest and management for escapement ( spawners ) in the future.
It is pretty much a given that most folks cannot make all these meetings so which one you might ask? November 1 at Montesano City Hall ( high lighted in Red below ) would be my first choice. It is a citizens opportunity to speak their mind and it is important. Yeah right another " dog & pony show " is the likely response most will have to this concept. The difference this time is that the WDF&W Commission will have the GHMP on their agenda for the next four months monitoring this process prior to adopting " policy guidelines " in February.
So bottom line is that it is that time. If you want the Salmon resources in Grays Harbor and the Chehalis Basin managed in a reasonable manner citizen participation is more important than ever. As harsh as it sounds you snooze you will loose in this process.
WDFW NEWS RELEASE Washington Department of Fish and Wildlife 600 Capitol Way North, Olympia, WA 98501-1091 http://wdfw.wa.gov/ October 17, 2013 Contact: Ron Warren, (360) 249-1201 Public meetings scheduled to discuss Grays Harbor salmon management OLYMPIA - The Washington Department of Fish and Wildlife (WDFW) has scheduled eight public meetings this fall and winter to discuss and develop a new draft policy for managing salmon fisheries in Grays Harbor. The public meetings are part of a nearly five-month process to develop the new draft policy specifically for Grays Harbor salmon management. The Washington Fish and Wildlife Commission, a citizen panel appointed by the governor to set policy for WDFW, is scheduled to consider adopting the draft policy in mid-February. Salmon fisheries in Grays Harbor are currently managed under a framework that was initially developed in 2007, in conjunction with the commission's North of Falcon policy, said Ron Warren, regional fish program manager for WDFW. "We would like to further refine the management of Grays Harbor salmon fisheries to help ensure we can meet spawning goals for wild salmon returning to the basin, as well as give anglers and commercial fishers a clearer picture of what fishing opportunities they can expect each year," Warren said. The public meetings include three workshops and five Grays Harbor Advisory Committee meetings. The advisory committee discussions are open to the public, and those in attendance will have an opportunity to comment at the end of each meeting. The public meetings are scheduled for: • Oct. 21 - Grays Harbor Advisory Committee, from 6-8 p.m.; public input from 8-9 p.m.; WDFW's Montesano office, 48 Devonshire Road. • Oct. 28 - Grays Harbor Advisory Committee, from 6-8 p.m.; public input from 8-9 p.m.; WDFW's Montesano office, 48 Devonshire Road. • Nov. 1 - WDFW fishery managers will host a public workshop from 6-8 p.m.; Montesano City Hall, 112 North Main Street, Montesano. • Nov. 13 - Grays Harbor Advisory Committee, from 6-8 p.m.; public input from 8-9 p.m.; WDFW's Montesano office, 48 Devonshire Road. • Nov. 18 - Grays Harbor Advisory Committee, from 6-8 p.m.; public input from 8-9 p.m.; WDFW's Montesano office, 48 Devonshire Road. • Nov. 26 - WDFW fishery managers will host a public workshop from 6-8 p.m.; Montesano City Hall, 112 North Main Street, Montesano. • Jan. 13 - Grays Harbor Advisory Committee, from 6-8 p.m.; public input from 8-9 p.m.; WDFW's Montesano office, 48 Devonshire Road. • Jan. 15 - WDFW fishery managers will host a public workshop from 6-8 p.m.; Montesano City Hall, 112 North Main Street, Montesano. WDFW fishery managers are scheduled to brief the Fish and Wildlife Commission on the development of the draft policy during the commission's November meeting in Olympia. Warren said WDFW will develop a range of policy options that will be discussed during the December commission meeting in Olympia. The commission is scheduled to hold a public hearing on the draft policy options during its January meeting in Olympia. The commission is scheduled to make a final decision at its February meeting in Olympia. Throughout the process, WDFW will periodically update its website at http://wdfw.wa.gov/conservation/fisheries/grays_harbor_salmon/ with more information on the development of the draft policy. ________________________________________ This message has been sent to the WDFW News Releases & Weekender mailing list. Visit the WDFW News Release Archive at: http://wdfw.wa.gov/news/ To UNSUBSCRIBE from this mailing list: http://wdfw.wa.gov/lists/unsubscribe.html
I was given a three ring binder ( as an Adviser ) and Jim Scott & Ron Warren outlined the process. Some insight was gained when everyone was asked what was their single biggest bitch. So it was a warm up / ground rules thing and about ZERO hard info outside of the coming process. Again the Nov. 1 meeting is the first major foray into the general public for input. The Adviser meetings do have time for those who attend to speak and if you have the time one should attend. The fact that the Commission is engaged is important and not to be overlooked in the mayhem. So the answer to SH's question is " hi & how are you and here is what is about to happen ".
I am not one of the chosen few.......so I got no 3 ring binder. I always get a few "jabs in".......I call it like I see it......told them that it looked like the beginning of another "Dog and Pony show".....time tells all, major problems in the Chehalis/Humptulips basins........Not many gill netters left......100's of hours are spent in meetings....trying to justify a "cowboy gill net season" for fewer than 20 netters.
Gill netters have a common saying "who will feed the general population if we don't net??????? Hate to have to tell them again but QIN can do the job quite well.
1. I did request that NO NT gill nets above the 101 Bridge.....reason more banks anglers now, don't need to be fishing in muddy water from gill net boats run up river.
2. Hit them, again, with the Wynoochee mitigation that hasn't been spent.....2.4 million......monies to be used for Coho and SH. Told them if they can't get the job done, 23+ years, let the QIN take the lead.
Actually I said something about WDFW sitting around with their finger up their ass and not getting things done.
Interesting read. The tables breaking out the dollar amount by user groups are available if anyone wants them. This is for hatchery production but in the case of Grays Harbor the values would cross into the natural origin harvest and with Coho at 5 or 6 to 1 W / H. Lot of Rec $$$$.
TECHNICAL MEMORANDUM (FINAL)
April 28, 2009
Memo to: From:
Andy Appleby, Washington Department of Fish and Wildlife Tom Wegge , TCW Economics
RE: Economic Analysis of WDFW 's Hatchery 2020 Plans
The Hatchery Scientific Review group (HSRG) retained TCW Economics to conduct an economic assessment of the State's Draft Hatchery Action Implementation Plans (Hatchery 2020 Plans). This memorandum summarizes the final results of the economic assessment , and describes the methods, including data sources , used to conduct the assessment.
Accompanying this memorandum is an excel workbook that includes the data used to analyze WDFW's 120 salmon and steelhead hatchery programs, and the economic impact estimates for each program.
Results
As described in more detail below, the analysis of economic impacts focuses on measuring the expected effects of each program on generating local personal income from affected commercial and sport fisheries in different economic regions of the state. The estimates are considered minimum contributions due to the methods used to estimate freshwater sport catch, including lower than optimum levels of sampling in some marine commercial fisheries.
State-operated hatcheries for salmon and steelhead evaluated in this analysis are located in watersheds in the Puget Sound region, Coastal region, and Lower Columbia River region. The commercial and sport fisheries where hatchery-produced salmon and steelhead are harvested also occur in these three regions, as well as in more distant fisher ies located outside of state waters (e.g., southeast Alaska , British Columbia, and Oregon coast). For this analysis, however, only effects associated with the harvest in Washington State waters were evaluated .
Puget Sound Hatchery Programs
The contribution to local personal income of salmon and steelhead hatchery programs located in the Puget Sound region is shown by watershed in Table 1. Local personal income generated from Puget Sound hatchery production is estimated at $11.4 million annually in commercial fisheries and $18.4 million in sport fisheries.
TCW Economics Econom ic Consulting for Natural Resou rce Managemen t and Land Use Plan n ing 2756 9111 Avenue Sacramento, CA 9581 8 916/45 1-3372 fax: 916/451-1920 e-mail : twegge@tcweco n .com
For hatchery produced fish that are harvested in commercial fisheries, the Puget Sound marine and freshwater net fisheries account for $10.9 million, or about 96 percent of the total personal income generated . Hatchery production of chum accounts for about 53 percent of the total personal income generated and hatchery production of Chinook accounts for about 38 percent.
For hatchery produced fish caught in sport fisheries, $11.4 million of the total $18.4 million in local personal income is associated with sport fishing activity in freshwater areas of the Puget Sound region. Puget Sound marine sport fisheries account for about $6.5 million and ocean sport fisheries account for about $627,000 in local personal income. Hatchery produced coho caught in both marine and freshwater sport fisheries generate about $7.8 million annually , steelhead sport fisheries generate about $6.7 million, and Chinook sport fisheries generate about $3.9 million in local personal income. Hatchery programs in the Snohomish watershed contribute about $5.1 million annually in local personal income in the Puget Sound region and hatchery programs in the Payullup/White watershed contribute about $3.4 million annually.
It is estimated that commercial and sport fisheries in the Puget Sound region that depend on hatchery production support an estimated 532 full- and part-time jobs throughout the region. This number of jobs does not include hatchery jobs or other jobs indirectly supported by operations at hatchery facilities.
Coastal Hatchery Programs
The contribution to local personal income of salmon and steelhead hatchery programs located in the Coastal region is shown by watershed in Table 2. Local personal income from coastal hatchery production is estimated at $1.5 million annually in commercial fisheries and $7.6 million in sport fisheries. Almost all of the local personal income generated by the harvest from coastal hatchery programs occurs in the State's coastal economic region.
For hatchery produced fish harvested in commercial fisheries, coastal net fisheries account for 97 percent of the total personal income generated . Hatchery coho production accounts for $1.0 million of the $1.5 million in annual personal income. Although not reported in Table 2, it is estimated that more than 80 percent of the local personal income is captured in the Westport area, which is the primary port associated with catch area 2.
For hatchery produced fish caught in sport fisheries, $6.8 million of the total $7.6 million in local personal income is associated with sport fishing activity in coastal freshwaters . Ocean sport fisheries account for about $821,000 and Puget Sound marine sport fisheries account for about $25,000 in local personal income. Hatchery fish caught in steelhead sport fisheries generate about $4.2 million annually , Chinook sport fisheries generate about $876,000, and Coho sport fisheries generate about $2.6 million in local personal income. Hatchery programs in the Wynoochee watershed contribute the most personal income ($1.9 million), followed by hatchery programs in the Solduc/Quillayute and Humptulips watersheds ($1.3 million each).
It is estimated that commercial and sport fisheries in the Coastal region that depend on hatchery production support an estimated 277 full- and part-time jobs throughout the region. This number of jobs does not include hatchery jobs or other jobs indirectly supported by operations at hatchery facilities.
Lower Columbia River Hatchery Programs
The contribution to local personal income of salmon and steelhead hatchery programs located in the Lower Columbia River region is shown by watershed in Table 3. Local personal income
from Lower Columbia River hatchery production is estimated at $1.5 million annually in commercial fisheries and $27.9 million in sport fisheries.
For hatchery produced fish harvested in commercial fisheries, the Lower Columbia River net fisheries account for about $974,000, or about 67%, of the total personal income generated . Hatchery production of coho accounts for about 53 percent of the annual $1.4 million in personal income generated and Chinook accounts for about 47 percent.
For hatchery produced fish caught in sport fisheries, $14.5 million of the total $27.9 million in local personal income is associated with sport fishing activity on the Columbia River mainstem and about $10.5 million is associated with sport fishing in terminal areas (tributary fisheries) of the Lower Columbia River . Ocean sport fisheries account for about $2.8 million and Puget Sound marine sport fisheries account for about $74,000 in local personal income. Hatchery fish caught in steelhead sport fisheries generate about $13.7 million annually , Chinook sport fisheries generate about $3.7 million, and coho sport fisheries generate about $10.5 million in local personal income. Hatchery programs in the Cowlitz River watershed contribute the most personal income at $14.8 million annually , distantly followed by hatchery programs in the Lewis River watershed ($5.7 million) and Kalama River hatchery programs ($2.8 million) .
It is estimated that commercial and sport fisheries in the Lower Columbia River region that depend on hatchery production support an estimated 1,108 full- and part-time jobs throughout the region. This number of jobs does not include hatchery jobs or other jobs indirectly supported by operations at hatchery facilities.
Reposting this bit as this Friday is the first public meeting and I urge anyone who can to attend.
Below is the WDF&W Region 6 District 17 schedule for the review and modification of the Grays Harbor Management Plan ( GHMP ). So in plain English how does this effect everyone? Well in very blunt terms the GHMP is about who catches what fish (in-river sport / bay sport /commercial ), where they catch the fish, and how ( fishing rod or net ). After completing this process ( outlined below ) the WDF&W Commission will adopt policy guidelines WDF&W Region 6 District 17 will then follow in the allocation of harvest and management for escapement ( spawners ) in the future.
It is pretty much a given that most folks cannot make all these meetings so which one you might ask? November 1 at Montesano City Hall ( high lighted in Red below ) would be my first choice. It is a citizens opportunity to speak their mind and it is important. Yeah right another " dog & pony show " is the likely response most will have to this concept. The difference this time is that the WDF&W Commission will have the GHMP on their agenda for the next four months monitoring this process prior to adopting " policy guidelines " in February.
So bottom line is that it is that time. If you want the Salmon resources in Grays Harbor and the Chehalis Basin managed in a reasonable manner citizen participation is more important than ever. As harsh as it sounds you snooze you will loose in this process.
WDFW NEWS RELEASE Washington Department of Fish and Wildlife 600 Capitol Way North, Olympia, WA 98501-1091 http://wdfw.wa.gov/ October 17, 2013 Contact: Ron Warren, (360) 249-1201 Public meetings scheduled to discuss Grays Harbor salmon management OLYMPIA - The Washington Department of Fish and Wildlife (WDFW) has scheduled eight public meetings this fall and winter to discuss and develop a new draft policy for managing salmon fisheries in Grays Harbor. The public meetings are part of a nearly five-month process to develop the new draft policy specifically for Grays Harbor salmon management. The Washington Fish and Wildlife Commission, a citizen panel appointed by the governor to set policy for WDFW, is scheduled to consider adopting the draft policy in mid-February. Salmon fisheries in Grays Harbor are currently managed under a framework that was initially developed in 2007, in conjunction with the commission's North of Falcon policy, said Ron Warren, regional fish program manager for WDFW. "We would like to further refine the management of Grays Harbor salmon fisheries to help ensure we can meet spawning goals for wild salmon returning to the basin, as well as give anglers and commercial fishers a clearer picture of what fishing opportunities they can expect each year," Warren said. The public meetings include three workshops and five Grays Harbor Advisory Committee meetings. The advisory committee discussions are open to the public, and those in attendance will have an opportunity to comment at the end of each meeting. The public meetings are scheduled for: • Oct. 21 - Grays Harbor Advisory Committee, from 6-8 p.m.; public input from 8-9 p.m.; WDFW's Montesano office, 48 Devonshire Road. • Oct. 28 - Grays Harbor Advisory Committee, from 6-8 p.m.; public input from 8-9 p.m.; WDFW's Montesano office, 48 Devonshire Road. • Nov. 1 - WDFW fishery managers will host a public workshop from 6-8 p.m.; Montesano City Hall, 112 North Main Street, Montesano. • Nov. 13 - Grays Harbor Advisory Committee, from 6-8 p.m.; public input from 8-9 p.m.; WDFW's Montesano office, 48 Devonshire Road. • Nov. 18 - Grays Harbor Advisory Committee, from 6-8 p.m.; public input from 8-9 p.m.; WDFW's Montesano office, 48 Devonshire Road. • Nov. 26 - WDFW fishery managers will host a public workshop from 6-8 p.m.; Montesano City Hall, 112 North Main Street, Montesano. • Jan. 13 - Grays Harbor Advisory Committee, from 6-8 p.m.; public input from 8-9 p.m.; WDFW's Montesano office, 48 Devonshire Road. • Jan. 15 - WDFW fishery managers will host a public workshop from 6-8 p.m.; Montesano City Hall, 112 North Main Street, Montesano. WDFW fishery managers are scheduled to brief the Fish and Wildlife Commission on the development of the draft policy during the commission's November meeting in Olympia. Warren said WDFW will develop a range of policy options that will be discussed during the December commission meeting in Olympia. The commission is scheduled to hold a public hearing on the draft policy options during its January meeting in Olympia. The commission is scheduled to make a final decision at its February meeting in Olympia. Throughout the process, WDFW will periodically update its website at http://wdfw.wa.gov/conservation/fisheries/grays_harbor_salmon/ with more information on the development of the draft policy. ________________________________________ This message has been sent to the WDFW News Releases & Weekender mailing list. Visit the WDFW News Release Archive at: http://wdfw.wa.gov/news/[/i][i]
Well this bit is interesting to say the least. I believe it is relevant in the current discussion of the sacrificing of the resource to maintain the antiquated commercial fisheries.
TECHNICAL MEMORANDUM (FINAL)
April 28, 2009
Memo to: From:
Andy Appleby, Washington Department of Fish and Wildlife Tom Wegge , TCW Economics
RE: Economic Analysis of WDFW 's Hatchery 2020 Plans
The Hatchery Scientific Review group (HSRG) retained TCW Economics to conduct an economic assessment of the State's Draft Hatchery Action Implementation Plans (Hatchery 2020 Plans). This memorandum summarizes the final results of the economic assessment , and describes the methods, including data sources , used to conduct the assessment.
Accompanying this memorandum is an excel workbook that includes the data used to analyze WDFW's 120 salmon and steelhead hatchery programs, and the economic impact estimates for each program.
Results
As described in more detail below, the analysis of economic impacts focuses on measuring the expected effects of each program on generating local personal income from affected commercial and sport fisheries in different economic regions of the state. The estimates are considered minimum contributions due to the methods used to estimate freshwater sport catch, including lower than optimum levels of sampling in some marine commercial fisheries.
State-operated hatcheries for salmon and steelhead evaluated in this analysis are located in watersheds in the Puget Sound region, Coastal region, and Lower Columbia River region. The commercial and sport fisheries where hatchery-produced salmon and steelhead are harvested also occur in these three regions, as well as in more distant fisher ies located outside of state waters (e.g., southeast Alaska , British Columbia, and Oregon coast). For this analysis, however, only effects associated with the harvest in Washington State waters were evaluated .
Puget Sound Hatchery Programs
The contribution to local personal income of salmon and steelhead hatchery programs located in the Puget Sound region is shown by watershed in Table 1. Local personal income generated from Puget Sound hatchery production is estimated at $11.4 million annually in commercial fisheries and $18.4 million in sport fisheries.
TCW Economics Econom ic Consulting for Natural Resou rce Managemen t and Land Use Plan n ing 2756 9111 Avenue Sacramento, CA 9581 8 916/45 1-3372 fax: 916/451-1920 e-mail : twegge@tcweco n .com
For hatchery produced fish that are harvested in commercial fisheries, the Puget Sound marine and freshwater net fisheries account for $10.9 million, or about 96 percent of the total personal income generated . Hatchery production of chum accounts for about 53 percent of the total personal income generated and hatchery production of Chinook accounts for about 38 percent.
For hatchery produced fish caught in sport fisheries, $11.4 million of the total $18.4 million in local personal income is associated with sport fishing activity in freshwater areas of the Puget Sound region. Puget Sound marine sport fisheries account for about $6.5 million and ocean sport fisheries account for about $627,000 in local personal income. Hatchery produced coho caught in both marine and freshwater sport fisheries generate about $7.8 million annually , steelhead sport fisheries generate about $6.7 million, and Chinook sport fisheries generate about $3.9 million in local personal income. Hatchery programs in the Snohomish watershed contribute about $5.1 million annually in local personal income in the Puget Sound region and hatchery programs in the Payullup/White watershed contribute about $3.4 million annually.
It is estimated that commercial and sport fisheries in the Puget Sound region that depend on hatchery production support an estimated 532 full- and part-time jobs throughout the region. This number of jobs does not include hatchery jobs or other jobs indirectly supported by operations at hatchery facilities.
Coastal Hatchery Programs
The contribution to local personal income of salmon and steelhead hatchery programs located in the Coastal region is shown by watershed in Table 2. Local personal income from coastal hatchery production is estimated at $1.5 million annually in commercial fisheries and $7.6 million in sport fisheries. Almost all of the local personal income generated by the harvest from coastal hatchery programs occurs in the State's coastal economic region.
For hatchery produced fish harvested in commercial fisheries, coastal net fisheries account for 97 percent of the total personal income generated . Hatchery coho production accounts for $1.0 million of the $1.5 million in annual personal income. Although not reported in Table 2, it is estimated that more than 80 percent of the local personal income is captured in the Westport area, which is the primary port associated with catch area 2.
For hatchery produced fish caught in sport fisheries, $6.8 million of the total $7.6 million in local personal income is associated with sport fishing activity in coastal freshwaters . Ocean sport fisheries account for about $821,000 and Puget Sound marine sport fisher ies account for about $25,000 in local personal income. Hatchery fish caught in steelhead sport fisheries generate about $4.2 million annually , Chinook sport fisheries generate about $876,000, and coho sport fisheries generate about $2.6 million in local personal income. Hatchery programs in the Wynoochee watershed contribute the most personal income ($1.9 million), followed by hatchery programs in the Solduc/Quillayute and Humptulips watersheds ($1.3 million each).
It is estimated that commercial and sport fisheries in the Coastal region that depend on hatchery production support an estimated 277 full- and part-time jobs throughout the region. This number of jobs does not include hatchery jobs or other jobs indirectly supported by operations at hatchery facilities.
Lower Columbia River Hatchery Programs
The contribution to local personal income of salmon and steelhead hatchery programs located in the Lower Columbia River region is shown by watershed in Table 3. Local personal income
from Lower Columbia River hatchery production is estimated at $1.5 million annually in commercial fisheries and $27.9 million in sport fisheries.
For hatchery produced fish harvested in commercial fisheries, the Lower Columbia River net fisheries account for about $974,000, or about 67%, of the total personal income generated . Hatchery production of coho accounts for about 53 percent of the annual $1.4 million in personal income generated and Chinook accounts for about 47 percent.
For hatchery produced fish caught in sport fisheries, $14.5 million of the total $27.9 million in local personal income is associated with sport fishing activity on the Columbia River mainstem and about $10.5 million is associated with sport fishing in terminal areas (tributary fisheries) of the Lower Columbia River . Ocean sport fisheries account for about $2.8 million and Puget Sound marine sport fisheries account for about $74,000 in local personal income. Hatchery fish caught in steelhead sport fisheries generate about $13.7 million annually , Chinook sport fisheries generate about $3.7 million, and coho sport fisheries generate about $10.5 million in local personal income. Hatchery programs in the Cowlitz River watershed contribute the most personal income at $14.8 million annually , distantly followed by hatchery programs in the Lewis River watershed ($5.7 million) and Kalama River hatchery programs ($2.8 million) .
It is estimated that commercial and sport fisheries in the Lower Columbia River region that depend on hatchery production support an estimated 1,108 full- and part-time jobs throughout the region. This number of jobs does not include hatchery jobs or other jobs indirectly supported by operations at hatchery facilities.
As the Grays Harbor Management Plan ( GHMP ) is being worked on I thought I would put up this E mail thread to help folks understand WHY it is important to get involved. This thread is about Chum and how Region - 6 District 17 manages the preseason forecast by lumping Chum in one number rather than manage by stock. ( individual streams ) Now if you were to break escapement down further by defining the Wynoochee and Wishkah at say equal to the Satsop, then very rough numbers ( close guess? ) for the mainstem Chehalis for Chum would be 7140. Keeping in mind the 7140 is just a working guess but likely in the ball park, doubts on why the up river Chum stocks are being exterminated by commercial harvest should be gone. Good lord has anyone seen Chum in numbers that are needed above the Satsop?
So one more time. WDF&W Region 6 District 17 staff get away with this because WE blindly accept information provided, do not stay involved, and FAIL TO RECOGNIZE IT IS THE COMMISSION THAT MUST REQUIRE THE NECESSARY REFORMS. The absolute mess the GHMP has become is because the local communities ( especially the inland communities ) have allowed it to happen. You add the fact that the Commission has blindly accepted the dribble out of R-6 D-17 you get what we see.
From: Hughes, Kirt M (DFW) To: Warren, Ron R (DFW); cc: Scharpf, Mike M (DFW); Holt, Curt L (DFW); Herring, Chad J (DFW); Subject: RE: Chum Date: Tuesday, March 19, 2013 1:31:00 PM
Although we do not have the forecast model developed in a manner to specifically forecast at a tributary specific level, we could do that but it will require a LOT of work and tie we do not currently have. That said, not that I recommend doing so, one could roughly allocate the Grays Harbor wide goal and forecast by the relative portions of spawner habitat at the level Dave is requesting. While there might be some argument for this being acceptable for the goal, there is no basis for doing this with the forecast but I guess we will do it anyway. The complexity of escapement, age composition, and productivity should really be brought to account.
Anyhow, available spawner habitat is approximately 22% in the Humptulips, and 78% in the Chehalis (of total GH habitat 22% is in the Satsop).
Following through on this as a way to split the forecast as David is interested in you get the following.
From: Warren, Ron R (DFW) Sent: Thursday, March 14, 2013 8:30 AM To: Hughes, Kirt M (DFW) Subject: FW: Chum
From: Sent: Thursday, March 14, 2013 7:58 AM To: Warren, Ron R (DFW) Subject: Fwd: Chum
Ron,
Any idea on when your guys will provide the requested info below on Chum?
From: To: "Ron Warren" <ron.warren@dfw.wa.gov> Cc: "Jim Scott" <scottjbs@dfw.wa.gov> Sent: Thursday, March 7, 2013 6:24:28 AM Subject: Chum
Mr. Warren,
After reviewing the Grays Harbor advisory meeting last night, ( March 6, 2013 ) I found the information provided to well short of what is needed to address Chum harvest for Grays Harbor as a whole or the Chehalis Basin. As a member of the Grays Harbor Advisory Group I am formally requesting to be provided the following information.
1. A 2013 Preseason Forecast for the number of returning Chum adults to the Humptulips River.
2. A 2013 Preseason Forecast for the number of returning Chum adults to the Chehalis River.
3. A 2013 Preseason Forecast for the number of returning Chum adults to the Satsop River.
Here is an interesting bit concerning members of the Grays Harbor Advisers or rather a new member. So the question becomes why the concern about the CCA? Another e mail thread addressed that as to not having two CCA members as Advisers and Kirt Hughes was even sending out a sheet that he wanted your views on harvest / conservation / any affiliations prompting one individual to ask if we were going back to the 50's and Tailgunner JOE! Now compare this concern with six or more members are from the Gillnetters Association with two members from the same family. I will find some additional information on the Advisory Group but I thought this is relevant.
So no confusion exist I am on the Advisory Group ( the newbie ) and this Rec / Commercial bit is a load of crap. In my view WDF&W has created a Adviser Group that DOES NOT IN ANYWAY REFLECT THE CITIZENS OF GRAYS HARBOR & THE CHEHALIS BASIN.
From: Warren, Ron R (DFW) To: Hughes, Kirt M (DFW) Subject: RE: GH Advisory Committee... new members? Date: Tuesday, January 12, 2010 7:03:00 AM
My only hesitation is that since the inception of the AdHoc committee there has been the creation of a different element that will enter the committee if we open positions. This element is CCA.
Ron Warren Region 6 Fish Program 48 Devonshire Road Montesano, WA 98563 360-249-1201 Office 360-249-1229 Fax ron.warren@dfw.wa.gov
From: Hughes, Kirt M (DFW) Sent: Tuesday, January 12, 2010 6:09 AM To: Cc: JC ; Warren, Ron R (DFW) Subject: Re: GH Advisory Committee... new members?
-------- Thanks for the conversation last night. I will speak with Ron about soliciting new members for the GH group; he is at Pacific Salmon Commission meetings this week so it may be a few days before we are able to put something together. Kirt Hughes
From: --------- To: Hughes, Kirt M (DFW) Cc: ---------- Sent: Mon Jan 11 23:53:28 2010 Subject: GH Advisory Committee... new members? Kirt
With the recent passing of Mike Munsell, the recreational representation on our committee is down one more body. With the loss of Andy Matthews, and the chronic lack of participation from the folks from the I-5 corridor, it seems appropriate to infuse some new blood from the sportfishing community.
Allow me to introduce John --------- , a local GH resident, avid fisherman in local waters, and currently Govt Relations Committee (GRC) liaison between the local chapter of the CCA and the State GRC. He has a keen interest in the GH fisheries and wants to learn more about the key GH issues. Mild mannered, soft spoken, a good listener, and a critical thinker… he would definitely be an asset to our group.
If we could arrange for a face to face introduction before we convene as a committee next month, that would be great.
Sure makes it look like Advisory Groups are created to tell the Department what it wants to hear. And then claim that what they do has the support of the Stakeholders.
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.
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!
I was asked to post how the Commission sets out the "sideboards" for NOF so here is 2012. Formatting is gone with the C&P but it is fairly easy to follow. Now go to the bottom and read the delegation of authority SLOWLY and think about what it means in relation to what we see with Salmon harvest tribal & non tribal.
Washington Fish and Wildlife Commission North of Falcon, Policy C-3608 Adopted Feb. 4, 2011 Page 1 of 3 FISH AND WILDLIFE COMMISSION POLICY DECISION POLICY TITLE: 2011-2012 North of Falcon POLICY NUMBER: C-3608 Supersedes: C-3608, 2009-2010 Effective Date: February 4, 2011 Termination Date: December 31, 2012 See Also: Policy C-3001 Approved by: ___________________________Chair Washington Fish and Wildlife Commission, 02/04/2011 North of Falcon Policy This Policy will guide Department staff in considering conservation, allocation, in-season management, and monitoring issues associated with the annual, salmon fishery planning process known as “North of Falcon”. When considering management issues, Department staff will ensure that decisions are made consistent with the Department’s statutory authority, U.S. v. Washington, U.S. v. Oregon, the Endangered Species Act, the Puget Sound Chinook Harvest Management Plan, the Pacific Salmon Treaty, the Pacific Fishery Management Council’s Framework Salmon Management Plan, pertinent state/tribal agreements, and the applicable Fish and Wildlife Commission policies. The Department will implement this Policy consistent with the purposes and intended outcomes described in the 21st Century Salmon and Steelhead Planning Project including: • WDFW shall manage salmon and steelhead to recovery and sustainability in a way that is science-based, well-documented, transparent, well-communicated, and accountable. • Fisheries are managed to meet or exceed ESA, recovery, and conservation goals; and harvest management measures protect and promote the long-term well-being of the commercial and recreational fisheries. Fishery Management General • On a statewide basis, fishing opportunities will be provided when they can be directed at healthy wild and hatchery stocks. • Selective fishing methods and gears that maximize fishing opportunity and minimize impacts on depressed stocks will be utilized to the fullest extent possible within legal constraints of implementation and budgetary limits associated with required sampling, monitoring and enforcement programs. • When assessed from a statewide perspective, fishing directed at chinook, coho, pink, sockeye, or chum salmon will not be exclusively reserved for either sport or commercial users. • When managing sport fisheries, meaningful recreational fishing opportunities will be distributed equitably across fishing areas and reflect the diverse interests of fishers, including retention and catch and release fisheries. • The Department will seek non-treaty fishing access to unutilized portions of treaty harvest allocations through the implementation of pre-season agreements, taking into consideration changes in abundance, fishery conflicts, and factors that may influence attainment of spawning escapement objectives. Washington Fish and Wildlife Commission North of Falcon, Policy C-3608 Adopted Feb. 4, 2011 Page 2 of 3 Sockeye, Chum, and Pink Salmon • For fisheries directed at Fraser River origin chum, pink, and sockeye stocks, the majority of harvest will be provided to the commercial fisheries. • For fisheries directed at harvestable Puget Sound origin chum stocks, the majority of harvest will be provided to the commercial fisheries. • For fisheries directed at Lake Washington sockeye, the first 200,000 non-treaty harvest will be provided to recreational fishers. If the allowable non-treaty harvest is greater than 200,000, commercial harvest directed at this stock may be considered. • For fisheries directed at harvestable Puget Sound origin pink salmon, seasons will be established that provide meaningful opportunities for both recreational and commercial fisheries while minimizing gear and other fishery conflicts. Chinook and Coho Salmon • The Puget Sound harvest management objectives for chinook and coho stocks, in priority order, are to (1) provide meaningful recreational fishing opportunities, and (2) identify and provide opportunities for commercial harvest. When managing sport fisheries in this region, recreational opportunities will be distributed equitably across fishing areas, considering factors such as the: uniqueness of each area, the availability of opportunities for various species in each area throughout the season, desire to provide high levels of total recreational opportunity, and biological impacts. • Grays Harbor harvest management objectives shall include opportunities for both the recreational and commercial fisheries. • Columbia River harvest management regimes shall be developed in cooperation with Oregon Department of Fish and Wildlife representatives. Commercial and recreational fishing opportunity will be scheduled to optimize the non-treaty harvest of chinook and coho and to provide a balanced opportunity to each fleet. When developing recreational and commercial fishing options, the Department shall consider fair and reasonable catch opportunity, stability and duration of fisheries, as well as sharing of the conservation responsibility. • Willapa Bay harvest management shall be consistent with Willapa Bay Framework management objectives. The following general intent shall apply: Willapa Bay harvest management objectives shall include meaningful opportunities for both recreational and commercial fisheries. • Pacific Ocean harvest shall be managed consistent with the Pacific Fishery Management Council’s Framework Salmon Management Plan and the National Standards that provide for fair and equitable allocation of fishing privileges among various fishers. In-Season Management • When in-season management actions are taken, they will be implemented in a manner that is consistent with pre-season conservation and harvest management objectives, and the fishery intent developed through the North of Falcon process. Monitoring, Sampling and Enforcement • Monitoring, sampling and enforcement programs will be provided to account for species and population impacts of all fisheries and to ensure compliance with state regulations. • Fishery participants will be required to comply with fishery monitoring and evaluation programs designed to account for species and population impacts. Washington Fish and Wildlife Commission North of Falcon, Policy C-3608 Adopted Feb. 4, 2011 Page 3 of 3 Gear and Fishery Conflicts • Recreational and commercial fisheries shall be structured to minimize gear and other fishery conflicts. Unanticipated fishery interaction issues identified in-season, including conflicts with fisheries directed at other species, shall be resolved by involving the appropriate sport and commercial representatives in a dispute resolution process managed by Department staff. Incidental Mortalities • The Department will manage fisheries to minimize mortalities on non-target species (e.g. rockfish, sea birds, etc.). Management regimes will include strategies to limit seabird mortalities consistent with the federal Migratory Bird Treaty Act. Communications • The Department shall strive to make ongoing improvements for effective public involvement during the North of Falcon planning process and annual salmon fishery implementation, incorporating the following intents: – include North of Falcon participants as observers during appropriate state/tribal discussions of fishery issues. – maintain a record of all decisions made during the North of Falcon process. – use a variety of tools to effectively communicate with the public, receiving input on pre-season planning or in-season fishery issues, and making available the record of decisions; such tools will include use of recreational and commercial advisory groups, public workshops addressing key issues, the WDFW North of Falcon Web site, and inseason tele-conferencing. Other Species • The Fish and Wildlife Commission’s policy on Lower Columbia Sturgeon Management (POL-C3001) shall guide pre-season and in-season planning of Columbia River and coastal sturgeon fisheries and related incidental impacts. Management of Willapa Bay sturgeon fisheries will be further guided by Willapa Bay Framework management objectives. Delegation of Authority The Fish and Wildlife Commission delegates the authority to the Director to make harvest agreements with Northwest treaty tribes and other governmental agencies, and adopt permanent and emergency regulations resulting from the agreements made during the annual North of Falcon process.
Double up post but it is rather important for everyone one to know that the draft for the Policy Guidelines for the GH Management Plan is out at least partway to the Advisers. So if you want it real soon rather than wait for it to get up on FTC website or WDF&W's PM me your E mail address and I will send it to you. Oh almost forgot 4 / 3 commercial days ( three net free days a week ) appears to be in it.
So how did the December Commission meeting go? It was interesting to say the least with cause for optimism that change may be coming and yet the huge potential for more of the same. The potential exist for the many options could be cobbled together in a manner that is smoke and mirrors. The Power Point presentation utilized is not up on WDF&W's website yet but as soon as it is someone will post a link I am sure.
So now what? Well everyone should direct there comments directly to the Commission and here is the address. commission@dfw.wa.gov Below are my comments to the commissioners on two issues that I feel strongly about. It is your right so if your involved or following this process be involved and get your views to the Commission.
Commissioners,
Attached are the issues I intended to testify on at Saturdays Commission meeting but a printer failure left me with only two copies so I have attached comments to this E mail. I apologize for my failure to submit the issues correctly and I will attempt to make sure that does not happen again. In addition two issues really stood out as being misrepresented at the 12/07/13 Commission meeting.
1. The issue of the Quinault Indian Nation ( QIN ) being responsible for the failure to make escapement really stands out. While I disagree with the manner that the QIN is setting it’s seasons on the fall Salmon harvest, they are within the boundaries of the court mandated fisheries. They are allowed up to 50% of the harvestable Salmon that cross the bar and within in that narrow guideline the QIN is not violating the court mandates. It was WDF&W in recent years that implemented the separation of the Humptulips and Chehalis Basins ( a action that I support ) and to the best of my knowledge the QIN did not sign on to or recognize it as altering their court mandated harvest methods.
In April 2013 Region 6 ( R6 ) District 17 ( D17 ) staff had the QIN proposed seasons and when the State’s fisheries were modeled with the QIN they went well into escapement. D17 refused to provide to the public the seasons fully modeled but when we finally got the QIN seasons modeled with the States season it showed a rather large deficit on the Chehalis side Chinook but a rather large number of Humptulips Chinook available for harvest but not utilized. So did Region 6 District 17 staff have options this past year? Yes they most certainly did. By moving Non Treaty Commercials to the Humptulips in the timing normally utilized the QIN impacts could have been substantially offset. Rather than take that approach R17 instead attempted to stack the Non Treaty nets right on top of the QIN Chehalis effort. Commissioners there was no way no how the combined state and QIN fisheries allowed for Chehalis Chinook in the model to make escapement but rather than alter their approach R6 D17 staff simply went forward and claimed they did not have agreement. Since then D6 R17 have steadfastly refused to make public what / when / why they did not have agreement with the QIN.
Having broodstocked with QIN fishers and as the project manager for the Chehalis Tribal fishers in the Chehalis Chinook Broodstocking effort some years back I came to understand and appreciate how deep the distrust of WDF&W was and frankly in recent years it has become much worse. So who is at fault? Both! The litany of disrespect both parties have shown each other has reached a point that most of us involved in advocacy in the Chehalis Basin find well past being even close to acceptable. Commissioners to be blunt the Commission needs to put an end to this conduct, at least on WDF&W’s side, then hopefully the QIN will follow. In conversations with retired agency staff one individual described current R6 D17efforts to work with the QIN on fisheries issues as similar to a fireman “ trying to put out a house fire with a flame thrower”.
2. The second issue is when Director Anderson discussed directed fisheries vs incidental. Frankly Commissioners this issue is one of the most misrepresented, distorted, abused practice I have ever seen in fisheries management by both the QIN and WDF&W. On the States side 2012 is a great example of complete and total disregard for honesty by D17 staff. Through the entire APA process & North of Falcon no Chum retention was put forth by the D17 staff but when the WAC came out Chum retention for the final day of the NT Nets season. I immediately contacted R17 staff and was told that the retention was allowed as the 5% escapement impact had yet to be reached for Chum and they were incidentally caught in a directed Coho harvest. This resulted in far more incidental Chum being harvested than targeted Coho for that set and harvesting into the Chum escapement. Try as we can myself and others struggle to understand the violation of the APA process front to back coupled with the utilization of the terms directed and incidental to continually violate the intent & goals of the current Grays Harbor Management Plan. Frankly many see this manipulation continuing in the revamped GH Management Plan without Commission intervention establishing solid definitions & guidelines on terminologies and methodologies.
On the QIN’s side a example is in December QIN begins what is commonly known as their early Steelhead fishery. Again the QIN has court mandated rights and in the 70’s & 80’s the former Department of Game utilized plants of December returning Chambers Creek lineage Steelhead to reduce harvest on the Native Wild Steelhead. Right / wrong / whatever the unintended consequences was that the QIN fishers harvested substantial numbers of Late Native Coho stocks as incidental catch. Fast forward to the present and the December returning Steelhead plants are gone, Late Coho stocks are in trouble and declining in number, and QIN fishers still maintain the December / January Steelhead fishery. This fishery is targeting planted a Steelhead stock that is no longer planted and few natural origin Steelhead returning adults exist but continues the practice of harvesting a Late Native Coho run that is in decline as incidental catch in a Steelhead fishery not modeled in the Salmon fisheries model.
Commissioners I truly appreciate your efforts to address the Grays Harbor issues but this abuse of the terms directed and incidental harvest must be addressed. This issue is particularly difficult as the WDF&W Region 6 District 17 staff, past & present, are every bit as guilty of manipulation for expanded commercial catch / sales as the QIN! Again it is my view that the Commission and the Commission alone can require WDF&W staff to reform this practice as I can guarantee that present WDF&W staff or the QIN can or will not address the issue without direct Commission input.
The link is to the WDF&W website page for the GH Management Plan redo. The Power Point presentation is at the 9:00 AM point Saturday in the meeting to view. You will find the economic statement rather revealing.
The link is to a review of the policy guidelines by the East County guys. I would C&P it in but maintaining the cross out formatting makes that bit out, so you will have to do the link bit then open up Commission Policy Edits. Lot of conversation on the fuzzing up of the language so it is a interesting read.
Having my e mail go up in flames with questions concerning the GH Management process that I simply could not give a definitive answer to I asked the question of WDF&W staff:
About the GHMP redo schedule. Several folks have asked me a question I do not have the answer to so………….. The January Commission meeting is to do what? The Commission moved the so called policy sideboards to public comment for 30 days so is the January meeting going to be where you present the completed GHMC draft redo? The Commission meeting February is to adopt the completed redo of GHMP or just the policy guidelines? Just what exactly is the timeline & schedule and just what is the document that the public will to see? The completed GHMP or policy guidelines to review and comment on?
Which resulted in this response:
I can not always predict what will happen at a Commission meeting, but here is my sense of what is likely to happen at the January FWC meeting:
1) Staff will summarize comments on the draft policy that were received at the December Commission meeting and during the 30-day public comment period. 2) The public will have the opportunity to provide comments on the draft policy. 3) Staff will propose enhancements to the draft policy to address the public comments that were received during the December Commission meeting or in the 30-day public comment period. 4) Commissioners will propose enhancements to the draft policy to address public comments received up to that time. 5) The Commission will agree upon any enhancements or options they would like included in the draft Policy. 6) If there are substantive changes or options identified for consideration, the Commission may request that the Policy be put out for a second 30-day public comment period.
The question of how Mr. Anderson got his authority to unilaterally change seasons or add them is in the paragraph below.
Delegation of Authority The Commission delegates the authority to the Director, through the North of Falcon stakeholder consultation process, to set seasons for recreational and WDFW-managed commercial fisheries in Grays Harbor, to adopt permanent and emergency regulations to implement these fisheries, and to make harvest agreements with treaty tribes and other government agencies.
Now just how & what Mr. Anderson is expected to do is in the performance agreement below.
WASHING TON DEPARTMENT OF FISH AND WILDLIFE Fish and Wildlife Commission and Director Philip Anderson Performance Agreement - July 1, 2013 - June 30, 2014
The Fish and Wildlife Commission (Commission) and Director Philip M. Anderson (Director), agree to work together and respect their unique roles and responsibilities. The Executive Performance Elements (Attachment A) will be the primary tool used to evaluate the Director's key competencies.
The Priority Actions (Attachment B) represent the key indicators of the Director's performance that reflect the Commission's general expectations. The priorities listed therein are selected from the draft 2013-15 Strategic Plan. These actions are identified as the Commission's highest level performance outcomes and will be reflected, as appropriate down through the Departments accountability system (e.g., program operational plans and individual staff evaluations).
The Commission and the Director agree to review and update the list of Priority Actions as the need arises in response to budget reductions or significant changes in management direction.
Part I: Roles and Responsibilities It is recognized that together the Commission and the Director comprise the Department of Fish and Wildlife. The Commission is responsible for the policy governance of the Department within the parameters established by the State Legislature and serves as the public trustee of the state's fish and wildlife resources.
The Director is supervised by the Commission and is responsibl e for hiring agency staff and managing the Department in a manner that is consistent with statutory requirements established by the State Legislature, state and federal law, and with the policies adopted by the Fish and Wild life Commission.
The Commission will act as a body, speaking with a unified voice and acknowledges that the strength of the body is derived from the diversity of viewpoints brought together through its decision-making process. The Chair of the Commission is responsible for ensuring that the Commission accomplishes its responsibilities.
Commission committees will be used primarily to gather, discuss, and analyze information relative to policy issues or rules that are anticipated to come before the full Commission. Committees are intended to function as a forum that allows for more informal discussions between commissioners and/or with staff. The Director will be copied on E-mail communications between committee chairs and the committee's lead staff support person. Infmmation and data requests made by a committee that requires a significant staff workload will be presented as part of the committee's report to the full Commission and considered through the Commission's "Blue Sheet" process. Committees do not have the authority to make decisions on behalf of the Commission.
Washington Fish and Wildlife Commission Director's Performance Agreement Page I
Commission 's "Blue Sheet" process. Committees do not have the authority to make decisions on behalf of the Commission. The Commission and the Director agree to be mutually supportive, maintain a positive working relationship, and conduct their relationship based on mutual respect while acting in a manner that is consistent with the following principles:
• The Commission and Director will work together as a team in fulfilling the Department's responsibilities of preserving and •protecting the state's fish and wildlife resources and providing fish and wildlife related activities for the citizens of Washington. • The Commission and the Director commit to maintaining a strong working relationship founded in open and candid communication. • The Commission will focus its attention on policy matters and setting clear performance outcomes for the Director, leaving the Director sufficient flexibility to be agile and utilize his creativity in adapting to changing circumstances. • Individual Commissioners will communicate their concerns relative to policy matters with the Director 's Office . Ifdirect communication by a commissioner with staff a member regarding substantive issues is needed such communication will be coordinated with the Director 's Office.
Part II: Communication Actions and Strategies • The Director's Office will provide a report at each regular Commission meeting that • includes updates on current events and emerging issues, and budget and administrative matters . • The Director's Office will provide the Commission with periodic progress reports on the items contained in the Priority Actions listed in Attachment B. • The Director and the Chair of the Commission will communicate regularly to ensure that the Commission and the Director's Office actions and activities are supportive of each other and aligned with Commission policy direction and the success of the Department.
Part III: Performance Evaluation Process • The Commission will conduct an evaluation of the Director's performance of his responsibilities during an executive session of the full Commission. • The Director's evaluation will be based on the Executive Performance Elements contained in Attachment A and the Priority Actions contained in Attachment B.
Date Dat(r 7
Washin gton Fish and Wildlife Commission Director's Performan ce Agreement Page 2
Executive Conduct
Overall Conduct The Director must assure that no organizational practices, activities, decisions, or circumstances are allowed that are unlawful, imprudent, or in violation of commonly accepted business and professional ethics and practices.
Work Ethic The Director must act as a role model for staff. The Director is expected to be personally accountable for the accomplishments and shortcomings of the agency. The Director is expected to assume di rect responsibility for all aspects of agency leadership.
Strategic and Visionary Leadership The Director must demonstrate strategic and visionary leadership. The Director is expected to assess and decide the best way to achieve substantial cost savings, while preserving critical functions and increasing agency efficiency. He must lay the foundation for a stronger and more effective and respected agency, by directing the strategic elimination oflower priority activities and the consolidation of effort and energy in higher priority programs.
Problem Solving The Director should make progress in resolving longstanding problems. The Director is expected to be energetic and creative in looking for innovative means to address priority issues and conflicts among constituent groups. He must actively seek out new ideas and methods that may be brought to bear to advance the agency's mission.
Conservation Ethic The Director must be motivated by a strong conserYation ethic: a determination to place the highest priori ty on the long-term interests of the resources and their habitat. The interests of the public and specific user-groups are important , but they cannot supersede the welfare of the fish and wildlife populations we are charged with managing. The Director must establish a record of makin g decisions that will lead to the recover y of depleted resources.
Performance and Accountability The Director must keep the workforce motivated to pursue excellence. The Director is expected to set high standards for performance and foster a climate in which all employees strive to meet those standards. He is also expected to see that supervisors provide regular positive reinforcement to recognize excellence. He must demonstrate expertise in management techniques that effectively hold employees accountable.
Resource Management Expertise
Scientific Rigor The Director must work closely with the scientific community in building a defensible scientific basis for resource management. He is expected to have a working understanding of scientific analyses and quantitative methods used to study fish and wildlife population dynamics as well as the health and productivity of habitats.
Washington Fish and Wildlife Commission Director's Performance Agreement Attachment Page I
Integrated Resource Management The most effective approach to species management considers the full range of factors affecting ecosystem services including predator-prey dynamics, habitat conditions, and socio-economic values. The Director should pursue this approach to maximize effectiveness of service delivery.
Enhance Recreational Opportunities Within the capability of the land and other resources , enhancement of wildlife related recreational opportunities is among the highest priorities for the agency. A dedicated effort should be made to explore options for enhancing and expanding recreational opportunities.
Maintain the Stability and Economic Well Being of the Commercial Fishing Industry A dedicated effort should be made to assess, monitor , and enhance the stability and economic well being of the commercial fishing industry.
Collaboration and Communication Competencies
Strengthen and Modernize Communications Agency communications are a "mission-critical" function that must keep pace with contemporary times. Implementation of a clearly articulated agency communication strategy is a high priority.
Enhance Tribal Relationships Washington is home to Indian Tribes that in many cases have overlapping authorities and jurisdictions relative to the management of fish and wildlife resources. The Director is expected to maintain and enhance the Department' s working relationships with the tribes and seek to manage resources consistent with joint management plans where appropriate.
Working with Stakeholders The Director is expected to have a personal manner that works well with constituents from all backgrounds. He must approach his authorities and responsibilities with humility and open mindedness. He is expected to display an attitude that inspires others to join in collaborative processes, because they are confident of being treated fairly. He is expected to maintain a profe ssional demeanor.
Expand Opportunities with Environmental and Non-Traditional Constituents Recreationists who do not hunt or fish, but appreciate wildlife, are important constituents for the agency. Surveys have shown that these "non-traditional" stakeholders represent a significant portion of the public in Washington State. Ways to establish new relationships with these constituents and enlist their support should be found.
Washington Fish and Wildl ife Commission Director's Performance Agreement Attachm ent Page 2
Goal 1: Conserve and protect native fish and wildlife Aqencv Strategy Deliverable for 2013-15 Program Implement Wolf Conservation and 1. Attempt to radio-mark at least one wolf from each confirmed wolf pack. Wildlife Management Plan to recover wolves while 2. Provide technical assistance and pursue cost-share agreements with livestock Wildlife addressing wolf-livestock and wolf - operators to avoid and minimize wolf -livestock conflicts. ungulate conflicts. 3. Monitor ungulate populations to determine potential wolf impacts. Wildlife Implement actions to reduce risks to 4. Complete planned hatchery repairs and improvements to enhance fish production. CAMP native salmon and steelhead from 5. Implement improved broodstock management for hatchery programs consistent Fish operating hatcheries. with the goal of achieving the HSRG broodstock standards for all hatchery programs by 2015. 6. Evaluate alternative hatchery production options to provide increased fishing Fish opportunities for recreational and commercial fishers. Improve effectiveness of HPA Program to 7. Approved culvert water crossing and marine bank protection hydraulic projects Habitat protect fish life. show compliance and effectiveness. Ensure impacts to native fish from 8. Provide a report on at-risk stocks of wild steelhead , limiting factors, recommended Fish fisheries are consistent with conservation management actions, and implementation of the Statewide Steelhead goals. Management Plan. 9. Evaluate alternative approaches and develop an improved approach for the Fish management of Puget Sound Chinook under the Endangered Species Act. 10. Complete by December 1, 2013 annual fishery management plans for coastal Fish steelhead that meet conservation and catch-sharing objectives. 11. Enhance the effectivenes s of Zone 6 commerci al fisheries rules by working with the Enforcement tribes and ODFW to implement concurrent regulations for the Zone 6 fishery. and Fish 12. Develop with the Quinault Tribe a consistent fishery management approach for Fish Grays Harbor Chinook and coho salmon. Increase WDFW leadership and 13. Lead monitoring efforts and secure BPA funding to conduct restoration activities Habitat participation in conducting restoration on DFW lands and to coordinate restoration and monitoring throughout the basin. activities in the Columbia Basin. Correct fish passage barriers on county 14.Identify and prioritize county and city owned fish passage barriers for correction. Habitat and city lands and implement provisions Implement monitoring of all road crossings on WDFW lands to ensure continued from U.S. v. Washington case. compliance with the court injunction. Establish PHS as the agency's primary tool 15. Update PHS data and management recommendations. Develop cross program Habitat that identifies habitats and species to process to prioritize habitats and species in PHS. protect.
Goal 1: Conserve and protect native fish and wildlife (continued) Agency Strateqy Deliverable for 2013-15 Program Establish desired ecological conditions on WDFW Wildlife Area s and evaluate their status using ecological integrity assessments . 16.Implement pilot program to use citizen science volunteers to conduct ecological monitoring at four wildlife areas. Wildlife Prepare for future conditions that will result from climate change. 17.Adaptation strategies to climate change are developed for the future sustainabili ty of Washington 's priority habitats and species. Habitat Enhance laws and regulations to improve the implementation of aquatic invasive species (AIS) prevention sta ndards to prevent the spread of AIS in Washington. 18. Prepare a legislative package for the 2014 session that will improve enforceability of AIS laws and rules, reduce risks of AIS, and provide for enhanced penalties and fees. Fish and Enforcement
Goal 2: Provide sustainable fishina. huntinQ, and other wildlife-related recreational and commercial experiences Aqency Strateqy Deliverable for 2013-15 Program Advance implementation of mark selective fisheries through focusing on alternative commercial fishing gear in the Lower Columbia River. 19. Create an industry advisory board and complete other steps necessary to implement an ex perimental fishery with alternative mark-selective commerci al fishing gear. 20. Test and report on the effectiveness of alternative commercial fishing gear and recommend release mortality rates to use in fishery management. Fish
Fish Find innovative ways to improve access to public and private lands to enjoy fishing, hunting and other outdoor recreational opportunities. 21. Promote recreational opportunities on WDFW lands based on the Wildlife Program's "recreation identity" initiative. 22. Expand publicity about Puget Sound diving opportunities. 23. Work with Washington Tourism Alliance (WTA) to promote non-consumptive recreation opportunities in WTA's Experience Washington promotions. 24. Complete the Hunt by Reservation System by the fall 2013 hunting seasons . 25. Complete access area projects funded by the Legislature in the capital budget. 26. Provide ADA accessible facilities where appropriate. PA & CR and Wildlife PA & CR PA & CR
Wildlife CAMP Wildlife Prevent the illegal taking and trafficking of fish and wildlife species. 27. Develop,with other state agencies and the tribes, a strategy to improve the effectiveness of catch accounting in tribal and state managed fisher ies that includes a scoping assessment of the need, feasibility, and cost to implement an electron ic fish ticket system for all commercial fisheries and an electronic, certification tagging system for tracking shellfish. Enforcement and Fish Improve methodology of estimating status of fish and wildlife populations and harvest modeling. 28. Complete fieldwork and initiate analysis to estimate the abundance of PS rockfish. 29. Develop an improved moose population estimate. Fish
Wildlife
Goal3: Promote a healthy economy, protect community character, maintain an overall high quality of life, and deliver high-quality customer service. Agency Strategy Deliverable for 2013 -15 Program Increase recruitment and retention of customers by improving the marketing of fishing, hunting, and wildlife watching opportunities. 30. Establish a WDFW marketing team to work with the Director to establish agency- wide priorities and adopt strategies and performance measures. PA & CR Timely and effective measures are provided in response to wildlife-related conflicts. 31. Transition certain problem wildlife responsibilities from Enforcement to Wildlife Prograrri in FY14. Wildlife Increase WDFW outreach to key stakeholders and the public to improve citizen engagement and participation in the Department's decision-making processes. 32. Improve the effectiveness and transparency of the North of Falcon process by providing a web page for public comment and the posting of fishery performance information (including treaty-non-treaty sharing of impacts). 33. Engage stakeholders and the public in the development and completion of an enhanced Grays Harbor sal mon and sturgeon management framework. 34. Conduct targeted outreach to recreational organizations rega rding the results of HPA and fish passage proqram improvements. Fish and PA & CR
Fish
Habitat Promote the value and economic benefits of WDFW -managed programs by expanding communication with local community and business leaders. 35. Develop new and enhanced partnerships with recreation advocates and business associations to promote the economic, environmental and community benefits of WDFW programs. 36. Meet with local and regional economic development councils,tourism bureaus and chambers of commerce to share information and identify opportunities for collaboration. 37. Publicize the economic and job impacts of WDFW outsou rcing of construction work to local contractors around the state. PA & CR
PA & CR
PA & CR Goal 4: BuHd an effective and efficient organization by supporting our workforce,. improving business processes, and investing in technolOQv. Agency Strategy Deliverable for 2013-15 Increase workforce satisfaction and productivity by investing in a comprehensive agency training program and career development process. 38. Develop a Department training and career development program that improves employee knowledge,skills,and abilities and supports succession within the Department. All Programs Improve agency processes by creating a Lean culture. 39. Develop a long-range plan to create a culture of continuous improvement (Lean) within the Department and implement priority process improvement projects during the biennium. Lean Office
It is good to see more and more folks pushing for change. Atta boy for Duane & Joe for the effort to get more folks involved.
Anglers protest Grays Harbor gill netting
December 26, 2013
KXRO Newsradio
Anglers are asking the Washington Fish & Wildlife Commission to ban commercial gill netting in Grays Harbor and are trying to get at least 300 people to the January 11 commission meeting in Olympia.
“Failure to meet escapement needs, 7 or 8 out of the 12 past years on different rivers in the basin . . . Not acceptable!” said Duane Inglin, one of the event’s organizers. “It’s also not in line with what the commission recognizes as a successful management strategy.”
Their plan is to “Let the commission know that it is no longer acceptable for WDFW to spend 250,000.00 to 300,000.00 per year on over-seeing a commercial fishery for 20 to 30 commercial fishermen. Spend that money on hatchery production and reform. Boost the numbers in the basin, providing more opportunity for the thousands of sports fishers who spend hundreds of thousands of dollars, in that region. “
According to organizers, the January 11th meeting will be the last time to speak in front of the commission prior to their February 14th vote on the Grays Harbor Management Plan.
Hi I am a bit new here. I was just wanting to share my book with everyone. It is FREE on Amazon right now and it is about How to Smoke Salmon. http://www.amazon.com/dp/B00H7JHQGI. I also made the movie Smokin' Fish that is on PBS right now. Please enjoy and let me know if there is somewhere else I should post this. Thanks. Cory Mann
mmmmmmm, Steve Thiesfeld.......interesting move on WDFW's part.....I didn't like the options,of personnel, within R6. Guess we'll see which way the wind blows.....very soon.
Finally, I know folks are curious about my background, so here’s some information that might be helpful: I grew up in Yakima and spent all of my formative years there. I have Bachelor’s and Master’s in Fisheries from the University of Washington and proudly wear a lot of purple! . My first job was in central Oregon for ODFW where I worked for 10 years. I was the assistant district fish biologist in Prineville and then conducted research on kokanee in Lake Billy Chinook. I came back to Washington in 1999 as an Area Habitat Biologist in Port Orchard processing HPAs for marine projects. I then transferred to the fish program and conducted research on bull trout in the White Salmon and Klickitat river basins. In 2002, I waded into the world of salmon management as the Puget Sound Recreational Salmon Fishery Manager. In 2008, commercial management was added to my duties as the Puget Sound Salmon Manager. In addition to managing the Puget Sound commercial and recreational fisheries, I also administer the Puget Sound Recreational Fisheries Enhancement Fund that provides funding for a number of hatchery programs; and I’ve served as both the state technical representative and alternate panel member on the Fraser River Panel. I am an avid outdoorsman and spend most of my free time fishing for steelhead, salmon and halibut; or hunting deer and elk.
I wish you and your families a healthy and happy New Year!
We will most likely miss him in Puget Sound but he has set the agenda well for his replacement, so we at least have a good starting point for his replacement. He will be good for grays harbor.
His first order of business seems to be contacting each of us WDFW advisors in the area & wanting a personal meeting with each to get to know us & where/how we fish the area.
I told him to bring a large notebook as I have a wish list & a gripe list, his comment was "fine, we can get to that later, I but the first order of business is to get to know you all first".
As Dave said, I have known him for years through the NOF process of Puget Sound. Your first impression of him is just a country boy, don't let that fool you. I believe at least he will not lie to us.
Bit of C&P here but I thought this legal opinion from the AG interesting. I high lighted a couple of key things but look the the legal definition of HOW the WDF&W managed sport fisheries at that time and not much has changed.
1970 Honorable Duane L. Berentson State Representative, 40th District P. O. Box 426 Burlington, Washington 98233 Cite as: AGO 1970 No. 15 Dear Sir: By letter previously acknowledged, you have requested the opinion of this office on a question which we paraphrase as follows: May the director of fisheries lawfully close a given area to commercial fishing without also closing it to sports fishing? We answer your question in the affirmative subject to the qualification set forth in our analysis below. ANALYSIS The regulatory powers of the director of fisheries are set forth in RCW 75.08.080, as follows: "The director shall investigate the habits, supply and economic use of, and classify, the food fish and shellfish in the waters of the state and the offshore waters, and [[Orig. Op. Page 2]] from time to time, make, adopt, amend, and promulgate rules and regulations as follows: "(1) Specifying the times when the taking of any or all the various classes of food fish and shellfish is lawful or prohibited. "(2) Specifying and defining the areas, places and waters in which the taking and possession of the various classes of food fish and shellfish is lawful or prohibited. "(3) Specifying and defining the types and sizes of gear, appliances, or other means that may be lawfully used in taking the various classes of food fish and shellfish, and specifying the times, places, and manner in which it shall be lawful to possess or use the same. "(4) Regulating the possession, disposal, and sale of food fish and shellfish within the state, whether acquired within or without the state, and specifying the times when the possession, disposal, or sale of the various species of food fish or shellfish is prohibited. "(5) Regulating the prevention and suppression of all infectious, contagious, dangerous, and communicable diseases and pests affecting food fish and shellfish. "(6) The fixing of the size, sex, numbers, and amounts of the various classes of food fish and shellfish that may be taken, possessed, sold, or disposed of. "(7) Regulating the landing of the various classes of food fish and shellfish or parts thereof within the state. "(8) Regulating the destruction of predatory seals and sea lions and other predators destructive of food fish or shellfish, and specifying the proof of the destruction of the same that shall be required. [[Orig. Op. Page 3]] "(9) Specifying the statistical and biological reports that shall be required from licensed or nonlicensed fishermen, dealers, boathouses, handlers, or processors of food fish and shellfish. "(10) Specifying which species of marine and freshwater life are food fish and shellfish. "(11) Classifying the species of food fish and shellfish or parts thereof that may be used for purposes other than human consumption. "(12) Promulgating such other rules and regulations as may be necessary to carry out the provisions of this title and the purposes and duties of the department. "Subdivisions (1), (2), (3), (4), (6), and (7), shall not apply to licensed oyster farms or oysters produced thereon." By its enactment of subsections (1)-(4), (6), (9) and (12) of this statute, the legislature has clearly granted to the director the authority, in regulating the taking of food fish and shellfish, to specify seasons, areas, gear, maximum catch and possession limits and allowable sales and disposition of catch, and to require certain statistical reports for various segments of the state fishery. However, sound management of the total fishery resource has necessitated the enactment of different regulations for sports fishing (angling) than for commercial fishing. Basically, the sports fisheries are managed so as to allow large numbers of fishermen each to take a limited number of fish. Lawful gear for angling is defined in RCW 75.04.100 as one pole, held in hand, to which not more than two single hooks may be attached. Under WAC 220-56-063 and 220-56-066, most rivers, streams and ocean areas are open to angling. Spawning areas and areas below dams and racks are closed to angling, and other areas can and have been closed when such closures were necessary for proper escapement. Possession and bag limits for angling vary for different areas. For the coastal fishery the limit is three salmon of not less than 20 inches in length, as provided for in WAC 220-56-013. No license is required for angling, but [[Orig. Op. Page 4]] sports catches must be recorded upon salmon punch cards which are returned to the department of fisheries. See, WAC 220-56-023. Fish taken by angling are for personal use only and may not be sold commercially.On the other hand, the commercial fisheries are managed to allow for proper escapement and maximum commercial take. The legislature has established license requirements for all segments of the commercial fishery, and has defined lawful gear under the various licenses. See, chapter 75.28 RCW. Areas open to commercial fishing are set by statute (chapter 75.18 RCW) and permanent regulations (WAC 220-47-010 through 220-47-070) promulgated thereunder. Data for the commercial fisheries is collected continuously by the department of fisheries, and additional closures and regulations are frequently made by emergency regulation to preserve necessary escapement as mandated by fishery data and recommendations of the international salmon fishery commission. The Washington supreme court has consistently upheld the authority of the director of fisheries to prohibit the use of certain specified gear in a given area while leaving the same area open for the use of other gear. Thus, inBarker v. State Fish Commission, 88 Wash. 73, 152 Pac. 537 (1915), the court upheld a regulation which effectively closed Puget Sound to gill net fishing while leaving the Sound open to purse seine net fishing. And inVail v. Seaborg, 120 Wash. 126, 207 Pac. 15 (1922), the court upheld a regulation which closed Puget Sound to commercial gear while leaving it open to hook and line fishing. Subsequently, inMcMillan v. Sims, 132 Wash. 265, 231 Pac. 943 (1925), the court upheld a regulation closing Skagit Bay to commercial fishing while allowing the area to remain open to hook and line fishing. The court has specifically rejected the contention that opening specified areas only to certain gear or types of fishing violates the equal protection and the privilege and immunity clauses of the federal and state Constitutions, respectively.1/ See,State v. Tice, 69 Wash. 403, 125 Pac. 168 (1912); Barker v. State Fish Commission, supra; and Frach v. Schoettler, 46 Wn.2d 281, 280 P.2d 1038 (1955). In theBarker case, in denying the allegations that a [[Orig. Op. Page 5]] prohibition against gill nets was discriminatory, the court stated at pp. 76-77: "It seems plain to us that this is not a discrimination between, or a classification of, persons; but only a discrimination as to appliances which may be used; and that as to each class of such appliances, every person may use them under exactly the same conditions and restrictions. There is no suggestion in the law that gill nets may not be used as the law prescribes by all persons, or that purse and drag seines may not be used as the law prescribes by all persons. There is plainly no discrimination touching any characteristic or quality attaching to the person of appellants or any other person. "It has become the settled law of this state, in harmony with the rule prevailing in other states, that the classification of territory in game and fish laws preventing hunting or fishing in a portion of the state and permitting it elsewhere in the state is not a discrimination between, or a classification of, persons in violation of the state or Federal constitutional guaranties here invoked. Hayes v. Territory, 2 Wash. Terr. 286, 5 Pac. 927; State v. Tice, 69 Wash. 403, 125 Pac. 168, 41 L.R.A. (N.S.) 469;Cawsey v. Brickey, 82 Wash. 653, 144 Pac. 938. Among the numerous decisions of other states so holding we note: Portland Fish Co. v. Benson, 56 Ore. 147, 108 Pac. 122; Bittenhaus v. Johnston, 92 Wis. 588, 66 N.W. 805, 32 L.R.A. 380. "Classification of methods of taking fish, making certain methods lawful and other methods unlawful, has been held not to discriminate between persons in violation of any constitutional right. State v. Lewis, 134 Ind. 250, 33 N.E. 1024, 20 L.R.A. 52; State v. Mrozinski, 59 Minn. 465, 61 N.W. 560, 27 L.R.A. 76." The conclusion to be drawn from these cases in terms of the question which you have posed, is that the director of [[Orig. Op. Page 6]] fisheries has the authority to close a given area to commercial fishing without also closing it to sports fishing where his action is taken for the purposes of conservation, protection and proper management of the state's fisheries. Furthermore, we should add that we view this conclusion as being fully consistent with that which was reached in AGO 59-60 No. 127, which you have referred to in your request. In that 1959 opinion to a previous director of fisheries, we advised that the director could not close an area to commercial fishing for the sole purpose of establishing an area for sports fishing pointing out there, as we have here, that the underlying requirement which the director must meet in promulgating regulations is that his action must be reasonable in terms of his responsibility for the management and conservation of the fishery resource. The problem, in the case considered in this prior opinion, was that no conservation or management goals were involved; instead, the proposed closure would have been made to keep commercial boats out of a given area solely for the purpose of promoting sports fishing in that area, and thus (we concluded) would have been arbitrary and capricious. We trust the foregoing will be of assistance to you. Very truly yours, SLADE GORTON Attorney General WILLIAM LEMKE Assistant Attorney General *** FOOTNOTES *** 1/United States Constitution, Amendment 14 and Washington Constitution, Article I, § 12.
More on the C&P bit but it is the fact that the AG said the NT buy back boats were a no go to use in Washington if sold to a tribal fisher as they are commercial. Kinda interesting how WDF&W staff forget things.
October 8, 1975 Honorable Donald W. Moos Director, Department of Fisheries Room 115, General Administration Building Olympia, Washington 98504 Cite as: AGLO 1975 No. 87 Dear Sir: This is written in response to your recent request for our opinion on a question which we paraphrase as follows: If the department of fisheries purchases commercial fishing vessels under chapter 183, Laws of 1975, 1st Ex. Sess., may the department then sell those vessels to Indians residing in this state for their use in commercial fishing activities in Washington waters? We answer this question in the negative for the reasons set forth in our analysis.
ANALYSIS Chapter 183, Laws of 1975, 1st Ex. Sess., which was passed by the legislature last June, authorizes the state department of fisheries to purchase commercial fishing vessels and appurtenant gear from the private owners thereof under certain specified circumstances. See, § 4, which reads, in full, as follows: "The department is authorized to purchase commercial fishing vessels and appurtenant gear, and the appropriate current commercial fishing licenses and delivery permits issued by the state of Washington if the vessel, licensee or permit holder: "(1) Was licensed to fish or deliver fish during 1974 within the case area; and "(2) Was substantially restricted in its fishing season in 1974 by the department as a result of compliance with United States of America et al v. State of Washington et al., Civil No. 9213, United States District Court for Western District of Washington, February [[Orig. Op. Page 2]] 12, 1974. "The department shall not purchase any vessel without also purchasing all appropriate current Washington commercial fishing licenses and delivery permits issued to such vessel or its owner: PROVIDED, That the department is authorized to purchase current licenses and delivery permits in the absence of the purchase of a vessel." The underlying basis for such purchases of commercial fishing vessels and gear is spelled out in § 2 of the act as follows: "The legislature finds that the protection, welfare, and economic well-being of the commercial fishing industry is important to the people of this state. There presently exists an overabundance of commercial fishing gear in our state waters which causes great pressure on the fishing resources. This results in great economic waste to the state and prohibits conservation and harvesting programs from achieving their goals. This adverse sitation has been compounded by the recent federal court decision, United States of America et al. v. State of Washington et al., Civil No. 9213, United States District Court for the Western District of Washington, February 12, 1974. As a result, large numbers of commercial fishermen face personal economic hardship and the state commercial fishing industry is confronted with economic difficulty. The public welfare requires that the state have the authority to purchase commercial fishing vessels, licenses, gear, and permits offered for sale, as appropriate, in a manner which will provide relief to the individual vessel owner,and which will effect a reduction in the amount of commercial fishing gear in use in the state so as to insure increased economic opportunity for those persons in the industry and to insure that sound scientific conservation and harvesting programs can be carried out. It is the intention of the legislature to provide relief to commercial fishermen adversely affected by the current economic situation in the state fishery and to preserve this valuable state industry and these natural resources." (Emphasis supplied.) [[Orig. Op. Page 3]] Consistent with this declaration of policy to remove surplus commercial fishing vessels and gear from use for that purpose, § 6 of the act, upon which our answer to your question depends, then provides that: "The department may arrange for the insurance and storage and for the resale or other disposition of all vessels and gear purchased pursuant to this 1975 amendatory act. Such vessels shall not be used by any owner or operator as a fishing vessel other than as a vessel used for angling or other personal use in waters within the state of Washington, nor shall such vessels be used by any owner or operator to deliver fish within the boundaries of the state of Washington. The department shall require that the purchasers or other users of vessels resold or otherwise disposed of by the department execute any and all suitable instruments to insure compliance with the requirements of this section. The director may commence suit or be sued on any such instrument in any state court of record or United States district court having jurisdiction." This section of the act, as you will readily note, expressly permits the department, among other things, to ". . . arrange for the . . . resale . . . of all vessels and gear purchased pursuant to . . ." the act. Any vessels so disposed of by the department, however, can only be legally used by the purchasers thereof, within the waters of the state of Washington, for ". . . angling or other personal use. . ."; conversely, the vessels ". . . shall not be used by an owner or operator as a fishing vessel . . . " other than in the foregoing manner. Section 7 of the act then adds sanctions to this prohibition by providing for criminal penalties as follows: "Any person violating any of the provisions of this 1975 amendatory act, or of any of the rules or regulations of the director made pursuant thereto, or who aids or abets or assists in the violation thereof, shall be guilty of a gross misdemeanor, and upon a conviction thereof shall be punished by imprisonment for not less than thirty days or more than one year, or by a fine of not [[Orig. Op. Page 4]] less than twenty-five dollars or more than one thousand dollars, or both. Upon conviction of any person of a violation of any provision of this 1975 amendatory act, or rule or regulation of the director, the judge or justice of the peace may, in addition to the penalty imposed by law, provide for the forfeiture of the vessel and licenses and/or permits to the state of Washington." Based upon the foregoing, it will be seen that while the department of fisheries may sell any of the vessels in question to Indians residing in this state, they will be subject to the same restrictions as apply to any other purchasers and thus will be barred from using the vessels for fishing in any other manner than by what is referred to in § 6, supra, as angling. In effect, all purchasers, be they Indian or non-Indian, will be barred from using the vessels in Washington waters for the basic purchase for which they are designed - i.e., commercial fishing with normal commercial fishing gear. Thus, we answer your question, as paraphrased, in the negative. We trust that the foregoing will be of some assistance to you. Very truly yours, SLADE GORTON Attorney General EDWARD B. MACKIE Deputy Attorney General OFFICES AND OFFICERS - STATE - DIRECTOR OF FISHERIES - AUTHORITY OF DIRECTOR OF FISHERIES TO CLOSE AN AREA TO COMMERCIAL FISHING WITHOUT ALSO CLOSING TO SPORTS FISHING The director of fisheries may lawfully close a given area to commercial fishing without also closing it to sports fishing where his action is taken for the purposes of conservation and for the protection and proper management of the state's fisheries. - - - - - - - - - - - - - June 25, 1970
Hijacked and C&P this as Saturday is the day for everyone to let the commission know how they feel about the GHMP redo!
This Saturday at 9:00 am the Fisheries Commission will hear a report and take public input concerning the Grays Harbor Management Plan. Directions and the agenda are in the web site below (note that this is at the Comfort Inn and not WDFW): http://wdfw.wa.gov/commission/meetings/2014/01/agenda_jan1014.html
This is a good meeting to attend to show recreational support for the direction of fishing in Grays Harbor. At our meeting Tuesday night we discussed some potential issues that could be worth your effort to comment about. These were: 1)Accountability for meeting escapement, 2) Economic loss resulting from commercial fishing, 3) No need for three commercial fishing groups in Grays Harbor, and 4) Modeling efforts to harvest the last theoretical fish. There are many others, your input is important for the future direction of Grays Harbor fisheries.
A little reminder there is a Adviser meeting tonight folks at 6 PM Region 6 Office in Montesano on the GHMP redo. Now the public can not participate but there is 1 hour set aside at the end for public comment.
It is last call for the Grays Harbor Management Plan redo! The Commission added / made substantial changes to the draft plan presented by WDF&W and they should be up on the WDF&W website soon but the current draft is available at the link below. Otherwise guys the final public meeting to look & question the document is this coming Wednesday highlighted below.
January 13, 2014 Grays Harbor Advisory Committee, from 6-8 p.m.; public input from 8-9 p.m.; WDFW’s Montesano office, 48 Devonshire Road. January 15, 2014 WDFW fishery managers will host a public workshop from 6-8 p.m.; Montesano City Hall, 112 North Main Street, Montesano. WDFW fishery managers briefed the Fish and Wildlife Commission on the development of the draft policy during the commission’s November meeting in Olympia. WDFW will develop a range of policy options that will be discussed during the December commission meeting in Olympia. The commission is scheduled to hold a public hearing on the draft policy options during its January meeting in Olympia. The commission is scheduled to make a final decision at its February meeting in Olympia.
Commission seeks comments on revised draft policy for Grays Harbor fisheries OLYMPIA - The Washington Fish and Wildlife Commission is seeking public comments on a revised draft policy to improve salmon management in Grays Harbor. The revised draft policy includes new provisions recently proposed by the commission to conserve wild salmon runs, clarify catch allocation, and reduce conflicts between sport and commercial fishers in the harbor. The commission, a citizen panel that sets policy for the Washington Department of Fish and Wildlife (WDFW), added the new provisions during a public meeting attended by more than 150 fishers Jan. 10-11 in Tumwater. Ron Warren, deputy assistant director of WDFW's Fish Program, thanked the commission for adding provisions he said would provide the department with clear direction for setting future seasons for non-tribal salmon fisheries in Grays Harbor. "We need to focus on conserving and restoring the salmon runs in the Grays Harbor Basin," Warren said. The revised policy, scheduled for a vote by the commission at a meeting Feb. 7-8, is available at http://wdfw.wa.gov/conservation/fisheries/grays_harbor_salmon/ . Written comments on the revised draft policy may be submitted through Jan. 31 via email to commission@dfw.wa.gov or by mail to the Washington Fish and Wildlife Commission, 600 Capitol Way N., Olympia, WA 98501-1091. Commissioner Rolland Schmitten, who spoke in favor of the amendments, noted that fisheries in southeast Alaska and Canada intercept nearly half of all fall chinook salmon returning to the Chehalis River, which flows into Grays Harbor. "Our challenge is that there are simply not enough salmon to meet the expectations of all stakeholders," Schmitten said. In other business, the commission modified fishing rules for two rivers on opposite sides of the Cascade Range: • Naselle River: Fishing from a floating device equipped with an internal combustion motor was prohibited year round from the Highway 4 Bridge upstream to the Crown mainline (Salme) Bridge. The commission's action was based on a citizens' petition. • San Poil River: The daily limit for walleye was raised from eight fish to 16 fish to address an overpopulation of walleye in this tributary to Lake Roosevelt.
These comments to the Commission on the GHMP are authored by another individual ( who hangs out around here ) and a great example of just plain zeroing in on making sure the new plan can not be manipulated as the present one. Damn good job if I say so myself.
Draft Recommendation 5 states:
“ WDFW-managed commercial fisheries in the Grays Harbor Basin shall have the following impact limits:
Areas 2A, 2B, 2D: impact rate of less than 0.8% on Chehalis fall Chinook.
Area 2C: impact rate of less than 1.2% on Humptulips fall Chinook.”
This recommendation appears to be over specified or at least can be interpreted in several ways. It is important to understand that all areas contain both Chehalis fall Chinook and Humptulips fall Chinook, especially area 2C. As an example this recommendation could mean that when fishing in 2C the harvest will be capped at 1.2% Humptulips Chinook plus 0.2% of the comingled Chehalis Chinook. Then the 2A/2D fishery could still include another 0.8% of the Chehalis Chinook run plus another .02% of the Humptulips run. The actual numbers would be determined by using coded wire tag data in each area. This recommendation could also mean that all fish caught in 2C are Humptulips fall Chinook capped at 1.2% of the Humptulips run. This would also overharvest the Chehalis fall Chinook.
I would recommend the following modification to recommendation 5.
“ WDFW-managed commercial fisheries in the Grays Harbor Basin shall have the following impact limits:
Areas 2A, 2B, 2C, and 2D combined shall have an impact rate of less than 0.8% on Chehalis fall Chinook and less than 1.2% on Humptulips fall Chinook.”
Hey all I have not been able to post a update on the legal challenge to the 2013 season but it was settled out of court. So read through it and you will see it ends up addressing several key issues of the Grays Harbor Management Plan redo. I will do a second post with the talking points ( press release more / less ) shortly.
SETTLEMENT AGREEMENT
Hamilton, et al. v. Wash. Dep’t of Fish and Wildlife, Thurston Cnty. Sup. Ct. No. 13-2-01741-2 Hamilton, et al. v. Wash. Dep’t of Fish and Wildlife, Thurston Cnty. Sup. Ct. No. 13-2-02050-2
This Agreement is entered into on the date of last signature below by and between Tim Hamilton, Arthur Holman, and Ronald Schweitzer (Petitioners) and the Washington Department of Fish and Wildlife (Department).
RECITALS
Petitioners filed the above-referenced lawsuits challenging rules promulgated by the Department setting salmon fishing seasons for Willapa Bay and Grays Harbor, respectively, for 2013.
Petitioners and the Department both desire to facilitate enhanced communication between the Department and recreational fishers. We both want to ensure a strong technical foundation for salmon fishery management in both commercial and recreational fisheries in Willapa Bay and Grays Harbor, and we want to improve the integration of the North of Falcon fishery planning and APA rule processes.
Petitioners and the Department seek to settle these matters and resolve all claims between them related to the subject of the above-referenced matters.
AGREEMENT
Now, therefore, in consideration of the mutual promises contained herein, the parties agree as follows:
1) Petitioners agree to dismiss with prejudice the above-referenced lawsuits, without costs or attorney fees to either party. Such dismissal shall occur within 10 days of execution of this Agreement.
2) The Director will request the Washington Fish and Wildlife Commission to give him direction to initiate the development of a Willapa Bay Fishery Management Policy (Policy) after the Grays harbor Policy and the 2014 North of Falcon process has been completed. The Department will target having the new Willapa Bay policy process completed by February of 2015 and implemented through the 2015 North of Falcon process. In addition, following the adoption of the Policy, the Willapa Bay Management Plan will be revised in a manner consistent with the Policy.
3) The Department will establish a dedicated account and deposit $15,000 in such account to be used solely for procuring the consulting services of independent fishery scientists for tasks described herein. The initial task of the independent fishery scientists will be to review existing scientific studies and recommend appropriate release mortality rates for use by the Department to predict the mortality of fish released from state managed commercial gillnets in Grays Harbor (see 5a below). a. The independent fisheries scientists engaged pursuant to this paragraph shall be jointly selected by the parties and the scientists’ scope of work shall be jointly developed by the parties. b. The parties acknowledge that time is of the essence in engaging the scientists pursuant to this chapter and shall make best efforts to select and approve the scientists and the scope of work no later than February 14, 2014. If the scientific review and recommendations regarding release mortalities cannot be completed by March 14, 2014, as contemplated by the parties, then the work will and any recommendations will be completed by February 1, 2015 and used in the 2015 and subsequent preseason planning processes.
c. Additional tasks that will be considered and implemented by agreement of the parties utilizing any remaining funds from this account include the development of: 1) a Grays Harbor web page with a clear presentation of key information (i.e., catches, spawners, basis of spawner goals); 2) improved preseason predictions of salmon abundance; and 3) inseason estimates or indicators of salmon abundance.
4) The Department will provide $15,000 to a nonprofit organization established by Petitioners to enhance communication and build cooperation between the Department and recreational fishers. The Department shall make such payment within 10 days of receiving proof of an appropriate nonprofit organization having been established.
5) The nonprofit organization created by Petitioners shall, at a minimum, complete the following:
a. Assist the Department in the planning, promotion, and implementation of a workshop to ensure that the release mortality rates used for preseason planning of commercial fisheries in Grays Harbor are based on the best available information (Workshop 1 – February 2014). After the conclusion of the workshop, the panel of independent fishery scientists (paid for through the independent account created and funded pursuant to paragraph 3, above) will summarize scientific studies presented at the workshop and provide recommendations on release mortality rates.
b. Assist the Department in the planning, promotion, and implementation of a workshop to review the performance identify improved methods for predicting the catch in Grays Harbor Basin salmon fisheries (Workshop 2 - February 2014). Panelists will present information on the performance of previous catch projections, propose improvements, and solicit additional suggestions to improve preseason catch projections.
c. Assist the Department in the planning, promotion, and implementation of four workshops designed to improve understanding of salmon fishery management in the Grays Harbor Basin (Workshops 3-6). The workshops would occur prior to August, 2014.
d. Provide recommendations and suggestions to the Department on increasing public confidence in the Administrative Procedure Act (APA) rulemaking process for season-setting for Willapa and Grays Harbor.
6) The parties agree to work together to develop messaging and outreach to the public that accurately conveys this Agreement and the public process provided for in the Agreement. The parties shall not communicate about this Agreement or the public process provided for in the Agreement in a manner inconsistent with their jointly developed messaging and outreach plan.
7) The parties agree that they shall meet not less than monthly while the obligations under this Agreement are outstanding to discuss implementation of this Agreement. Each party may designate one or more representatives to attend such meetings and attendance may be by telephone or other electronic means. The parties will strive to cooperatively resolve any disagreements related to this Agreement. In the event either party has a disagreement with the other, that party shall communicate that disagreement during a meeting of the parties. Prior to initiating any legal action to enforce this Agreement, a party shall communicate in writing the subject of the disagreement and give the other party 30 days to respond.
8) This Agreement constitutes the entire agreement between the parties with respect to resolution of the above-entitled matters and the subject matter thereof. Any representations, promises, or statements not set forth in the Agreement are of no force and effect and have not been relied upon.
9) The language of all parts of this Agreement shall be construed as a whole, according to its fair meaning, and not strictly for or against any of the Parties. It has been negotiated by and between attorneys for the Parties and shall not be construed against either side as drafter. If any portion or provision of this Agreement is determined to be illegal, invalid, or unenforceable by any court of competent jurisdiction, the remainder of this Agreement shall not be affected by such determination and shall be valid and enforceable to the fullest extent permitted by law, and said illegal, invalid, or unenforceable portion or provision shall be deemed not to be a part of this Agreement.
10) This Agreement shall be governed by and construed in accordance with the laws of the state of Washington. Venue for any suit involving a dispute over this Agreement shall be Thurston County.
11) Each party agrees to be responsible for his own attorneys fees and costs associated with the above-referenced lawsuits and this Agreement.
Dated this __ day of January, 2014
TIM HAMILTON
Dated this __ day of January, 2014
ARTHUR HOLMAN
Dated this __ day of January, 2014
RONALD SCHWEITZER
Dated this __ day of January, 2014
______________________, TITLE _______________________ FOR THE DEPARTMENT OF FISH AND WIDLIFE
OK here are the " Talking Points Willapa Bay and Grays Harbor Settlement Agreement " and it gives you a little better read on things outlined in the settlement.
The Washington Department of Fish and Wildlife has completed a settlement agreement with Tim Hamilton, Art Holman, and Ron Schweitzer that resolves litigation regarding commercial fishing in Grays Harbor and Willapa Bay for the 2013 season. Rather than prolonging litigation, all parties have agreed to build on a shared interest in enhancing communication between the Department and recreational fishers, ensuring a strong technical foundation for salmon fishery management, and improving the integration of the North of Falcon fishery planning and the rules process. All parties recognize that salmon play an integral role in the commerce, recreation, and cultural identity of the people of the Pacific Northwest. This is particularly true along the Washington coast, where salmon are an economic mainstay for communities, a focal point for tribal life, and an important link between the ocean and interior ecosystems in Willapa Bay and Grays Harbor. The Agreement reflects a shared interest in the conservation of salmon in these basins and in building support for the salmon resources among commercial fishers, recreational fishers, and outdoor recreation enthusiasts. Key elements of the agreement include: • Ensuring a strong technical foundation for salmon fishery management by enlisting the assistance of independent fishery scientists to review the rates used to project the mortality of salmon released in commercial fisheries.
• Increasing the public’s ability to participate in season setting and fisheries management by developing a web page with Grays Harbor information on fishery catches, spawners, and the basis of spawner escapement goals.
• Initiating a series of workshops to:
o assist the public in understanding how fishery management in Grays Harbor is conducted, seasons are set, and the processes used; o increase the accuracy and reliability of models used to set fishing seasons; and o develop in-season indicators of salmon abundance to enable adaptive management.
• Director Anderson will request that the Fish and Wildlife Commission provide him with direction to initiate the development of a Willapa Bay Fishery Management Policy for implementation in the 2015 North of Falcon process. In addition, following adoption of the policy, the Willapa Bay Management Plan will be revised in a manner consistent with the policy. These elements of the agreement are designed to enhance conservation of the state’s salmon resource, improve public trust, and develop a solid foundation for a long-lasting relationship with all stakeholders.
2) The Director will request the Washington Fish and Wildlife Commission to give him direction to initiate the development of a Willapa Bay Fishery Management Policy (Policy) after the Grays harbor Policy and the 2014 North of Falcon process has been completed. The Department will target having the new Willapa Bay policy process completed by February of 2015 and implemented through the 2015 North of Falcon process. In addition, following the adoption of the Policy, the Willapa Bay Management Plan will be revised in a manner consistent with the Policy.
It says what it says and the outcome will depend upon what the Commission feels is correct. That said it means a Willapa redo with aoutcome not defined before hand.
Just a reminder, the deadline for submitting comments to the fish and wildlife commission is Jan. 31, following is the page I sent in, just a quick note saying how you feel about certain points in the report is all that is needed, public support for closing comm. gillnet fishing was really strong, following up with an equally strong amount of submitted comments is also vital. Commissioners, my name is Robert Rao and I live in Elma. I have spoken before you twice in the last two months and have attended numerous Gray’s Harbor Salmon Management meetings. I appreciate the hours you have put in on this subject hearing many points from the public and the W.D.F.W. staff. My points are as follows; The last lines of the general policy statement “In implementing the policy guidelines, the Department will work with the tribes in a manner that is consistent with U.S. v. Washington and other applicable state and federal laws and agreements “ I believe the state has an obligation legally and morally to defend the 50% percent rights of the citizens of the state by being proactive in monitoring tribal catches throughout the state, not just in Gray’s Harbor. A quicker and more reliable catch record system is needed. I also believe that closing area 2A in the Chehalis River if not this year but next year would have two important results. Public testimony by non-native commercial fishermen to this issue has stated that the tribe WILL NOT fish that area on the same days as commercial gillnetters. This means that a 4 days in and 3 days out will not be considered by the tribe in this area which means ALL of Gray’s Harbor will not have 4 days in and 3 days out by all gillnetters. The river is also very narrow in this area and numerous gillnets will defeat recovery actions taken. This also will be a negotiation point when dealing with the Quinalt tribe as it will show them that the state is serious about recovery efforts and is willing to compromise. There should be a total ban on commercial. gillnets in areas designated as freshwater to remain consistent with policies adopted for the Columbia River and Puget Sound. I believe the residents of our state have overwhelmingly shown their support for this direction as demonstrated in the sheer volume of public testimony shown. I also feel that more input to the Pacific Salmon Commission is needed as to the serious state of the runs in Gray’s Harbor. If a more valid scientific study is needed instead of current means of measuring run size then those studies should be implemented .Alaska harvests of our fish are esp. damaging, the state of Alaska stocks should be an example of how NOT to manage a resource. My third point concerns the language for the 4 days in and 3 days out. The language allows for changing the intent of 4 days in and 3 days out by saying “when possible”. As I have pointed out above we understand the state cannot promise the tribes will fish that way but to insure transparency of the process we need to know that the 4 days in and 3 days out means just that when talking about non-tribal gill-netters. Otherwise people may feel that a last minute ”back door deal” may occur again. My last point has to do with determining chum runs by lumping them all together in Gray’s Harbor. The scientific absurdity of this should be apparent to all. With these runs missing escapement as many years as they have (although we don’t have the data to show how really bad it is!) it is obvious that changes in scientific data collecting are needed. Thank you for reading and hearing our concerns. Robert Rao
A number of folks have been trying to understand the legal action and settlement. Well I am sure not going to try and explain it but you can view the write up by the East County guys who filed the legal action here. http://fishingthechehalis.net/nof-process The documents and supporting papers are all available for viewing and while it is a bit of a dry read ( as all legal documents are ) it is rather interesting.
The thing that takes a bit to understand is the legal action was on the 2013 season and season setting process. Our legal system does not exactly move along at lightning speed so it simply takes a bit to wind your way through the process and that is how you end up with a challenge to the 2013 seasons in 2014.
The Grays Harbor Management Plan ( GHMP ) redo is getting closer and it looks promising, maybe. That said it is not a done deal until "the fat lady sings" so to speak and everyone needs to stay involved. I imagine all have read or listened to that spiel a hundred times before but it is true. Then comes the question on just how can WDF&W manage the Salmon resource in a manner that simply discriminates and denies harvest opportunity to the inland communities and recreational fishers in general?
At first look one might think this is something new but it is not. It is simply the manner that terminal harvest impacts (inside Grays Harbor & rivers that empty into it ) have always been allocated. That WDF&W has always viewed the recreational fisher differently than commercial fishers is absolutely true but finding way to allow the average citizen to grasp how deeply ingrained in WDF&W this philosophy is can be a bit difficult.
So after going through the FTC library I will use the two paragraphs below which are taken directly from a opinion by then Washington State Attorney General Slade Gorton to then WDF Director Don Moos in 1975 which addressed the commercial buy backs. While the entire document is only somewhat relevant today it is one of the few times I have found the management philosophy of WDF&W clearly defined by a impartial 3rd party. So take a look at the highlighted sentences defining the intent of the recreational and commercial management by WDF&W.
Basically, the sports fisheries are managed so as to allow large numbers of fishermen each to take a limited number of fish. Lawful gear for angling is defined in RCW 75.04.100 as one pole, held in hand, to which not more than two single hooks may be attached. Under WAC 220-56-063 and 220-56-066, most rivers, streams and ocean areas are open to angling. Spawning areas and areas below dams and racks are closed to angling, and other areas can and have been closed when such closures were necessary for proper escapement. Possession and bag limits for angling vary for different areas. For the coastal fishery the limit is three salmon of not less than 20 inches in length, as provided for in WAC 220-56-013. No license is required for angling, but [[Orig. Op. Page 4]] sports catches must be recorded upon salmon punch cards which are returned to the department of fisheries. See, WAC 220-56-023. Fish taken by angling are for personal use only and may not be sold commercially.
On the other hand, the commercial fisheries are managed to allow for proper escapement and maximum commercial take.The legislature has established license requirements for all segments of the commercial fishery, and has defined lawful gear under the various licenses. See, chapter 75.28 RCW. Areas open to commercial fishing are set by statute (chapter 75.18 RCW) and permanent regulations (WAC 220-47-010 through 220-47-070) promulgated thereunder. Data for the commercial fisheries is collected continuously by the department of fisheries, and additional closures and regulations are frequently made by emergency regulation to preserve necessary escapement as mandated by fishery data and recommendations of the international salmon fishery commission.
Boiled down to the very basic issues the GHMP redo is not just about what is fair for all citizens but changing the historical bias ingrained within WDF&W. No small chore to be sure and it will not happen unless we all stay involved. The progress made in the past few months is not due to FTC or any single person or group but rather because the inland communities & recreational fishers did not just object but went with " oh hell no we are NOT doing that again. "
So stay involved folks and attend the Commission meeting Meeting Link A close friend of mine said " it ain't no time to go to sleep at the wheel" and I think he captured where we are!
I do agree with rivrguy about being careful, but the forecast for Oly is now only 50% chance of less than a half inch tonight, and 30% chance of less than a half inch Saturday so nothing major.
a quick update. There is a light dusting of snow in Oly, enough to make the street in front of my house white. Currently not snowing. I would guess it is about 1/4 inch.
The LONG and winding road has finally led to a BIG win for the fish and for the rec community in Grays Harbor.
Key conservation provisions of the GHMP unanimously passed by the commission today:
1) Secured a 3 consecutive days/wk net-free escapement window
2) Must meet escapement goals for each stock at least 3 out of the 5 previous years in order to have directed fishing on that stock. Else manage for a NT impact of 5%.
3) Affirmed that Hump and Chehalis sub-basins shall be managed as distinct and separate drainages
4) Chehalis fall kings are allocated 0.8% to the state nets at low abundance to 5.8% at high abundance on a linear sliding scale between run sizes of 18K to 25K. For clarity, the comm share slides from about 2% up to 27% of the total state share.
5) Humptulips fall kings will fall under similar provisions starting at 1.2% at the low end and 5.6% (memory may be a bit shaky on that upper number)
A HUGE step forward in improving the management of Grays Harbor.
I'll post the official link to the policy when its up on the web.
Chair Wecker's closing comments included a commitment on the record to better determine release mortalities in both the comm and rec fisheries… about this policy being a new beginning to push the agency forward in implementing fisheries that improve our ability to selectively release depressed NON-target stocks unharmed.
a quick update. There is a light dusting of snow in Oly, enough to make the street in front of my house white. Currently not snowing. I would guess it is about 1/4 inch.
Good thing the meeting was this morning, there's been about 5" in the last 6 hours. Looks like it's stopped now.
I think Doc about captured what was adopted yesterday and until it is posted nothing much to add on the verbiage. The thing is is this another leg of the journey that more or less is coming together in four stages. So the first steps have been taken so what is next one might ask? The harvest model & mortalities which Chair Wecker addressed Saturday.
Quote:
Chair Wecker's closing comments included a commitment on the record to better determine release mortalities in both the comm and rec fisheries… about this policy being a new beginning to push the agency forward in implementing fisheries that improve our ability to selectively release depressed NON-target stocks unharmed.
This issue is being addressed almost daily as agency staff and the litigants work to finalize the time line as part of the settlement of the legal action taken by three East County citizens that was settled out of court. The entire settlement can be viewed here http://fishingthechehalis.net/nof-process but the points below are the most relevant at the moment.
a. Assist the Department in the planning, promotion, and implementation of a workshop to ensure that the release mortality rates used for preseason planning of commercial fisheries in Grays Harbor are based on the best available information (Workshop 1 -February 2014). After the conclusion of the workshop, the panel of independent fishery scientists (paid for through the independent account created and funded pursuant to paragraph 3, above) will summarize scientific studies presented at the workshop and provide recommendations on release mortality rates.
b. Assist the Department in the planning, promotion, and implementation of a workshop to review the performance identify improved methods for predicting the catch in Grays Harbor Basin salmon fisheries (Workshop 2 - February 2014). Panelists will present information on the performance of previous catch projections, propose improvements, and solicit additional suggestions to improve preseason catch projections.
c. Assist the Department in the planning, promotion, and implementation of four workshops designed to improve understanding of salmon fishery management in the Grays Harbor Basin (Workshops 3-6). The workshops would occur prior to August, 2014.
The third leg of the GHMP reform effort will revolve around incorporating the policy guidelines adopted into the verbiage & Tiers in the GHMP. One more time we all need to stay engaged and track this process as the agency has a real habit of taking a clear statement and giving it the " fuzzy wuzzy " treatment.
The final element will be when the 2014 NOF process goes forward to set seasons for 2014 based upon the reformed GHMP. I & others have gotten the infamous crystal ball out to look into the future and guess what, we do not have a clue. When everything outlined in this post ( and previous post ) are completed the fall salmon seasons are going to be different than in the past to be sure. Moving toward harvest management that places the fish and conservation first is not going to be painless for any of the users.
It is the price all will pay for the abuses by WDF&W in the past.
This is a article from the Montesano Vidette that provides additional information on the upcoming process that will be the bases for developing accuracy in the harvest model. It is part of the out of court settlement between WDF&W and the East County guys that sued over the 2013 settlement.
By Steven Friederich Vidette Editor
OLYMPIA — The state Department of Fish & Wildlife has settled a lawsuit with three recreational fishing advocates from Grays Harbor, promising to demystify the regulatory process that governs the way fishing rules are made and enforced on the Twin Harbors. Tim Hamilton of McCleary joined with Art Holman of Aberdeen and Ron Schweitzer of Elma to file the lawsuit last fall, alleging that state agency officials are allowing commercial gillnetters open season and unfettered access to gobble up salmon to the destruction of fish runs.
They had sought injunctions to shut down the commercial gillnetting season on Willapa Harbor and on Grays Harbor. The judge denied the injunctions, but said the lawsuit could continue. The biggest win for the advocates is that the state Department of Fish & Wildlife will hire independent fishery scientists to see how often salmon are escaping the gill nets and actually making it upriver to spawn.
Recreational fishing advocates have said for years that commercial gillnetters, who who flank the river with 13 to 19 nets for several days at a time, are preventing a good number of fish from getting up the river to spawn or be caught by recreational fishermen, who pay annual fees to go fishing. Commercial gill nets are granted in excess of 80 percent of the salmon available for harvest each year. The gillnetters are only supposed to catch Coho salmon, but they often catch chum and Chinook, as well, which are supposed to be released back into the wild. But, records provided by Hamilton to back up his claim, that most of those salmon that are thrown back out into the Harbor end up dead and the state agency rarely meets its “escapement” goals in either the Willapa or Grays Harbor of salmon actually heading back upriver.
Meantime, the association for the gillnetters say they provide valuable jobs for the commercial fishing industry and help spur on the economy. The independent scientists, who will be chosen by both state Fish & Wildlife officials and a non-profit group created the three plaintiffs and “the scientists’ scope of work shall be jointly developed by the parties,” the settlement states. No one is accusing the Indian tribes, who also use gillnets, of doing anything wrong. The tribes are protected by special treaty.
The settlement calls on the state placing $15,000 into a special fund to pay for the independent review, as well as $15,000 to go to the new non-profit group, which Hamilton says is called Twin Harbor Fish & Wildlife Advocacy. “What we’ve done is set it up for an outside review, to look over what we’ve been saying all along,” Hamilton said. “We’re encouraged because the new rules being looked at makes sure that the salmon come first. Fish & Wildlife is moving forward with policy saying you will ensure we are getting enough of those fish back so the species survives for the future.”
The dispute the scientists will look at is how many salmon are really making it upriver and how many are just dying at the mouth of the river and are actually just surviving on paper, not in reality. The settlement states that Fish & Wildlife will create a dedicated website “with a clear presentation of key information,” including catches, spawners and basis of spawner goals and the state agency will improve its pre-season salmon prediction and its in-season indicators on if the salmon are surviving. The non-profit group will work with the state Department of Fish & Wildlife to conduct town hall meetings around the Twin Harbors to better explain its rules and provide recommendations on the mortality of salmon.
“What I want to be able to do is go out and hold a minimum of four local meetings to teach the population on how these seasons are set and the fisheries are managed so they understand the processes and how it all works,” Hamilton said. In addition, the settlement calls for a better management plan to be developed for Willapa Harbor, mirroring the process that will take place for Grays Harbor. The Grays Harbor fisheries watchdog website set up by the Hamilton brothers Tim and Dave, shall continue to exist. Nicknamed Fishileaks, the website is at http://fishingthechehalis.net and has become a go-to-resource for those on the Harbor trying to make sense of the rule-making process being undertaken by the state Fish & Wildlife Commission.
“Rather than prolonging litigation, all parties have agreed to build on a shared interest in enhancing communication between the Department and recreational fishers, ensuring a strong technical foundation for salmon fishery management, and improving the integration of the North of Falcon fishery planning and the rules process,” a joint statement from all of the parties said.
“All parties recognize that salmon play an integral role in the commerce, recreation, and cultural identity of the people of the Pacific Northwest,” the statement adds. “This is particularly true along the Washington coast, where salmon are an economic mainstay for communities, a focal point for tribal life, and an important link between the ocean and interior ecosystems in Willapa Bay and Grays Harbor. The Agreement reflects a shared interest in the conservation of salmon in these basins and in building support for the salmon resources among commercial fishers, recreational fishers, and outdoor recreation enthusiasts.”
Anybody have any idea how the release mortality studies will be conducted? Seems like something that would be really difficult to measure accurately. Maybe they'll start with a mutually-developed set of assumptions about relative fish condition at the time of release? Maybe they will somehow tag gillnet-caught fish that are released to see how many end up in another net? Survey the river bottom for marked carcasses when the fishery is completed? How about the rec side? That seems to be the most challenging of all.
These are interesting, exciting, times. Cool stuff!
Knowledge costs money. If "you" don't want to invest in the studies as they cost toomuch then don't do selective fisheries and live with the consequences.
The policy guidelines and the Power point presentation from the Commission meeting are out. If you want a copy e mail and I will send it. If you wait it will make up on the WDF&W website .... soon I think.
AND NOF FOR 2014
2014 North of Falcon schedule is now on the web: http://wdfw.wa.gov/fishing/northfalcon/ . Dates are listed below. There will also be 2 workshops to attend, dates to be determined.
2014 North of Falcon Public Meeting Schedule March 3 2014 Salmon Forecasts and Fishing Opportunities: • 9 a.m.-3 p.m., Room 172 of the Natural Resources Building, 1111 Washington St. S.E. Olympia. • WDFW presents Puget Sound, coastal Washington and Columbia River salmon abundance forecasts. Fishery management objectives and preliminary fishing opportunities for 2014 are discussed. March 8-13 Pacific Fishery Management Council: • DoubleTree by Hilton Hotel Sacramento, 2001 Point West Way Sacramento, CA. • The PFMC adopts a range of ocean fishery options, including catch quotas for sport and commercial fisheries. March 14 Grays Harbor Salmon Advisory Group Meeting: • 6 p.m.-9 p.m. WDFW's Montesano office, 48 Devonshire Road. • Public discussion of Grays Harbor salmon forecasts and fishing opportunities. March 17 Columbia River Fisheries Discussion: • 10 a.m.-4 p.m. Vancouver Water Resources Education Center, 4600 SE Columbia Way, Vancouver, Wash. • Public discussion of management objectives and preliminary options for Columbia River fall commercial and sport fisheries. March 19 First North of Falcon Meeting: • 9 a.m.-3 p.m., Room 172 of the Natural Resources Building, 1111 Washington St. S.E. Olympia. • Discussion of management objectives and preliminary fishery proposals for Puget Sound, coastal Washington and Columbia River area sport and commercial fisheries. Grays Harbor Fisheries Discussion: • 6 p.m.-8 p.m. Montesano City Hall, 112 N. Main Street, Montesano. • Public discussion of Grays Harbor salmon forecasts and fishing opportunities. March 20 Puget Sound Recreational Fisheries Discussion: • 6 p.m.-8 p.m., Trinity Methodist Church, 100 South Blake Ave., Sequim • Discussion of local salmon fisheries. March 21 Willapa Bay Salmon Advisory Group Meeting: • 6 p.m.-9 p.m. WDFW's Montesano office, 48 Devonshire Road. • Public discussion of Willapa Bay salmon forecasts and fishing opportunities. March 24 Public Hearing on Ocean Salmon Management Options: • 7 p.m., Chateau Westport, 710 W. Hancock, Westport. • Public hearing, sponsored by the Pacific Fishery Management Council, to receive comments on the proposed ocean salmon fishery management options adopted by the council during its March meeting. March 25 Willapa Bay Fisheries Discussion: • 6 p.m.-8 p.m. Raymond Elks Lodge, 326 Third Street, Raymond. • Public discussion of Willapa Bay salmon forecasts and fishing opportunities. March 27 Pre-season Columbia Basin salmon forecasts and fishery outlook: • 6 p.m.-8 p.m., Benton PUD, 2721 W. 10th Ave. Kennewick. • Public discussion of potential recreational and commercial salmon fisheries statewide. April 1 North of Falcon Meeting: • 9 a.m.-5 p.m., Embassy Suites Hotel, 20610 44th Ave. West, Lynnwood. • Public meeting to present results of state-tribal negotiations and analyses of preliminary fishery proposals. With public participation, preferred options are developed for Puget Sound and Columbia River area sport and commercial fisheries. April 3 North of Falcon Meeting – Columbia River & Ocean discussion: • 9 a.m.-2 p.m., Room 172 of the Natural Resources Building, 1111 Washington St. S.E., Olympia. • Public meeting to present results of state-tribal negotiations and analyses of Ocean and Columbia River fisheries proposals. With public participation, preferred seasons are developed for Ocean and Columbia River area sport and commercial fisheries. April 4 Final Grays Harbor/Willapa Bay Fisheries Discussion: • 9 a.m.-5 p.m., Room 172 of the Natural Resources Building, 1111 Washington St. S.E., Olympia. • Public meeting to reach final agreement on sport and commercial salmon seasons for Grays Harbor and Willapa Bay. April 5-10 Final Pacific Fishery Management Council: • Hilton Vancouver Washington, 301 W. Sixth Street, Vancouver, WA. • PFMC adopts final ocean fisheries regulations and state-tribal fishing plans are finalized for all inside area commercial and sport salmon fisheries.
A side note: The results of the study that estimates pre-spawn mortality of C&R fish (both commercial and recreational) has implications far beyond Grays Harbor. The potential to change how mark-selective fisheries are implemented on the Columbia Rv is huge. The Tribes have complained at length about the lack of reliable estimates of C&R release mortalities on the Columbia (recreational only, of course). This study might provide a glimpse of how close the actual release moralities are to the estimates used in the catch-balancing calculations. So, after many years of complaining, the Tribes might get want they've been asking for.
But, given that the study will also include gill net release mortality estimates, the Tribes might not like the results.....
Why? They don't release anything from a net. If the mortality rates go up on released fish, they get to kill more. As the rates go up the non-Indians fish less, leaving them more time on the river alone. A win-win.
Carcass - Not sure I understand your question......
As I understand it, the study that WDFW is doing will look at the survival rates of fish that are caught in gill nets, and subsequently released. (Ditto for recreationally caught fish.) I realize the Tribes don't intentionally release anything caught from their gill nets, but they recognize there is unaccounted losses from fish that drop out, or get thru the nets. But nobody has done a study to determine the survival rate of these fish. Presumably, the study on Gray's Harbor will provide some indication of the C&R survival of fish that encounter gillnets.
I realize it's the C&R survival rate from recreationally caught fish that the Tribes are most interested in.
Way back when a drop-out rate of 3% of the landed catch was applied to all (I and NI) gillnet fisheries. I don't know if that is still the case. At one time there was a push to include seal removals. Tribes were not in favor of this because set nets appeared to have more seal losss than drift nets (NI could only use drifts).
Some of the tribes are pushing for a 100% mortality rate on C&R steelhead.
I agree that we need significantly more work on survival post-release. We need to look at how the C&R experiance affects not only survival to spawning but spawning itself. Do they swim as far upstream, do the bury their eggs as deep, are the eggs as viable, does a steelhead successfully become a repeat spawner? This, and more, needs to be looked at.
". . . Some of the tribes are pushing for a 100% mortality rate on C&R steelhead. . . "
Couldn't help but notice this. OK, that's just stupid. Mainly because I know of one tribal steelhead broodstock program that over 4 years experienced a 2% incidental mortality rate, and most would agree that the stresses of broodstocking (tubing, tank truck transport, raceway holding, and handling) exceeds that of CNR fishing.
WDFW NEWS RELEASE Washington Department of Fish and Wildlife 600 Capitol Way North, Olympia, WA 98501-1091 http://wdfw.wa.gov/ February 18, 2014 Contact: Ron Warren, (360) 902-2799 Public meeting on salmon forecast kicks off season-setting process OLYMPIA - Anglers, commercial fishers and others interested in Washington state salmon fisheries can get a preview of this year's salmon returns and potential fishing seasons during a public meeting here March 3. Kicking off the annual salmon season-setting process, the Washington Department of Fish and Wildlife (WDFW) will present initial forecasts - compiled by state and tribal biologists - of 2014 salmon returns. The meeting is scheduled from 9 a.m. to 3 p.m. in room 172 of the Natural Resources Building, 1111 Washington Street S.E., in Olympia. Those attending the meeting will have an opportunity to talk to fishery managers about the pre-season forecasts and participate in work sessions focusing on possible salmon fisheries and conservation issues. WDFW has also scheduled additional public meetings focusing on regional salmon issues through early April. This series of meetings - involving representatives from federal, state and tribal governments and recreational and commercial fishing industries - is known as the North of Falcon process. A meeting schedule and more information about the salmon season-setting process for Puget Sound, the Columbia River and the Washington coast is available on WDFW's website at http://wdfw.wa.gov/fishing/northfalcon/ . The North of Falcon process is held in conjunction with public meetings conducted by the Pacific Fishery Management Council (PFMC), responsible for establishing fishing seasons in ocean water three to 200 miles off the Pacific coast. Final adoption of the 2014 salmon fisheries is scheduled for April 10 at the PFMC meeting in Vancouver, Wash.
I thought I would put up the new policy guidelines for those who hate links. You loose formatting going from a PDF to Word to PP but it is somewhat readable.
Commission Policy Documents << Commission Policy Documents Index
POLICY DECISION POLICY TITLE: Grays Harbor Basin Salmon Management POLICY NUMBER: POL-C3621 Supercedes: N/A Effective Date March 1, 2014 Termination Date December 31, 2023 See Also: C-3608, C-3619 Approved by: /s/ Miranda Wecker Fish and Wildlife Commission Chair DOWNLOAD: Signed copy of POL-C3621 (PDF)
Purpose The objective of this policy is to advance the conservation and restoration of wild salmon. Where consistent with this conservation objective, the policy also seeks to maintain or enhance the economic well-being and stability of the fishing industry in the state, provide the public with outdoor recreational experiences and a fair distribution of fishing opportunities throughout the Grays Harbor Basin, and improve the technical rigor of fishery management. Enhanced transparency and information sharing are needed to restore and maintain public trust and support for management of Grays Harbor salmon fisheries. Definition and Intent This policy sets a general management direction and provides guidance for Washington Department of Fish and Wildlife (Department) management of all Pacific salmon returning to the Grays Harbor Basin. The Grays Harbor Basin is defined as Grays Harbor and its freshwater tributaries. General Policy Statement This policy provides a cohesive set of principles and guidance to promote the conservation of wild salmon and steelhead and improve the Department's management of salmon in the Grays Harbor Basin. The Fish and Wildlife Commission (Commission) recognizes that management decisions must be informed by fishery monitoring (biological and economic), and that innovation and adaptive management will be necessary to achieve the stated purpose of this policy. By improving communication, information sharing, and transparency, the Department shall promote improved public support for management of Grays Harbor salmon fisheries. State commercial and recreational fisheries will need to increasingly focus on the harvest of abundant hatchery fish. Mark-selective fisheries are a tool that permits the harvest of abundant hatchery fish while reducing impacts on wild stocks needing protection. As a general policy, the Department shall implement mark-selective salmon fisheries, unless the wild populations substantially affected by the fishery are meeting spawner (e.g., escapement goal) and broodstock management objectives. In addition, the Department may consider other management approaches provided they are as or more effective than a mark-selective fishery in achieving spawner and broodstock management objectives. Fishery and hatchery management measures should be implemented as part of an "all-H" strategy that integrates hatchery, harvest, and habitat systems. Although the policy focuses on fishery management, this policy in no way diminishes the significance of habitat protection and restoration. In implementing the policy guidelines, the Department will work with the tribes in a manner that is consistent with U.S. v. Washington and other applicable state and federal laws and agreements. Guiding Principles The Department will apply the following principles in the management of salmon in the Grays Harbor Basin: 1. Promote the conservation and restoration of salmon and steelhead by working with our partners (including Regional Fishery Enhancement Groups and Lead Entities) to protect and restore habitat productivity, implementing hatchery reform, and managing fisheries consistent with conservation objectives. 2. Meet the terms of U.S. v. Washington and other federal court orders and promote a strong relationship with the Quinault Indian Nation. Spawning escapement goals, fisheries, and artificial production objectives will be developed and jointly agreed with the Quinault Indian Nation. The Department shall seek agreement with the Quinault Indian Nation to manage fisheries with the intent of meeting the Chinook and coho salmon spawner goals for the Humptulips River and the Chinook and coho spawner goals for the Chehalis River. Agreements between the Department and the Quinault Indian Nation related to salmon in the Grays Harbor Basin shall be made available to the public through the agency web site. 3. The Department will work through the Pacific Salmon Commission to promote the conservation of Grays Harbor salmon and, in a manner consistent with the provisions of the Pacific Salmon Treaty, pursue the implementation of fishery management actions necessary to achieve agreed conservation objectives. 4. Within the Pacific Fishery Management Council (Council) process, the Department will support management measures that promote the attainment of Grays Harbor conservation objectives consistent with the Council's Salmon Fishery Management Plan. 5. In a manner consistent with conservation objectives, seek to enhance the overall economic well-being and stability of Grays Harbor Basin fisheries. 6. When establishing fishery seasons, the Department shall consider the anticipated impact of both Quinault Indian Nation and nontreaty fisheries in the Grays Harbor Basin. 7. In a manner consistent with conservation objectives, fishing opportunities will be fairly distributed across fishing areas and reflect the diverse interests of WDFW-managed fishers. 8. Recreational and WFDW-managed commercial fisheries shall be structured (e.g., schedule, location, gear) to minimize gear and other fishery conflicts. WDFW-managed commercial gillnet fisheries in a fishing area or aggregate area (i.e., Area 2A/2B/2D; or Area 2C) shall be scheduled, if possible, so that in any given calendar week there are a minimum of three consecutive days when no treaty or state-managed commercial fisheries occur. If the treaty fishery occurs 4 or more days in a calendar week, no WDFW-managed commercial fishery shall occur in the remaining days of the week. 9. Monitoring, sampling, and enforcement programs will adequately account for species and population impacts (landed catch and incidental fishing mortality) of all recreational and WDFW-managed commercial fisheries and ensure compliance with state regulations. 10. If it becomes apparent that a scheduled fishery will exceed its preseason catch expectation, and the overage will put at risk the attainment of conservation objectives, the Department shall implement inseason management actions that are projected to enhance the effectiveness of fishery management relative to the attainment of the conservation objectives and impact sharing in the preseason fishery plan. 11. Salmon management will be well documented, transparent, well-communicated, and accountable. The Department shall strive to make ongoing improvements in the transparency of fishery management and for effective public involvement. These shall include: a) clearly describing management objectives in a document available to the public prior to the initiation of the preseason planning process; b) enhancing opportunities for public engagement during the preseason fishery planning process; c) communicating inseason information and management actions to advisors and the public; d) seeking Quinault Indian Nation support for the inclusion of observers in co-management meetings; and e) striving to improve communication with the public regarding co-management issues that are under discussion. 12. The Department shall seek to improve fishery management and technical tools through improved fishery monitoring, the development of new tools, and rigorous assessment of fishery models and parameters. 13. The Department shall explore and pursue options to increase hatchery production in the Grays Harbor Basin in a manner consistent with the Hatchery and Fishery Reform policy (C-3619). These shall include: a. The Department shall work with the public and parties to the Wynoochee Settlement Agreement with the goal of submitting to the Federal Energy Regulatory Commission by September 30, 2014 the Wynoochee Dam mitigation plan and initiate spending of the mitigation funds in an expeditious manner thereafter. b. The Department shall seek restoration of hatchery funding cut in the Grays Harbor Basin since the 2007-2009 biennium. 14. When a mark-selective fishery occurs, the mark-selective fishery shall be implemented, monitored, and enforced in a manner designed to achieve the anticipated conservation benefits. Fishery and Species-Specific Guidance Subject to the provisions of the Adaptive Management section, the following fishery-and species-specific sections describe the presumptive path for achieving conservation objectives and a fair sharing of harvestable fish. Spring Chinook Salmon Subject to the adaptive management provisions of this policy, the Department will manage spring Chinook salmon fisheries consistent with the Guiding Principles and the following objectives: 1. Fisheries will be managed with the intent of achieving escapement goals for wild spring Chinook. In no case, shall WDFW-managed fisheries result in an impact of more than 5% of the return when the natural-origin adult return exceeds the spawner objective by less than 10%. 2. Prioritize freshwater recreational fisheries, with an objective of opening freshwater areas no later than May 1. Fall Chinook Salmon Subject to the adaptive management provisions of this policy, the Department will manage fall Chinook salmon fisheries consistent with the Guiding Principles and the following objectives: 1. Fisheries will be managed with the intent of achieving escapement goals for wild and hatchery Chinook. In no case, shall WDFW-managed fisheries result in an impact of more than 5% of the return when the natural-origin adult return exceeds the spawner objective by less than 10%. 2. The fishery management objectives for fall Chinook salmon, in priority order, are to: a. achieve spawner goals; b. provide meaningful recreational fishing opportunities; and c. limit commercial fishery impacts to the incidental harvest of fall Chinook during fisheries directed at other species. 3. The following guidelines describe the anticipated sharing of fishery impacts in the Grays Harbor Basin between WDFW-managed commercial, marine recreational, and freshwater recreational fisheries. Variation from these guidelines may occur if it will result in fisheries that more closely achieve the stated purpose of this policy. a. WDFW-managed commercial fisheries in the Grays Harbor Basin shall have the following impact limits:  Areas 2A, 2B, 2D: the impact rate of the state-managed commercial fishery shall be 0.8% on natural-origin Chehalis fall Chinook when the impact of the recreational fishery is equal to or greater than 4.2%. The impact rate of the WDFW-managed commercial fishery may be less than 0.8% when conservation concerns for natural-origin Chehalis fall Chinook result in a less than 4.2% impact rate in the recreational fishery.  When the terminal run of natural-origin Chehalis fall Chinook reaches an abundance of 18,793, the impact rate of the WDFW-managed commercial fishery shall linearly increase from 0.8% to a maximum of 5.8% at a terminal run of 25,000 natural-origin Chehalis fall Chinook.  Area 2C: the impact rate of the state-managed commercial fishery shall be 1.2% on natural-origin Humptulips fall Chinook when the impact of the recreational fishery is equal to or greater than 3.8%. The impact rate of the WDFW-managed commercial fishery may be less than 1.2% when conservation concerns for Humptulips natural-origin fall Chinook result in a less than 3.8% impact rate in the recreational fishery.  When the terminal run of natural-origin Humptulips fall Chinook reaches an abundance of 3,779, the impact rate of the WDFW-managed commercial fishery shall linearly increase from 1.2% to a maximum of 5.4% at a run of 4,070 natural-origin Humptulips fall Chinook. b. Chehalis Fall Chinook. Fisheries shall be developed with the intent of achieving the following sharing of impacts within the recreational fishing sector: Run Size % to Freshwater % to Area 2-2 Small 1 73% 27% Large 52% 48% c. d. Humptulips Fall Chinook. Fisheries shall be developed with the intent of achieving the following sharing of impacts within the recreational fishing sector: Run Size % to Freshwater % to Area 2-2 Small 78% 22% Large 63% 37% Chum Salmon Subject to the adaptive management provisions of this policy, the Department will manage chum salmon fisheries consistent with the Guiding Principles and the following objectives: 1. Fisheries will be managed with the intent of achieving escapement goals for wild and hatchery chum salmon. In no case, shall WDFW-managed fisheries result in an impact of more than 5% of the return when the natural-origin adult return exceeds the spawner objective by less than 10%. 2. No fisheries directed at chum salmon shall occur unless the adult coho salmon return exceeds spawner objectives, or if coho salmon impacts remain after coho and Chinook salmon fisheries. 3. The following guidelines describe the anticipated sharing of fishery impacts between marine recreational and freshwater recreational fisheries. Variation from these guidelines may occur if it will result in fisheries that more closely achieve the stated purpose of this policy. a. Fisheries shall be developed with the intent of achieving the following sharing of impacts within the recreational fishing sector: Run Size % to Freshwater % to Area 2-2 Small >98% ≤2% Large >98% ≤2% Adaptive Management The Commission recognizes that adaptive management will be essential to achieve the purpose of this policy. Department staff may implement actions to manage adaptively to achieve the objectives of this policy and will coordinate with the Commission, as needed, in order to implement corrective actions. Components of the adaptive management will be shared with the public through the agency web site and will include the following elements: 1. Annual Fishery Management Review. The Department shall annually evaluate fishery management tools and parameters and identify improvements as necessary to accurately predict fishery performance and escapement.
As a component of the annual fishery management review, the Department shall assess if spawner goals were achieved for Chehalis spring Chinook, Chehalis fall Chinook, Humptulips fall Chinook, Chehalis coho, Humptulips coho, and Grays Harbor chum salmon. If the number of natural-origin spawners was less than the goal in 3 out of the last 5 years (beginning in 2009), the Department shall implement the following measures: a. The predicted fishery impact for that stock in WDFW-managed fisheries in the Grays Harbor Basin will not exceed 5% of the adult return to Grays Harbor; and b. If a spawner goal for fall Chinook salmon is not achieved, the Grays Harbor control zone2 off of the mouth of Grays Harbor will be implemented no later than the second Monday in August and continue until the end of September. 2. Inseason Management. The Department shall develop, evaluate, and implement fishery management models, procedures, and management measures that are projected to enhance the effectiveness of fishery management relative to management based on preseason predictions. 3. Spawner Goals. The Department shall review spawner goals to ensure that they reflect the current productivity of salmon. The review shall be initiated with Chinook salmon in 2014.
To promote improved management of chum salmon, the Department shall include in the 2015 annual review an evaluation of options to improve chum salmon stock assessments. The Department shall subsequently initiate in 2015 a review of the spawner goal for chum salmon. Delegation of Authority The Commission delegates the authority to the Director, through the North of Falcon stakeholder consultation process, to set seasons for recreational and WDFW-managed commercial fisheries in Grays Harbor, to adopt permanent and emergency regulations to implement these fisheries, and to make harvest agreements with treaty tribes and other government agencies. ________________________________________ 1. A small run is defined as a run size less than 110% of the spawner goal. A large run is defined as more than 182% of the spawner goal for fall Chinook salmon and more than 156% of the spawner goal for coho and chum salmon. 2.The Grays Harbor control zone is defined as an area at the entrance to Grays Harbor bounded by a line from the lighthouse 1 mile south of the south jetty to buoy #2 to buoy #3 to the tip of the north jetty to the tip of the exposed end of the south jetty.
What we have here is a E mail from Fish Program AD Jim Scott outlining coming events in the process to redo the Grays Harbor Management Plan. The final policy guidelines were attached along with two other documents. The policy guidelines are available on WDF&W's website along with having been posted in this thread previously. I or someone will get the other two documents up a bit later.
It has been a intense effort by WDF&W staff & the East County guys to finish all aspects of the Litigation but it is a done deal. So round two begins. Oh yeah almost forgot, if you want the actual e mail with the attachments hit me with a PM and I will forward it to you.
Grays Harbor Advisory Group Members –
I have several pieces of news that I believe are positive steps toward conserving Grays Harbor salmon and improving fishery management.
Settlement Agreement. The Department signed an agreement on Friday to settle litigation regarding the rules for the 2013 Grays Harbor and Willapa Bay commercial fisheries. As described in the attached summary, rather than prolonging litigation, the parties have agreed to build on a shared interest in enhancing communication between the Department and recreational fishers, ensuring a strong technical foundation for salmon fishery management, and improving the integration of the North of Falcon fishery planning and the rules process. The agreement includes several provisions that are consistent with suggestions we included in our January presentation to the Fish and Wildlife Commission (FWC). These include the development of a Grays Harbor web page to clearly and consistently provide information on catches and spawners, and a series of collaborative workshops with stakeholders. I wish to be clear that these workshops will be developed with input from all of you – not just the parties to the settlement agreement – and all members of the public will be encouraged to attend the workshops.
Improvements in Technical Tools. We have discussed extensively during the last three months the draft Grays Harbor policy under consideration by the Fish and Wildlife Commission (FWC). Our discussions have necessarily focused on higher level policy guidance and general management direction, but I have also heard you and the public express many technical concerns. Although all of those technical concerns may not be individually addressed in the draft policy, we have attempted to capture them in several of the guiding principles and in the adaptive management section.
For example, Guiding Principle 12 of the draft Grays Harbor Policy states: “The Department shall improve fishery management and technical tools through improved fishery monitoring, the development of new tools and rigorous assessment of fishery models and parameters.”
The 2014 fishery planning season is now quickly approaching, and I want you to be aware of three actions that will address some of the more technical concerns that I have heard from the advisors or the public.
Grays Harbor Planning Model. I have heard on several occasions that the Grays Harbor fishery planning model may have had computational errors in past years (I believe John Campbell may have been the first person that provided me with this information). As a step toward implementing Guiding Principle 12 and addressing this technical concern, I have initiated the contracting process to get an independent review of the model’s computational formulas. I hope to get that contract initiated next week - time is short before we start 2014 fishery planning!
Preseason Catch Projections. A second technical concern that I have heard is that our preseason catch or impact projections do not accurately capture the current fisheries or accurately project fishery impacts. The Area 2-2 recreational fishery is probably the example I hear most frequently. We view this issue as a good topic for the workshops that were discussed above and included in the settlement agreement. We’re targeting a February workshop and will be soliciting your ideas for how to make the workshop successful.
Release Mortality Rates. The release mortality rates used by the Department to project the mortality of Chinook salmon released in commercial fisheries is a third technical concern that I have frequently heard. This is a complex topic and, while the mortality rates for salmon released by recreational fishers have been the topic of multiple scientific reviews, I am not aware that the rates used by the Department for commercial fisheries in Grays Harbor and Willapa Bay have had a similar scientific review. Accordingly, we have included in the settlement agreement a process to engage the assistance of independent scientific experts to provide us with recommendations. Again, we will be soliciting your ideas for how to make the workshop successful.
Well – its already noon on Saturday. I’m going to see if I can catch some of this beautiful day. Look forward to talking with you soon.
Jim
Grays Harbor Advisory Group Members –
I would like to thank all of you for your assistance in developing the Grays Harbor Basin Salmon Management policy that was adopted by the Fish & Wildlife Commission. I have attached the final policy and it is also available at http://wdfw.wa.gov/commission/policies.html.
As I mentioned in my previous e-mail, we are working with the Twin Harbors Fish and Wildlife Advocacy nonprofit to conduct two workshops to improve the technical foundation for our fishery management. Here is an update on the current status of these technical workshops.
Preseason Catch Projections. We are convening a technical workgroup to review and improve our methods for predicting salmon catch or impacts in recreational and commercial fisheries in the Grays Harbor Basin. The workgroup will include three WDFW staff members, two technical experts from the Twin Harbors Fish & Wildlife Advocacy, and 1 position is open for a technical expert from the commercial fishing industry. During the next month, we anticipate that the technical workgroup will meet on at least two occasions to develop recommendations for improvements in our catch and impact predictions. We have scheduled a workshop for March 10, 2PM, Natural Resources Building, Room 172 for the technical workgroup to present their analyses and recommendations. Let me know if you have suggestions for how to help make this workshop successful. Additional information is provided in the attachment.
Release Mortality Rates. We are convening an Independent Fishery Scientist Panel (IFSP) to recommend release mortality rates to use in preseason planning of commercial fisheries in Grays Harbor and Willapa Bay (additional information is in the attachment). We are fortunate to have secured the assistance of three great scientists: Lars Mobrand, Alex Wertheimer, and Steve Smith. Each of them has had a distinguished career with important contributions to fishery management. We are looking forward to working with them through the following steps:
February 19 – Background information provided to IFSP. This will include a literature survey of relevant studies, harvest rates and other fishery data, environmental data such as water temperature and salinity, and information on fisher behavior and compliance with rules.
February 26 – Workshop to present a summary of the information to the IFSP, allow the IFSP to ask questions, and provide an opportunity for the public to make comments. The workshop will include technical presentations from WDFW, the Twin Harbors Fish & Wildlife Advocacy nonprofit, and a slot is available for a technical expert from the commercial fishing industry. The workshop will occur in the General Administration Building, Auditorium, 2-5pm.
March 14 - IFSP provides draft report for 5-day review period.
March 26 – IFSP provides final report.
Please do not hesitate to contact me or Steve Thiesfeld if you have any questions.
So what we have next is the scope of work for workshops on commercial release mortalities. If you do not like C&P's not much I can do to help you with that as this & the next ( along with a previous post ) are the processes to reform the harvest model.
Scope of Work Mortality Rates for Salmon Released in Commercial Fisheries in Grays Harbor and Willapa Bay Draft February 19, 2014
Task: The Independent Fishery Scientist Panel (IFSP) shall provide recommendations on the release mortality rates to be used in the preseason planning of commercial salmon fisheries in Grays Harbor and Willapa Bay. In reaching these recommendations, the types of information that the IFSP shall rely upon shall include the following: • Fishery rules codified in the Washington Administrative Code. • Reports and publications on release mortality rates in Grays Harbor, Willapa Bay, and in other locations with similar fisheries. • Fishery data including encounter rates, harvest rates, and the condition of Chinook salmon released. • Environmental data including water temperature and salinity. • Fisher behavior and compliance with rules.
IFSP Report: The IFSP final report will address the following questions and include the rationale for each response:
1) What are the recommended mortality rates for Chinook and chum salmon released in the fisheries described in Table 1 and with fishers complying with the applicable rules and the practices described in the Fish Friendly workshops?
Table 1. Fishery locations, time periods, gear, and WACs for consideration by the IFSP.
Fishery Location Time Period Gear Rules Grays Harbor (areas 2A, 2B, 2C, 2D) Weeks 40-48 Gillnet, 6 1/2” maximum mesh WAC 220-36-023 Grays Harbor (areas 2A, 2B, 2C, 2D) Weeks 40-48 Tangle net, 4 ¼” maximum mesh WAC 220-36-023 Willapa Bay (areas 2M-2T) Mid-August through mid-September Gillnet, 9” maximum mesh WAC 220-40-021 WAC 220-40-027 Willapa Bay (areas 2M–2T) Mid-September through October 31 Gillnet, 6 ½” maximum mesh WAC 220-40-021 WAC 220-40-021
2) For these same fisheries, what are the recommended mortality rates for Chinook and chum salmon released taking into consideration actual practices in the fisheries?
3) If any mortality rates differed between your responses to questions 2 and 3, what were the major compliance issues that were the source of this difference?
Process: February 3-4: Identify candidates for Independent Fishery Scientist Panel (IFSP) (Scott, Hamilton). February 3-14: Solicit information from the commercial fishing industry relevant to the mortality rates for salmon released from commercial fisheries (Scott) February 3-14: Compile information relevant to the mortality rates for salmon released from commercial fisheries (Scott, Hamilton). February 5 – 7: Contact candidates for IFSP and determine availability (Scott). February 10: Select IFSP members (Scott, Hamilton). February 11-14: Complete contracts for IFSP members (Scott). February 19: Provide questions, schedule, and information package to IFSP (Scott). February 26: Conduct workshop with presentations to the IFSP (Scott, Hamilton). March 14: IFSP provides draft report. March 19: Comments provided to IFSP (Scott, Hamilton) March 26: IFSP provides final report. March 28: IFSP final report posted to Department website.
Workshop Format 1) The workshop will be conducted in Olympia on February 26, General Administration Building, Auditorium, 2PM. 2) The length of the workshop will be approximately 3 hours, with the following format: • Introduction (10 minutes) • Technical presentations (20 minutes Department; 20 minutes technical representative from nonprofit organization; 20 minutes technical representative from commercial fishing industry) • IFSP questions and answers (60 minutes) • Public comments (30 minutes, 3 minutes maximum per commenter)
Final part is the scope of work for the mortalities on the rec side.
Scope of Work Workshop to Develop Improved Methods for Predicting the Catch of Salmon in Grays Harbor Fisheries Draft February 11, 2014
Objective: Develop improved methods for preseason predictions of catch in WDFW-managed salmon fisheries in Grays Harbor.
Technical Team: The intent is that the technical team shall work together to complete a joint report that provides recommendations to improve catch projections. The technical team shall be comprised of three members from the WDFW and three at-large members. The commercial fishery industry will be provided the opportunity to fill one of the three at-large positions.
The technical team tasks are to:
1) Quantitatively evaluate the preseason predictions of catch or encounters in the following fisheries: a. Recreational Fisheries – Chinook i. Chinook catch or encounters in the Area 2-2 recreational fishery prior to week 40. ii. Chinook catch or encounters in the Area 2-2 recreational fishery in weeks 40-48. iii. Chinook catch or encounters in the Chehalis River mainstem recreational fishery. iv. Chinook catch or encounters in recreational fisheries in each tributary to the Chehalis River. v. Chinook catch or encounters in the recreational fishery in the Humptulips River. b. Recreational Fisheries – Coho i. Coho catch or encounters in the Area 2-2 recreational fishery prior to week 40. ii. Coho catch or encounters in the Area 2-2 recreational fishery in weeks 40-48. iii. Coho catch or encounters in the Chehalis River mainstem recreational fishery. iv. Coho catch or encounters in recreational fisheries in each tributary to the Chehalis River. v. Coho catch or encounters in the recreational fishery in the Humptulips River. c. Recreational Fisheries – Chum i. Chum catch or encounters in the Chehalis River mainstem recreational fishery. ii. Chum catch or encounters in recreational fisheries in each tributary to the Chehalis River. iii. Chum catch or encounters in the recreational fishery in the Humptulips River. d. Commercial Fisheries -- Chinook i. Chinook catch or encounters in the commercial fishery in areas 2A and 2D in weeks 40-48. ii. Chinook catch or encounters in the commercial fishery in area 2C in weeks 40-48
e. Commercial Fisheries – Coho i. Coho catch or encounters in the commercial fishery in areas 2A and 2D in weeks 40-48. ii. Coho catch or encounters in the commercial fishery in area 2C in weeks 40-48. f. Commercial Fisheries – Chum i. Chum catch or encounters in the commercial fishery in areas 2A and 2D in weeks 40-48. ii. Chum catch or encounters in the commercial fishery in area 2C in weeks 40-48.
2) For a minimum of the 10 fisheries with the worst performance, develop and quantitatively evaluate (using jackknife or bootstrap hindcasting) alternative predictors.
3) Using the results from the hindcasting, recommend methods to predict the catch or encounters for each fishery in 2014.
Process: February 3-4: Identify members of technical team (Scott, Hamilton). February 13: Information on predicted and actual catches distributed to technical team (Scott) February 3-28: Technical team conducts analysis and prepares recommendations. The technical team shall meet together a minimum of two times to complete the assigned tasks. March 10: Technical team presents analysis and recommendations at public workshop. March 12: Technical team presentation posted to WDFW webpage.
Workshop Format: 1) The workshop will be conducted in Olympia on March 10, 2014, 2PM, Natural Resources Building, room 172. 2) The length of the workshop will be approximately 1.5 hours, with the following format: • Introduction (10 minutes) • Technical Team presentation (50 minutes) • Technical Team addresses questions from the public (30 minutes)
Here's the meeting time and place set for the public meeting with the panel of 3 experts that have been retained to issue a recommendation to WDFW on a commercial selective gillnet mortality for Chinook and Chum in Grays Harbor and Willapa Bay. There will be a short presentation from Twin Harbors Fish & Wildlife Advocacy (Tim Hamilton) and then WDFW (Jim Scott). A question and answer period will follow. Then, the public in attendance will be allowed the opportunity to speak and offer their comments.
After the public meeting, the members of the panel will issue a report that includes their recommendations on mortality rates for selective fishing with a gillnet in the two coastal estuaries.
The GA Building is located a block off Capitol Way on the edge of the Capitol Campus. The meeting is in the auditorium. Parking is difficult in the immediate area.
Workshop Date, Time, and Location: The workshop will occur on February 26, 2-5PM, in the Auditorium of the General Administration Building in Olympia. Best idea may be to park on P-3 at the Natural Resources Building (WDFW offices) and walk the two or so blocks to the GA Building at 210 11th Ave SW, Olympia, WA 98501.
This bit is from Steve Thiesfeld ( the Region 6 Fish Program Manager ) and the links have in them information and the Power Point presentation from the final Commission meeting. It is a bit confusing to say the least with the lack of a steady flow of information but doing catch up so read on and more to be posted soon.
Well everyone here is the final part of this attempt to getting information out to everyone. ( for now ) The link is to the FTC website and the East Grays Harbor County guys independent panel of experts that are participating. Links to the submitted analysis / papers are imbedded in the write up. I think this might help those who have not followed events closely to catch up.
Last call for the workshop on the Grays Harbor Commercial Non Treaty net fishery. This is about the gillnet release mortality more commonly know as the " Chehalis Fling " http://fishingthechehalis.net/chehalis-fling and I am told there will be several presentations. So it is part of the harvest model redo so I urge all to make if you can. The location is known for the poor parking so make your plans accordingly.
Workshop Date, Time, and Location: The workshop will occur on February 26, 2-5PM, in the Auditorium of the General Administration Building in Olympia. Best idea may be to park on P-3 at the Natural Resources Building (WDFW offices) and walk the two or so blocks to the GA Building at 210 11th Ave SW, Olympia, WA 98501.
The Department of Fish & Wildlife has asked the Twin Harbors Fish & Wildlife Advocacy ( THFWA ) to assist them with a public notice so I thought this is a good way to help them out. Those interested can access data, files and information that has been presented to the members of the scientific panel studying mortality rates for selective fishing with a gillnet in Willapa Bay and Grays Harbor using a special "box" set up for the Panel members. The public can access all the files provided the Panel by WDFW at http://wdfw.wa.gov/fishing/downloads/Settlement%20Workshop%20Materials/
To access the files and presentation made to the Panel from the Twin Harbors Fish & Wildlife Advocacy, those documents are also available for viewing and downloading on the fishingthechehalis.net website at http://fishingthechehalis.net/nof-process
Much of the process that was dictated by the out of court settlement between THFWA and WDF&W on the 2013 seasons has been posted up before in this thread. Now that said it is a lot of dry reading but it is important for those who have a desire to keep pace and comprehend the difference between NOF in the past and the 2014 process. It is substantial and I or someone will post a update on workshop that took place on 2/26 on gillnet mortalities soon.
The first Adviser meeting is next week so I am getting the word out to everyone. As it was last year the public can set in and observe but not participate. In most cases time at the end of the meeting time is set aside for the public to comment. So it is this simple, it is always best to hit every meeting possible to track any process. Those who do are usually more informed and regarded with a bit more credibility than someone than shows late just to bitch. Not sure it should work that way but it is what it is.
Tuesday March 4th WDF&W Region 6 offices Montesano. Grays Harbor Advisors from 5:30 pm to 7:00 pm. Willapa Bay Advisors from 7:00 pm to 8:30 pm
Well next up in the Grays Harbor Management Plan redo is the technical work being done on the harvest model. Important? Yup but most folks have not and will not get into the model functions but it is a critical element in setting seasons so if you can I urge you all to attend.
The technical panel consisting of numerous WDFW staff, two from the Twin Harbors Fish & Wildlife Advocacy, and a representative of the commercial fishery have been meeting regularly to correct errors and develop means to improve the reliability and accuracy of the GH fall season harvest model used in setting seasons in the Grays Harbor terminal. In addition, WDFW contracted with a outside consulting firm to go through the model and come up with recommended changes as well.
A results of this effort will be presented in a public workshop on Monday, 3/10/2014 in Room 172 of the Natural Resources Building from 2 pm - 5 pm. The public is invited and an opportunity for the public to ask the panel members questions will follow the presentation.
Here is the schedule as of now for the NOF GH with the workshops.
2014 ‐ North of Falcon (NOF) and Grays Harbor and Willapa Bay Advisors Meeting Schedule Area Date/Location AGENDA
Grays Harbor Advisors (public comment at end) March 4th Grays Harbor Advisors from 5:30 pm to 7:00 pm. Montesano DFW Office Advisory Group function APA Process Review Pre‐season forecasts Management Objectives Meeting Coordination Public Comment
Willapa Bay Advisors (public comment at end) March 4th Willapa Bay Advisors from 7:00 pm to 8:30 pm. Montesano DFW Office Advisory Group function APA Process Review Pre‐season forecasts Management Objectives Meeting Coordination Public Comment
Grays Harbor Advisors (public comment at end) March 14th 6 pm to 9 pm Montesano DFW Office APA Process Review Forecast Management Objectives Policy Implementation Fishery suggestions Public Comment
Grays Harbor NOF Public Workshop #1 (APA record testimony to immediately follow) March 19th 6 pm to 8 pm Montesano City Hall APA Process Review Forecast Management Objectives Policy Implementation Fishery suggestions
Grays Harbor Testimony For APA record March 19th 8 pm to 9 pm Montesano City Hall Individuals will be provided up to 3 minutes to go on the record relative to Grays Harbor Rule Making (Fishery Seasons Development)
Willapa Bay Advisors (public comment at end) March 21st 6 pm to 9 pm Montesano Timberland Library 125 S Main St, Montesano, WA 98563 APA Process Review Forecast Management Objectives Policy Implementation Fishery suggestions Public Comment
Willapa Bay NOF Public Workshop #1 (APA record testimony to immediately follow) March 25th 6 pm to 8 pm Raymond Elks APA Process Review Forecast Management Objectives Management Plan Implementation Fishery suggestions
Here is the complete GH NOF schedule with the workshops as it stands now.
Willapa Bay Testimony For APA record March 25thth 8 pm to 9 pm Raymond Elks Individuals will be provided up to 3 minutes to go on the record relative to Grays Harbor Rule Making (Fishery Seasons Development)
Grays Harbor NOF Public Workshop #2 (APA record testimony to immediately follow) April 4th 9 am to Noon NRB Room 172 APA Process Review Forecast Management Objectives Policy Implementation Fishery suggestions Fishery Structure
Grays Harbor Testimony For APA record April 4th Noon to 1 pm NRB Room 172 Individuals will be provided up to 3 minutes to go on the record relative to Grays Harbor Rule Making (Fishery Seasons Development)
Willapa Bay NOF Public Workshop #2 (APA record testimony to immediately follow) April 4th 1 pm to 3:30 pm NRB Room 172 APA Process Review Forecast Management Objectives Management Plan Implementation Fishery suggestions Fishery Structure
Willapa Bay Testimony For APA record April 4th 3:30 pm to 4:30 NRB Room 172 Individuals will be provided up to 3 minutes to go on the record relative to Willapa Bay Rule Making (Fishery Seasons Development)
This hearing got by me as it is not in the schedule so I think a repost is helpful. Now this bit is about the harvest model & the calculations utilized by the Excel spreadsheet. For the past several years Softbite and others have been constantly pointing out errors in the model but frankly folks that thing is a mess and tomorrow is the first time the private consultants review will be made public. A little known fact is WDF&W contracted with a consulting firm to review the model accuracy and the consultants review will become part of the record. It will be a little unusual to watch the process roll out tomorrow. So below is the meeting time and location.
The technical panel consisting of numerous WDFW staff, two from the Twin Harbors Fish & Wildlife Advocacy, and a representative of the commercial fishery have been meeting regularly to correct errors and develop means to improve the reliability and accuracy of the GH fall season harvest model used in setting seasons in the Grays Harbor terminal. In addition, WDFW contracted with a outside consulting firm to go through the model and come up with recommended changes as well.
A results of this effort will be presented in a public workshop on Monday, 3/10/2014 in Room 172 of the Natural Resources Building from 2 pm - 5 pm. The public is invited and an opportunity for the public to ask the panel members questions will follow the presentation.
A lot is going on and frankly after the workshop on the harvest model it does not instill confidence. As one non agency panel member said “ do not bet the farm on this as it could be plus or minus 200% “ so this thing is really up in the air as to just what is about to happen let alone anyone have any confidence that the numbers in the model will reflect reality. WDF&W hired and outside consultant, MORI-ko, LLC, to review the harvest model on only 4 subjects and MORI-ko came back with came back with 13 pages of items that were wrong or undocumented ( proofed ) assumptions residing in the model. Now many were addressed by the panel but are little more than Band-Aids on the much larger problem of the lack of accuracy I mentioned previously.
From page 12 of the MORI-ko report:
Consideration should also be given to modifying the Model structure to reflect the gauntlet nature of Grays Harbor Fisheries, where fisheries in outer harbor areas affect run sizes in more inside and river fishing areas. For instance, fisheries in estuarine areas (e.g., 2-2. 2B, 2C, 2D) have no effect on projected catches by freshwater sport fisheries. Instead of projecting impacts using harvest rates on fish remaining after removals by estuarine fisheries, freshwater sort catches are computed using s exploitation rates on the total terminal run size. This formulation contains implicit assumptions regarding independence among fisheries, migration run timing of hatchery and wild components, unspecified environmental conditions, and the ability to control effort to constrain allowable catches to projected levels. The current Model structure is not consistent with this characteristic or the gauntlet-type run reconstruction methods employed by WDFW and QIN in their recent report concerning the escapement goal for Grays Harbor fall chinook.
This is heads up time as the NOF process gets closer and folks have asked just where are we? Well that is a good question so at this moment here is my take on things.
So the good first.
1. The Commission policies adopted will get three net free days a week. ( hopefully as the QIN can choose to fish more than 4 days )
2. The legal action challenging the 2013 settlement required WDF&W to get real numbers in the model for the Non Treaty Nets so that should, could , may, be done.
3. The APA process that creates the WAC's for harvest will meet legal requirements. Again this comes from the out of court settlement and WDF&W did not address this issue on their own.
Now the bad
1. We will be in 3/5 on the Chehalis for Chinook and the same for Humptulips Coho. 3/5 is if you miss escapement 3 out of 5 years harvest is limited to 5% release mortality only on that stock / speices.
2. WDF&W will continue to have corrupted commercial release data entered into the model as the District 17 staffer whose numbers were pure fantasy is still around and no change here.
3. It has been said the model is accurate to plus or minus 200% at any point such as week in the harvest model. In other words it is dart board time once again and nobody knows where this is going. Considering the fact that if escapement is not made the fish and citizens will pay the piper and WDF&W staff will still get paid and go merrily down the road one should not expect earth shattering change here either.
4. Despite the appearance of public involvement it is pretty much behind closed doors at this minute. WDF&W is working with the lawsuit settlement folks but after that nah, pretty much looks the usual dog & pony show is headed your way. If not for the information I and other citizens made available to the public just about zip has come from WDF&W and unless we see a dramatic change in direction the average citizen will have little input into this fall's salmon seasons.
5. The Humptulips Natural Origin Recruits Coho ( spawning adults ) have not made escapement since 1987 and something has to give. Just what is going to happen? I have no idea but this is a real issue.
6. Will the QIN seasons be in the model as the state seasons are set? Yes the Commission said but ( ah yeah the but thing again ) they did not say it had to be in the model when NOF goes forward so where the QIN season shows up is a real question. Which means those who feel strongly about conservation are not going to have any ability gauge the total season impacts until WDF&W files the CR 102 ( legally setting the season WAC ). Now the law permits you to comment on the legal record then but that is about it. Which means unless you get on the legal record with the intention of hiring a attorney and heading off to court ( take your check book with you ) then your pretty much being shoved to the curb.
7. The issue of the QIN exercising their treaty rights to 50% of the harvestable adults to Grays Harbor as a whole vs the Commission's and WDF&W's desire to manage the Humptulips and Chehalis Basin's separately has not been resolved. If you think back to the 2013 seasons WDF&W had the QIN proposals around April 4th but refused to place them in the model for the public to see until the QIN made their seasons public much later. Heavens folks I dropped the days in the model and made it public before the agency reluctantly did so. Oh almost forgot with the QIN seasons put in the 2013 model it hit minus 1200 for Chinook escapement on the Chehalis which in plain English means WDF&W knew full well when they established the states seasons ( both commercial & rec ) on paper in the model that the Chehalis Chinook would not make escapement. Now the new Commission policy guidelines say you will make escapement so choose your poison as to the notion that Region 6 District 17 staff ah ................... has joyfully endorsed this concept?
All that said I will still urge any who can to attend this coming Fridays Adviser meeting. Why? Well it has been a citizen effort that brought the potential for change in Grays Harbor fisheries by going to the Commission. The Commission agreed and put in place new guidelines. ( thank you Commissioners ) Assistant Director Fish Program Jim Scott has put a lot of effort in Grays Harbor as has the new Region 6 Fish Program Manager Steve Thiesfeld but that does not mean it has been with any transparency at all. I think this partly due the very tight timeline that the APA process allowed then you have the one constant factor that is always around WDF&W. They really do not care for the public rummaging around ( let alone participate ) the decision making process.
So participate in the process the best you can but do it with eyes wide open knowing that much has changed at the Commission level but that does not necessarily mean that Region 6 or District 17 staff mindset has.
So here are the upcoming dates.
Grays Harbor Advisors (public comment at end) March 14th 6 pm to 9 pm Montesano DFW Office APA Process Review Forecast Management Objectives Policy Implementation Fishery suggestions Public Comment
Grays Harbor NOF Public Workshop #1 (APA record testimony to immediately follow) March 19th 6 pm to 8 pm Montesano City Hall APA Process Review Forecast Management Objectives Policy Implementation Fishery suggestions
Grays Harbor Testimony For APA record March 19th 8 pm to 9 pm Montesano City Hall Individuals will be provided up to 3 minutes to go on the record relative to Grays Harbor Rule Making (Fishery Seasons Development)
A bump for a reminder of tonight's Adviser meeting. 3 hours and here is the agenda but all should remember in this meeting public participation / comment is at the end.
Grays Harbor Advisors (public comment at end) March 14th 6 pm to 9 pm Montesano DFW Office APA Process Review Forecast Management Objectives Policy Implementation Fishery suggestions Public Comment
Agenda
1. Process 2. Other Mortality Factors (e.g. drop off, hooking mortality, pinniped) 3. Release mortality rates, results from Independent Fishery Science Panel 4. Final Management Objectives 5. Fishery Modeling 6. Tribal Discussion
So how did the Adviser meeting go? Interesting to what the he-- is my read so the high points.
1. Ron Warren outlined that the QIN had obtained grants to do a biological assessment for Chinook escapement needs and that PFMC had agreed to the results. Simply put the accumulative escapement goals for Grays Harbor Chinook are to be reduced. Going to mean some real changes for the future harvest allocations for both treaty and non treaty.
2. WDF&W staff hoped to develop harvest options to take to the public but not sure that was accomplished. On the Rec side the Adviser's went right at the harvest model to overlay the new policy guidelines to see what was possible this season. Not so much on the commercial side. They had problems with the guidelines, new selective fishery mortalities rates, and in general staying real as to what was possible in the model.
3. Considerable disagreement emerged over the fact that in Grays Harbor & Willapa a drop out rate has not been utilized for either Rec or Commercial nets ( both QIN or NT Nets ). Agency staff preference was to let it ride and fix it next year. That I and others objected to but some agreed with the staff thoughts. In the end the Commercials came to put the drop out rates in also so the issue is undecided at this moment. One of those you know the impact number is incorrect, lot of effort to fix it ( agency thoughts ) so to fix or not is the question left on the table.
4. Now a real failure. This past year the Adviser meetings were opened to the public for citizens to set in and observe the process and comment at the end. That was a good thing but it left some citizens not familiar to the process ... ah confused? Nah lets tell it like it is ticked off. I think, incorrect, know that it appeared to some non Advisers that a group of Advisers were setting down and dividing up the harvest. Now that criticism was probably valid in the past but not so much presently. All Region 6 was attempting to do is take input to get the new harvest guidelines flushed out with options that the public could review and comment on AND provide additional input on good / bad / otherwise.
That was not communicated properly or reinforced as the meeting progressed resulting in confusion and anger. How WDF&W communicates exactly the process underway to the public needs to be addressed. The old way of doing things is history but if your a citizen not familiar with allocation of harvest and how all public input gathered and it is not clearly defined then confusion followed by anger is pretty much the reaction most folks will have. That is unfortunate and Region 6 staff need to address it sooner than later.
Thanks for the update. But to quote my friend eyeFish, GDITMMM!
1. This is so simple I don't know why I didn't think of it before. The solution to harvest always is to lower the escapement goal. I have a suggestion that will save QIN some time and money. Let's adjust the Chehalis chinook escapement to zero - for the QIN. I've gotten used to not fishing for harbor chinook, so I've made my adjustment. WDFW can save a few $$ and stop stocking any hatchery chinook in the Chehalis basin. Then we can watch QIN chinook salmon management in action where they have no federal hatchery $$ as a backstop.
3. So they can't even decide whether to try to fix the problem? Then that is the problem. It's one thing not knowing how best to go about finding the answer. It's quite another to toss around the notion of not even trying to figure out how to find the answer.
I was under the impression that WDFW intended to satisfy the critical terms of your lawsuit. Now it's looking more and more like they're trying to figure out how to dodge it and continue with business as usual.
The key is that we are now officially in the NOF process.
That process is ALL about killing fish…. who gets to kill 'em, where and when they get killed…. typically right down to the last available fish
NOF has nothing to do with conservation. Conservation has already been put in place by policy. At no point in history has the bar for conservation ever been set so high in Grays Harbor. Once the preseason forecasts are plugged into the policy provisions…. escapement to the gravel, tribal agreements/treaties, the 3 out 5 escapement guideline, the 3-day escapement window, and the new commercial ban on directed chinook fisheries…. what (hopefully) emerges on the either end is a finite number of fish left for the fishing industry (rec and comm) to harvest.
To the fullest extent possible, NOF seeks to kill them in a 2014 harvest management plan that sets rec and comm fishing seasons intended to maximally utilize every available paper fish.
I realize that turns a lot of people off. Those folks must accept that if they wanna go fishing, FISH WILL DIE! And if they want the best seasons possible, in terms of time/area/bag, recs MUST assert their claim to the available harvest…. right down to the last fish. There is no shame in that. Rest assured that conservation has already come off the top…. we simply seek to make the best of what's left .
I believe Dave missed one rather significant highlight in his last post.
New chinook release mortalities have been assigned. Historic rates applied a 45% mortality for gillnets and 14% mortality for tangle nets. After independent scientific review of the available literature, the new rates are as follows:
65% for chinook mesh (9" gear)… a 44% increase 61% for coho/chum mesh (6" gear)… a 36% increase 30% for tooth/tangle mesh (4" gear)… a 114% increase
The increased rates translate directly to increased chinook impacts for each day on the water. Commercials will burn thru their available proportionately faster with each gear type, which means less fishing days for the season.
BTW it's my understanding the new rates will be applied equally to Willapa Bay.
Hey THX Doc I was going get it a bit later but you got it!
Quote:
WDFW can save a few $$ and stop stocking any hatchery chinook in the Chehalis basin
SG the Chinook of hatchery origin in the Chehalis come primarily from Satsop Springs operated by the LOCAL community, are as close to 100% broodstock as humanly possible to get and have about ZERO additional impacts added to harvest, be it tribal or Non Tribal, to Natural Origin Recruits. ( NOR ) Prior to the local effort the E. Fork Satsop Chinook had been nearly wiped out for whatever the reason and the effort by folks are pretty much the only reason the Satsop sub basin Chinook have recovered to the levels they have. On the legal SG I think Scott & Thiesfeld are trying ( now the but ) BUT while they might get by me with some BS there is no way they get Tim, Ron, & Art let alone Mr. Joe their attorney.
Say speaking of the science panel it is surprising what rolled out. Besides what Doc said another is the Rec catch they caught that inriver numbers modeled for catch prediction was charged against the total run size. Say the run was 100k then the Bay Rec, QIN, and Non Treaty net take fish 45k so you have 55k remaining that the inriver sport ( and Chehalis Tribal ) fish on. The GH model was developing the inriver impacts off of the 100k rather than 55k remaining which resulted in the modeled impacts to be far greater than they really would be. Plain English the inriver was getting screwed one more time, BIG time. Which is when Doc, I, and others put forth the model inaccuracy of under reporting NT Nets & bay rec and OVER estimating Rec inriver we went on the hunt. Thanks to the panel we have part of the answer now.
Doc is also correct in that the new mortality rates for selective fishing will apply to Willapa. The out of court settlement was for BOTH. Also this was the scientific panel draft as some changes are going appear in the numbers as it is finished and Chum which are a straight non retention gillnet not selective in any manner is going to have a new mortality rate also.
The next step in the North of Falcon is the meeting March 19th for public input.
Grays Harbor NOF Public Workshop #1 (APA record testimony to immediately follow) March 19th 6 pm to 8 pm Montesano City Hall APA Process Review Forecast Management Objectives Policy Implementation Fishery suggestions
Grays Harbor Testimony For APA record March 19th 8 pm to 9 pm Montesano City Hall Individuals will be provided up to 3 minutes to go on the record relative to Grays Harbor Rule Making (Fishery Seasons Development)
So I urge all to attend as this is your opportunity to address the coming salmon seasons. I realize completely that thus far WDF&W has provided little to no information to the public since the Commission adopted the new Grays Harbor Management Plan guidelines. That said folks this is your time coming up to tell them what your thoughts are and get some information on the process of implementing the new GHMP guidelines.
Yes I do and I would urge anyone to speak to the fact that WDFW has intentionally allowed the public to remain uninformed as to the progress and the manner in which NOF is going forward. The APA process can / will be confusing to many but it is the legal process that establishes the fishing WAC's. http://apps.leg.wa.gov/rcw/default.aspx?cite=34.05 Oh, at the end of the meeting citizens can place comments that will go into the legal record which in the Concise Explanatory Statement ( CES ) which by law WDF&W must respond to.
Melanie and I sat for over 3 hours listening to the last meeting (other then the "regulars" we were the only public present)and after all that time we were told that we wouldn't get to comment publicly 'till almost 10:00 P.M., and that these meetings sometimes go 'till 11:00 , all I have to say is that the public is treated like S*** at these meetings, they are run like s*** by the state reps(new region 6 manager for one), VERY discouraging to those from the "public"who give up their time (and supper!) to attend these "talkfests", don't quite see what our input has to do with anything that they will "accomplish", BUT WE WILL BE THERE on Wed. Bob R
Well here is the next meeting for Willapa and it is the public input portion of the NOF process. Now considering the bomb that WDF&W dropped in scrapping the so called Willapa Management Plan at the Adviser meeting and implementing new objectives it might be a meeting to attend. There is a lot of doubt out in the public as WDF&W outlined commercial cut backs but not the rec. Word is the gillnetters are out recruiting Rep Blake & Senator Hatfield to stop any reform or reduction in commercial net seasons. Several folks are trying to get the agency to put forth a meeting notice and a copy of the new Willapa Objectives for the public to review but so far WDF&W has refused to do so.
Please folks recognize it is not accidental as they are conducting business as usual out of sight no input no nothing. It would appear WDF&W and Region 6 have not learned a damn thing in the past two years. One would think if your going to have a auction ( hidden influence ) on the citizens salmon seasons they would at least let everyone know the starting bid.
Willapa Bay NOF Public Workshop #1 (APA record testimony to immediately follow) March 25th 6 pm to 8 pm Raymond Elks APA Process Review Forecast Management Objectives Management Plan Implementation Fishery suggestions
Small mesh gear (6" coho mesh) now carries a 56% chinook mortality ... effectively stretching the limited available gillnet impacts by another 10%. Might buy them another day in GH, almost certainly more in WB.
Actual practice table 3 at 90% compliance is where those numbers originate. The key is the numbers are off 90% compliance with the rules and add the 3% drop out to the numbers. Read the section on on-board observers and Willapa had .71% per boat trip. That does not appear to have pasted muster with the ISFP so what WDF&W does to get the observer per boat ratio up is going to be interesting to watch.
From ISFP: "To the ISFP, observer presence as implemented in past years is likely not sufficient to affect compliance rate for Fish Friendly techniques by the fishing fleet. "
Region 6 Fish Program Manager Steve Thiesfeld has provided several model options for folks to work with. If you were not on his contact list PM me your e mail address and I will forward it to anyone who wants to take a shot at working with the modeled options.
Little edit: To the question would one understand the model easily, ah no unless your very familiar with Excel. In addition the staff notes on the model identify using the Columbia 45% mortality on commercial release mortality which is not what will used but rather the new mortalities developed by the Independent Scientific Review. Any bio mathematicians out there familiar with fishing models that would like review the model would be great as the more eyes the better.
That said if one has the model I can show anyone interested how to navigate through the thing as it is not shall we say user friendly.
Did not know my e mail could melt, now I do. Here it is down and dirty. Many of us over the past year & half have beat the holy hell out of agency staff for not being forthright and transparent if you like. So The new R 6 Fish Program Manager Steve Theisfeld took a different track. He was rather frank on the status of negotiations with the QIN but stressed it is a work in progress. He asked that those present not blast things all over the web until the co managers have completed their negotiations.
Bottom line is oh so many have asked that the agency do just that, be transparent. So I ask all to respect that and let the co managers complete their process. Soon enough all can complain / endorse / scream your choice but at the moment all should respect the request and allow the co managers to finish their work.
Unknown date and time at this point. Depends on date they actually file the CR 102. Can't have a hearing for at least 30 days to allow public comment via emails & letters. Currently expected in August around the 8th with adoption by Director following day. I expect the hearings will be in Monte office, but they can hold them in Oly if they want.
Having managed to get sicker than my dog I have had little time ( or desire ) to track things but this bit below concerns the closure on the Hoh. I asked what was up and the response I received is below. My question was what was up with the Clearwater & Hoh seasons.
From WDF&W:
No changes to Clearwater that I’m aware of. I did a quick glance and didn’t see a change.
We are below escapement on the Hoh for spring chinook and made a decision to close. Data showed we only caught ~ 30 hatchery Chinook a year. Seemed like a pretty low harvest to incur impacts on the wild stock . We talked about that a couple of times at NOF. We are trying to keep the tribes to 6% harvest rate.
From another email response:
Greetings Mr. XXX,
Your interpretation of the new fishing regulations is not in error. For a number of recent years we have been experiencing lower than normal returns of Spring Chinook in the Hoh River (see graph below). This year the run was forecast down yet again. As a result, we chose to limit our impacts on this depressed stock by closing the sport fishery for retention of all Chinook during this time period. That being said, the summer steelhead fishery opens the first Saturday in June, June 7th.
I hope this clarifies the regulations for this season. If you have further questions or concerns, feel free to contact me.
Thank you for your time, David
David Low Fishery Biologist Washington Dept. of Fish & Wildlife Montesano, WA 98563 360-249-1216
I was asked to update folks on how the negotiations between WDF&W and the Quinault Nation ( QIN ) are going for the 2014 season. To be honest I do not know all that much more than everyone else does but I did ask a bit back. The response I received is below and is a pretty straight forward assessment. While I could take issue with several of the points regarding the QIN I will leave that for another day. Keep in mind the information below IS NOT my views but another individuals opinion.
I will try my best to lay out the QIN position: They are upset about the policy because it was developed without them and because we did not go out to them and walk them through it. Walking them through it didn’t make them feel any better. They feel like they are now being asked to consider a policy they had no hand in the development of. They don’t feel that there is a conservation problem in Grays Harbor. They feel like DFW staff did not push back hard enough that there isn’t a conservation problem in Grays Harbor. They feel like the recreational anglers are going to come after them next. They specifically pointed out the “Ban Gillnets” sweatshirts that folks wore to the commission meetings.
With regards to this year’s fisheries: Despite best efforts to point out the low run size of Hump NORs and the fact that we haven’t made the aggregate Chinook escapement goal in the past 2 years, they have not moved off their schedule. They correctly maintain that all of the agreed-to escapement goals are being met with their original schedule. They have conveyed that they remain flexible to discuss gear conflict, tides, first starts, etc. They have conveyed that they don’t feel obligated to help us achieve the policy objectives. At the last meeting, the issue of 4 calendar days or 96 hours came up. They felt we needed to clarify that. I have asked for that clarification, and it is 4 calendar days. That has really hamstrung us.
They feel like the recreational anglers are going to come after them next. They specifically pointed out the “Ban Gillnets” sweatshirts that folks wore to the commission meetings.
Ask the tribe located about 30 miles upstream (the basin's namesake) if they think there is a conservation issue, and I suspect you may get a different answer.... Makes one wonder what thinking goes on at the QIN table. Maybe for them it's simple: "We catch plenty of fish; there must not be an issue."
Low holing does lend a much more optimistic perspective, it seems.
So far, the paraphrased response above more or less looks the way I thought it would.
After running through my e mail I can put forth the following as pretty much right on.
1. WDF&W is still trying to have further conversations regarding the 2014 seasons but the QIN has pretty much put their cards on the table. One must remember that the QIN court mandates require them to manage to 50% harvestable across the bar. Escapements goals are for the basin and the QIN has no responsibility to manage down to the goal of each tributary reaching the escapement goal just the basin and the Humptulips is in the Chehalis Basin or Grays Harbor numbers. My view as to the new management plan excluding QIN participation is BS as the QIN could have participated at the Commission level but CHOSE NOT TO. They would prefer a behind closed door deal with WDF&W with no pier review or public scrutiny. Hell WDF&W has refused to provide the proposed QIN seasons for 2014 so this secrecy bit is both of them not just the QIN.
2. Humptulips hatchery funding that the QIN & WDF&W are working on is still in limbo.
3. Wynoochee Mitigation is still a issue. In 2010 the QIN's Ed Johnstone called BS on a revised plan that WDF&W put together which basically dropped out the additional mitigation production. WDF&W has been claiming that the QIN are holding things up and yes that may be true but Thank God or we would have truly had Region 6 running a muck. Now that the Commission has said the issue must be resolved by September so they need to go at it and get it done but not out of the public eye with WDF&W using some so called Technical Committee as a license to raid the mitigation funds.
4. With the passing of Billy Frank the QIN is pretty much looking inside to tribal functions honoring one of their leaders so not much is going to happen for a couple of weeks or so.
One more update. The Humptulips has a major straying problem with Coho and Natural Origin Coho being overrun by hatchery Coho. It is bad enough that it could impact both Rec & Commercial bay fisheries. ( A/C/D ) For years the local community and agency staff ( in Particular Paul Seidel, Jim Scot, Hal Micheals ) tried to get a intake for Stevens water to reduce straying but Puget Sound had priority. Well in the past Governor's job package the intake was included but not much has been said so I asked for a update and the response is below and this is great news!
" We took bids Wednesday and Quigg Brothers of Hoquiam was the low bid at $1,110,000. This was somewhat higher than the estimate of $950,000, but we’ll be awarding them the contract. We should have the contract executed in 3 weeks, and the contractor can start preparing for construction. Quigg is a good contractor and I’m pleased they got the bid. "
But, coho biology is that they spawn high in a watershed and rear low. Seed from the top down and then be pushed downstream to the desired habitat. From which they smolt. So, it is natural and desireable, from the fish perspective, to bypass the hatchery and push on upstream as far as they can. The solution would be to rack the Hump and filter out the hatchery fish.
Or, alternatively, allow enough wild fish to spawn that they numerically overwhelm the hatchery fish.
The agency has filed the CR 102 for the Willapa Commercial seasons. Take a look and more to come as we all look through but I was told that it is based upon a 90% compliance on tangle net & revival boxes for the commercial fleet which is a pure District 17 staff fabrication...period. In other words some good stuff in the 102 but also the same old crowd in Montesano Office helped by Olympia is trying to cook the books again.
Little Edit: Yes I immediately asked Kirt Hughes ( District 17 ) for the final model used as Region 6 Fish Program manager Steve Theisfeld is off for a few days.
The agency has filed the CR 102 for the Willapa Commercial seasons. Take a look and more to come as we all look through but I was told that it is based upon a 90% compliance on tangle net & revival boxes for the commercial fleet which is a pure District 17 staff fabrication...period. In other words some good stuff in the 102 but also the same old crowd in Montesano Office helped by Olympia is trying to cook the books again.
Public hearing is Tues June 24... mark your calendars if you can attend
Kudos to the agency for proposing the new escapement windows (2 days a week baywide and 3 days a week in 2U (Lower Willapa River main channel below the US Hwy 101 Bridge).
Trying to keep up so this ..... no I do not know the QIN proposed schedule or the NT Commercial for Grays Harbor. Now Region 6 knows the QIN position to be sure but it is my understanding that communications with the QIN have pretty much ground to a halt and last I know of is around the last PFMC meeting AND R-6 IS NOT SAYIN ANYTHING. So much for transparency but nothing new as WDF&W has always regarded the public with disdain.
Now as GH & Willapa go forward one should remember that R-6 Fish Program top gun is Steve Theisfeld BUT WE HAVE THE SAME CREW MANAGING DISTRICT 17 which is GH & Willapa drainages. So what you are about to see is a exercise that will resemble herding cats! The folks that manage District 17 ( or the current Director ) are not going to accept a conservation driven management plan and will require being dragged kicking & screaming into the modern era.
Update on the Willapa from District 17 Kirt Hughes but I could not get the week calander to come with it.
All – as a follow-up to yesterday’s email below, I wanted to provide the Willapa Bay planning model with resulting output used to evaluate the proposed schedule for Willapa Bay commercial salmon fisheries. As with yesterday’s email, please be aware I have blind copied the Willapa Bay Advisors and others who had provided their email and an interest in Willapa Bay during the 2014 North of Falcon process.
There was substantial deliberation and consideration of input and comment received through the NOF process that went into developing the proposed schedule, below are some of the rational. Please remember that there is still an opportunity for written and verbal testimony from the public on the proposal. The written comment period is open now and comments must be received by June 24th; email and mailing address are included at the very bottom of yesterday’s email below. The public hearing to provide verbal testimony is scheduled for June 24th at the Region 6 Fish and Wildlife Headquarters in Montesano from 10am – noon in the large conference room (48 Devonshire Road in Montesano).
• The proposed schedule is a blend of 4 different models presented to advisors and the public prior to the final advisor meeting and the public meeting on April 4.
• It meets natural origin management objectives for Chinook, coho, and chum, including the reduced 20% harvest rate on Naselle natural origin Chinook.
• This schedule continues to require the release of unmarked Chinook in all fisheries as stated in our management objectives.
• This schedule continues to require the release of chum in all fisheries as stated in our management objectives.
• Provides closures of areas 2M, 2R and 2P through September 15 to protect Naselle natural-origin Chinook as stated in our management objectives.
• Provides a larger closure around North River and Smith Creek to protect natural-origin Chinook in those streams to meet our management objective and some of the extra protection identified by the recreational sector.
• Reserves a small percentage (0.4% of the overall 20%) of the Naselle natural-origin mortality impact for potential new selective gears that might be developed, e.g. beach seines or trap nets.
• Provides a 3.5 day summer fishery as requested by the commercial sector. We propose moving the summer fishery a week early (week beginning August 3) to allow a greater build-up of Chinook in the bay for the recreational sector and reduce the probability of encountering local stocks, including North River/Smith Creek Chinook which were identified by the recreational sector as needing extra protection.
• Provides, to the extent practicable within other constraints, commercial openings are timed to coincide with tides preferred by commercial sector and often less desirable to sport fishers. It also provides a minimum of overlap with potential days of commercial fishing in the Columbia River during the mid- to late-August.
• Except during the summer fishery (prior to August 15, specifically August 7 at 6PM), keeps area 2T closed until September 16th as requested by the recreational sector.
• Except during the weeks beginning October 5 and November 9, provides 2-3 days without commercial fishing during each week to allow additional natural-origin spawners upstream, as well as additional hatchery and natural origin fish for the freshwater recreational sector. Note that these windows are not consecutive days as provided for in the Grays Harbor Policy.
• Results in an ex-vessel value of $594K versus an ex-vessel value of $705K if we used the 2013 seasons. These are relative values because there is very small number of unmarked hatchery fish included in the calculations that the commercial sector would be required to release.
• Provides the recreational sector with 38% of the Chinook harvest and 22% of the Coho harvest. This compares to the average from 2003-2012 of 34% of the Chinook and 10% of the Coho.
Finally, on a calendar this schedule look like this:
The escapement windows ( similar to what has been achieved in GH) are a BIG win at WB.
At last year's NOF, I got RW to model 2 days/wk escapement thru 2U to help move some fish upriver.... only to have the Prez of the GN association immediately challenge it.
"Jesus Ron, who's running this show anyway, you or some eye doctor?"
The model was promptly ratcheted down to a 1 day window.... then after more objection from the same guy, it was erased minutes later.
24/7 wipeout after mid-Sept was the outcome.
We're eating this elephant one bite at a time, but 2014 alone potentially takes a mighty big bite. Let's see who shows up at the hearing on June 24.
These comments came from RB a Willapa resident not one of us traveling sports or conservationist and are in response to the talking points circulated by Kirt Hughes the District 17 Bio that I posted a couple of post up in this thread. So I thought I would share them with everyone as he pretty much captured how many seem to feel.
Initial thoughts, not final comments: 1. Whereas nets get most of chinook and coho, if they cannot get any chum (except for a net mortality) then sports cannot have any. This is the old culture (see 6. below). 2. The "gaps" of two days a week are useless when one day at a time, especially with 2N fishery as such a big area. We already know what one day gaps do for escapement and recreational fishing. That is how we got where we are 3. With only one day gaps and the Nov. schedule, the coho wipeout now hits early and late run coho, and models or not, they continue to degrade any coho sport fishery in the bay. 4. With the early August 2T netting, it is now official, they are gill netting Columbia River chinook, plus any early North River natural spawners. Have seen no evidence these are not present in early August. Without such evidence, this schedule is evidence it is OK to risk this depressed run. We should demand proof North River fish are safe from the early 2T schedule, or oppose it. 5. Having seen your analysis of WDFW recreational harvest modeling, claims of a small increase in sport % harvest of chinook and coho are not only tiny, they are not credible. Any claims of increase in escapement may be just as questionable. 6. Chum have been arriving earlier than historically for several years in Willapa Bay. If chum are still in enough trouble that zero retention even by sports is possible, then netting "coho" through Oct 12 is tantamount to accepting a ruined chum run unless Mother Nature takes care of it. I suspect that chum have the high net mortality of chinook, because like chinook, we just do not see them with net marks. When observers see chum in the nets in Oct., the nets should come out. This would qualify as in-season management if we cared about restoring chum.
Results in an ex-vessel value of $594K versus an ex-vessel value of $705K if we used the 2013 seasons. These are relative values because there is very small number of unmarked hatchery fish included in the calculations that the commercial sector would be required to release.
Provides the recreational sector with 38% of the Chinook harvest and 22% of the Coho harvest. This compares to the average from 2003-2012 of 34% of the Chinook and 10% of the Coho.
The quote above is from the e mail authored by Kirt Hughes Bio District 17 ( Grays Harbor & Willapa ) that I previously posted and the bit below is a citizen who reviewed just those TWO lines above. More to come later but frankly the review speaks volumes as to the attempts by D 17 staff to misrepresent the 2014 Commercial CR 102. ( WAC's for the commercial season )
I feel you should be aware that we believe the presentation materials and discussion points circulated with the Willapa model and 2014 CR 102 are inaccurate and will be considered misleading by members of the public.
The bullet points in the presentation implies that the commercial season was cut substantially this year versus last using ex vessel sales projections created by inserting the 2013 season in the model and comparing it with the same for the proposed 2014 season. WDFW's presentation states:
Results in an ex-vessel value of $594K versus an ex-vessel value of $705K if we used the 2013 seasons. These are relative values because there is very small number of unmarked hatchery fish included in the calculations that the commercial sector would be required to release.
The model uses Cell X51 in calculating ex vessel values. We believe this cell has a formula problem (missing parenthesis) that values coho at approximately $1 per fish. If corrected, we believe the ex-vessel value for the proposed season in the 2014 CR 102 is $743,832.
More concerning, a comparison for sport harvest in the next bullet point implies the rec fisher will catch more fish in 2014 than previously. WDFW's presentation states:
Provides the recreational sector with 38% of the Chinook harvest and 22% of the Coho harvest. This compares to the average from 2003-2012 of 34% of the Chinook and 10% of the Coho.
The Department's decision to create a 10 year average and insert it into the presentation following the commercial "this year versus last" does not provide the viewer the similar comparison that is implied. Substituting a decade long average for the 2013 percentage of harvest substantially lowered the percentage of sport harvest from 2013 creating an impression of a dramatic increase occurring in sport harvest with the 2014 proposal. When one compares the 31.3% of the coho harvest by sports last year with the 22% expected in the 2014 season proposal it shows sports fishers will actually lose 9.3% to the commercial interests for coho this year.
The Department forecasts show a significant increase in returning Coho salmon that many challenge as unrealistically high. The increased forecast results in the model predicting a dramatic increase in the numbers of Coho returning to Willapa Bay in 2014 and therefore, more Coho being caught this year than last by both sports and commercials. Using "impacts" or the number of fish actually expected to be caught by the model, the following table shows commercial harvest of Chinook is down from 2013 and the sport catch is projected higher. However, when coho numbers are combined with Chinook, the model shows the 2014 proposed season for commercial nets will result in a impact gain for the commercials of 14,112 and only 2024 for the sport sector.
*2013 **2014 2014 Difference Nets Chinook 15,303 12,026 -3,277 Sport Chinook 5870 6,809 939 Nets coho 11545 28,934 17,389 Sport coho 5267 6,352 1,085 Nets +/- Total Fish 14,112 Sport =/- Total Fish 2,024
The Willapa planning model predicts the 2014 season proposal will result in commercial and sport interests increasing harvest by 16,136 total fish (Chinook & Coho combined). Of that number, 87% of the increase in combined catch numbers will incur on the commercial side and only 13% on the sport side. Using a comparison of the fish counts expected to be caught this year versus last leaves an opposite perception than the one created by WDFW using a 10 year average in percentages and ex vessel sales that were miscalculated by a formula error in the model.
This commentary relates the Willapa planning model supplied by WDFW and reportedly used when creating the season installed in the CR 102 for 2014. XXXXXXXX has repeatedly expressed numerous other concerns over other problems in the model that effect its reliability. Those concerns remain unchanged.
What we have here is a letter to the agency regarding Wynoochee Mitigation and WDF&W 's failure to meet its obligation for 23 years. It is a rather complicated subject but I think folks can get a idea of what is going on and others have knowledge of the history also they may wish to add.
I am writing on behalf of myself, Mr. XXXX, and Mr. XXXX regarding the Wynoochee Mitigation Funds placed in trust by Tacoma City Light ( TCL ) in 1991 for Mitigation for the dam modifications and power generation. Currently the trust has grown with interest to approximately $2,400,000 and the WDF&W Commission directed that a plan to utilize the funds be completed by September 30, 2014 and too date I do not know a plan being put forth by WDF&W staff for public review or comment for the production of 55,700 Coho smolt and 25,000 Steelhead smolt each year.
This being the case I will approach the issue from a historical perspective. WDF&W staff under the direction of former Deputy Director Larry Peck, and later yourself, in series of problem solving meetings with Chehalis Basin citizens that became known as the Bristol Process developed a plan and budget for Wynoochee Mitigation. ( attachment A ) It was agreed that WDF&W would forward the agreed to plan to the Quinault Indian Nation ( QIN ) representatives and other signatories of the Wynoochee Mitigation Agreement for comment and input. The final document was to be submitted to FERC for approval. If you recall both the local community and agency staff took considerable pride in jointly resolving the Wynoochee Mitigation and WDF&W's Skookumchuck Mitigation violations by working together.
What has become apparent is the fact that WDF&W staff failed to complete any of the task and when questions were directed to WDF&W staff by citizens regarding the issue staff assured these citizens that progress was being made. It was not until myself and Mr. Joe Durham both filed Public Document Request that documents became available that showed WDF&W staff had been less than forthright and were likely intentionally misleading citizens.
It appears that WDF&W Region 6 staff under both Ron Warren and Kirt Hughes took the following actions:
1. Documents provided through the PDR process show WDF&W revised the plan not once but twice ( attachment B ) by dropping out both the line item budget and the priority to produce the 55,700 Coho and 25,000 Steelhead smolt. When citizens questioned progress on the TCL Wynoochee Mitigation information was withheld by Region 6 staff, primarily Mr. Warren and Mr. Hughes.
2. Region 6 staff failed to properly present the Bristol plan for the use of Mitigation funds to the QIN resulting in the letter of 12/10/2010 from Mr. Ed Johnston representing the QIN ( attachment C ) objecting to the process WDF&W was utilizing. Again this information was withheld from the citizens of the Chehalis Basin until obtaining documents through the PDR process.
3. It appears WDF&W staff utilized a group of individuals identified as a Technical Committee to attempt to develop and move the Wynoochee Mitigation issue forward. Chehalis Basin citizen participation was not sought and it appears Wynoochee Technical Committee purpose was to shield WDF&W from the local communities scrutiny regarding the changes made in the planning for the use Mitigation Funds.
With the previously mentioned issues in mind we strongly feel that the following need to be incorporated in a revived Wynoochee Mitigation plan:
A. That the plan utilize a revised line item budget from the original Bristol Wynoochee Mitigation plan. That the budget clearly defined the number of Steelhead and Coho smolt to be produced, the cost associated with the rearing of the smolt, and the duration of the production.
B. The Bristol budget had funding directed toward a pipeline for Aberdeen Lake Hatchery that rears the mitigation production for the Wynoochee River. There is little disagreement as to the need for the pipeline as the health of the fish is of prime importance. This expense was originally in the Bristol prepared budget but due to recent efforts of Rep. Brian Blake state funds were provided for the pipeline construction. The funds made available by this outside funding makes available a considerable amount of funding available to address past failures by WDF&W to produce the additional 55,700 mitigation Coho smolt and 25,000 mitigation Steelhead smolt required for the TCL Wynoochee Dam power generation upgrade. It is our view the funds no longer needed for the pipeline should be allocated to producing the approximately 1,856,100 Steelhead and Coho smolt that WDF&W has failed to produce since the signing of the Memorandum of Agreement ( MOA ) in 1991 as required and prorated for the years remaining in the MOA.
C. Any remaining funds should be used to recycle adults from the dam to a point downstream to enhance harvest opportunity and Friends Landing is a viable release location.
D. The practice of placing large numbers of adult Wild Coho and Native Steelhead above the dam should end and only marked adults be placed above the dam. As very few, if any, smolt survive out migrating through the dam the practice of placing such large numbers of Native Coho and Native Steelhead adults above the dam has been and is a primary reason for the Wynoochee River failing to make Wild Coho and Wild Steelhead escapement and a terrible waste of Native Coho & Steelhead.
E. Wynoochee Dam mitigation production should be required, when possible, to utilize 100% native brood to reduce any possible genetic conflicts now or in the future.
F. The final issue we wish to address is what is not a acceptable use of the TCL Wynoochee Dam Mitigation Trust. It is our understanding that the original mitigation funds for the Wynoochee Dam have been utilized and that twice WDF&W has proposed eliminating the original Mitigation Steelhead production. The shortfall of these funds is the result of the former Washington Department of Game ( WDG ) utilizing a substantial amount of the Mitigation funds to remodel the Aberdeen Lake Hatchery. WDG Director Weyland guaranteed to the Chehalis Basin, that any future shortfall would be absorbed by the agency.
Simply put no part of the TCL Wynoochee Trust should be utilized to pay for expense of rearing the original Wynoochee Dam mitigation Steelhead smolt. That is a WDF&W responsibility outside of the purpose of the TCL Wynoochee Trust.
It is our belief that the steps we have outlined offer the best opportunity to address the failure of WDF&W to meet the TCL Mitigation requirements that WDF&W agreed to fulfill in 1991 as a signatory on the MOA. The TCL Wynoochee Dam Mitigation is a obligation WDF&W has failed to fulfill for 23 years and needs to be addressed promptly and just as importantly properly with citizen participation.
In addition as long time citizen activist we would urge WDF&W to reject its recent policies that shroud this and many other issues in secrecy and embrace the policies of transparency endorsed by the WDF&W Commission.
If you have any questions feel free to contact me.
Frankly the proposed seasons are a strange collection of things that appear to be one thing and are in reality another. I can provide a calendar that shows the seasons but I will have to e mail it to you. A large number of people are pouring over the model and the equity of harvest coupled with the failure of any conservation standards. The agencies take on their efforts are posted previously and I will attempt to get the problems that the "Old Gezer Gang " have found in the next couple of days.
Public Comment Period: Written Comments may be E mailed to: Rules.Coordinator@dfw.wa.gov or mailed to: Joanna Eide, Enforcement Program, 600 Capitol Way North, Olympia, WA 98501 Fax 360 902 2156
A public hearing will take place on June 24, 2014, at 10:00 a.m. to 12 p.m. Region 6 Fish and Wildlife Office, Conference Room 48 Devonshire Rd., Montesano, WA 98563
Well bit faster than I thought I could be but anyhow here is a compilation of comments that will be placed in opposition to the Willapa Harbor Commercial CR 102.
I am writing on behalf of myself, Mr. XXXX, and Mr. XXXX to express our concerns regarding the Willapa Commercial CR 102. As a citizen I, and all citizens, are offered the opportunity to review and comment on the proposed seasons outlined in the CR 102 as published in compliance with the Administrative Procedure Act ( APA ). Simply put we question that the average citizen will have the ability to do so as Region 6 District 17 staff have misrepresented the CR 102 to such a degree few citizens will have a clear understanding of what they are being asked to comment on.
On 5/21/14 Kirt Hughes provided via e mail a briefing paper to citizens. ( attachment 1 ) Items in red are from Mr. Hughes:
1. Results in an ex-vessel value of $594K versus an ex-vessel value of $705K if we used the 2013 seasons. These are relative values because there is very small number of unmarked hatchery fish included in the calculations that the commercial sector would be required to release. This is completely misleading as after review it is clear Mr. Hughes declined to correct a error in the model that he had knowledge of . In attachment 2 you can obtain a clearer understanding but the purpose appears to be an attempt to portray the commercial catch value in such a way to understate the value or equity with the Recreational fishers. The error is simply a wrong value in the formula and values a Coho at $1 a fish.
2. Provides the recreational sector with 38% of the Chinook harvest and 22% of the Coho harvest. This compares to the average from 2003-2012 of 34% of the Chinook and 10% of the Coho. Again this is not correct and in fact is a gross misrepresentation of the actual outcome should the Willapa commercial seasons be implemented as put forth in the Willapa CR 102. Again in attachment 2 you can clearly see that the Willapa planning model predicts the 2014 season proposal will result in commercial and sport interests increasing harvest by 16,136 total fish (Chinook & Coho combined). Of that number, 87% of the increase in combined catch numbers will incur on the commercial side and only 13% on the sport side. Using a comparison of the fish counts expected to be caught this year versus last leaves an opposite perception than the one created by WDFW using a 10 year average in percentages and ex vessel sales that were miscalculated by a formula error in the model.
3. Provides a larger closure around North River and Smith Creek to protect natural-origin Chinook in those streams to meet our management objective and some of the extra protection identified by the recreational sector. This is correct in the context that this brief statement provides but again is misleading. North River Native Chinook are the last remaining stock unimpaired by hatchery practices in Willapa Harbor. In addition SaSSI identifies that the North River Chinook return earlier than the rest of the Willapa Chinook. Region 6 Fish Program Manager Steve Theisfeld proposed a limited closure area to protect the returning fish that was woefully inadequate and so additional proposals expanding the area were proposed by myself and others.
While the closure area was adopted with the intent to protect the early returning North River Chinook the effort was negated by allowing a mislabeled dip in fishery targeting Columbia bound Chinook in Willapa 2T at the very same time the highest concentration of the North River Chinook are present. In the early commercial fishery scheduled to take place between August 3 to14th a 2T exclusion of commercial fishers needs to be imposed and maintained until September 15th to provide truly meaningful protection to North River Native Chinook .
4. Except during the weeks beginning October 5 and November 9, provides 2-3 days without commercial fishing during each week to allow additional natural-origin spawners upstream, as well as additional hatchery and natural origin fish for the freshwater recreational sector. Note that these windows are not consecutive days as provided for in the Grays Harbor Policy. The 4/3 policy implemented in the new Grays Harbor with three consecutive days was a major step by the Commission to address the inequities of harvest allocation as the commercial fisheries, be it tribal or non treaty, harvested the vast majority of the fish. In attachment 1 Mr. Hughes identifies the fact that the 4/3 Willapa is different than Grays Harbor's 4/3. This is correct and duplistic at the same time. The one day or two days a week of no commercial harvest starting September 14 in week 38 to the end of week 41 is a attempt at deception again. During this time frame in Willapa Bay returning salmon are primarily Coho and the size and topography of Willapa precludes major distances being covered by returning fish in such a short period of time. The 4/3 concept is dependent on the three net free days being consecutive.
The average citizen would be led to believe that they have a greater opportunity but as outlined previously this is nothing but a shell game intended to misinform the average citizen. What Region 6 District 17 has proposed is a nearly complete wipeout fishery by commercial fishers which precludes any reasonable sharing of harvest. Instead the harvest is misrepresented by Kirt Hughes 5/21/14 " Provides the recreational sector with 38% of the Chinook harvest and 22% of the Coho harvest. This compares to the average from 2003-2012 of 34% of the Chinook and 10% of the Coho" when in reality if represented truthfully it is the Willapa planning model predicts that the 2014 season proposal will result in commercial and sport interests increasing harvest by 16,136 total fish (Chinook & Coho combined). Of that number, 87% of the increase in combined catch numbers will incur on the commercial side and only 13% on the sport side. Using a comparison of the fish counts expected to be caught this year versus last leaves an opposite perception than the one created by WDFW using a 10 year average in percentages and ex vessel sales that were miscalculated by a formula error in the model. ( attachment 2 )
5. Willapa estuary fisheries, both commercial and recreational, are mixed stock fisheries that are not managed to the weakest stocks with equal harvest pressure throughout the entire run timing , a practice disavowed by most present day managers. It appears District 17 staff agree with the Willapa Gillnetters President that there is no need to manage harvest and escapement for natural origin fish only hatchery, which we feel is a rather barbaric view in this day and age. In the model none of the streams flowing into Willapa Bay will make Natural Origin Chinook escapement before either recreational or commercial harvest and fall wildly short after harvest. ( Willapa Model attachment 3 ) This is despite a exploitation rate reduction in the 2014 recreational and commercial seasons from 30% to 20% in an attempt to overcome District 17 Willapa model failures to predict accurately the true impacts of harvest in the Willapa Estuary. This we feel is not a acceptable management policy for Willapa Harbor. In our review several knowledgeable citizens reviewing past model performance believe the model performance is such that the exploitation rate would need to be reduced to 10 to 15% to have any possibility for escapement goals being met for Natural Origin Chinook in the Willapa Harbor estuary.
6. The Willapa model identifies a substantial number of Chum, both hatchery and wild, are killed in the targeted commercial Coho fishery. While it is normal for there to be collateral impacts to non targeted stocks in both commercial and recreational fisheries, some of the proposed weeks in the Willapa commercial seasons are extreme. In the period October 8th through the 14th the model projects a Coho harvest of 3,380 with a by catch mortality of 2,922 Chum which is nearly 1 to 1. The commercial fleet is kept off the water for the days of October 15th through the 31st but return November 1st through the 10th. The model projects a Coho catch of 4,593 with a Chum by catch of 1,163 which results in approximately a 4 to 1 by catch ratio. The proposed by catch of Chum in both weeks is unacceptable and both of these weeks in the commercial should be cancelled and the possibility of alternate days without such extreme by catch explored.
7. It is our understanding that the Chum release mortality rate is calculated at 56% based upon the assumption of 90% compliance by the entire commercial fleet. Having broodstocked with tangle nets, participated in the filming the Grays Harbor Non Treaty Commercial fishers, and understanding that time is money to a commercial gillnet fisher one has to conclude that this is not a valid compliance percentage. It appears rather than identify the proper number of observers to achieve a 90% compliance rate that Region 6 District 17 staff simply picked the 90% rate to extend the commercial seasons to the maximum number of days possible. It is our belief that a minimum of 10% of the commercial fleet must have observers onboard in a 24 hour period to remotely come close to the 90% compliance staff is using in the model. Failure for WDF&W to achieve 10% observers fleet wide should result in a much higher mortality rate being utilized for released fish.
It is our belief staff should withdraw the Willapa Commercial CR 102 and start again regardless if the action results in delays in the Willapa Commercial seasons. Deception and misleading citizens is not acceptable and possibly violates Washington State Law in our view. The APA process and WDF&W's responsibility to comply with it are paramount!
Pretty dry reading lately as a lot of folks have been trying to get information out. So just what are the objections in English? Well several but lets start with this. The release mortality from the commercial fleet is 56% at 90% compliance. In other words WDF&W is saying in the CR 102 that 90% of the netters will follow the rules and if they do only 56% of the fish the fleet release will perish. This is BS and there is no way that WDF&W will have the ability to get 25% of the fleet fishing days with onboard observers to which is needed to utilize the 90% compliance. In other words what information is out there basically says that commercial selective fisheries compliance with regulations ARE DEPENDANT on the percentage of the fleet with on board observers. Let us say that WDF&W only has 10% boat days with observers then compliance would drop from 90% to 70% or so which means the release mortality goes up 70% or so which results IN FAR LESS DAYS on the water for the gillnet fleet.
Next up is the definition of lethargic. Now when gillnetter drags a non targeted species up in a net the commercial fisher is required to: a. Assess the condition and release the fish if vibrant, b. Put the fish in a on board recovery box if lethargic and then release after recovery.
The problem? Well the same District 17 staffer that never saw Chinook coming out of a gillnet dead or lethargic as a observer evidently wrote the definition for lethargic in the Willapa and frankly the fish damn near have rigor mortis setting in to qualify as lethargic. This is important as during the commercial Chinook season and absolutely ALL the time that Chum are present in the commercial Coho season, the injured fish will fill the recovery boxes and require the nets be pulled for a time. So District 17's answer is just redefine lethargic to damn near dead so the commercial fleet can fish in a "selective fishery" with 56% mortality when in reality it much much higher!
This one is ugly. In the week of 10 / 8 - 14 the proposed catch is 3380 for Coho with a by catch of 2922 Chum mortality calculated at 56% @ 90% compliance. This is nearly 1 to 1 a dead Chum as Crab food for every Coho sold. After a two week absence to protect the Chum the commercial fleet returns 11/1-10 and the model projects 5415 of Coho harvested with a by catch of 1163 which is approximately 4.5 Coho sold to 1 dead Chum as Crab feed. Again this ratio is ridiculous to anal you choose but any way you cut it unacceptable.
So why all the gyrations? It is called "cooking the books" and District 17 staff have elevated the practice to damn near a art form! It is about finding a way to get the model to show that commercial impacts are acceptable.
I received a few questions around the term lethargic and the following is from the Willapa Commercial CR 102 Page 6:
"Lethargic is defined as having or showing very little movement or is nonresponsive."
Now folks this definition of movement or nonresponsive means the fish is ALMOST DEAD!!!! I mean your like one step away from rigor and I swear WDF&W would try and call that lethargic if they could figure out how to make the fish wiggle so they could pitch it overboard and keep the gillnet fleet on the water.
I have been asked about Grays Harbor Commercial seasons, no idea. They looked like late October and November the new policy limits the wild West bit that existed in the past. In addition the Quinault Nations proposed seasons do not violate court agreed to escapement goals. That is the rub as when Tim Flint headed up Region 6 he separated the Humptulips from the Chehalis not for conservation but to enable a Rec bay fishery. Well with Coho Natural Origin Recruits ( wild spawners ) not making escapement BEFORE harvest it creates scenario riddled with contradictions to the new policy guidelines. One should remember that this IS NOT a big deal on the Rec side but is driven by WDF&W's refusal to recognize that the Chehalis Tribal and QIN ARE the commercial fisheries for Grays Harbor. It is time for WDF&W management to get over this Indian / white guy thing.
The letter below is my, and two other "old Geezers", comments in a letter to the Commission objecting to the Willapa CR 102 and the gross misrepresentation of the proposed Willapa commercial seasons by WDF&W staff.
June 6, 2014 via email: hard copy by mail
WDF&W Commission Washington Department of Fish & Wildlife 600 Capitol Way N. Olympia, Washington 98501-1091
Dear Commissioners, I am writing on behalf of myself, Mr. XXXXXX, and Mr. XXXXXX to express our ever growing concerns regarding the Willapa Commercial CR 102. As a citizen I, and all citizens, are offered the opportunity to review and comment on the proposed seasons outlined in the CR 102 as published in compliance with the Administrative Procedure Act ( APA ). Simply put I question that the average citizen will have the ability to do so as Region 6 District 17 staff have misrepresented the CR 102 to such a degree few citizens will have a clear understanding of what they are being asked to comment on.
On 5/21/14 Kirt Hughes provided via e mail a briefing paper to citizens. ( attachment 1 ) Items in blue are from dissertation and Mr. Hughes stated:
1. Results in an ex-vessel value of $594K versus an ex-vessel value of $705K if we used the 2013 seasons. These are relative values because there is very small number of unmarked hatchery fish included in the calculations that the commercial sector would be required to release. This is completely misleading as after review it is clear Mr. Hughes declined to correct a error in the model that he had knowledge of . In attachment 2 you can obtain a clearer understanding but the purpose appears to be an attempt to portray the commercial catch value in such a way to understate the value or equity with the Recreational fishers.
2. Provides the recreational sector with 38% of the Chinook harvest and 22% of the Coho harvest. This compares to the average from 2003-2012 of 34% of the Chinook and 10% of the Coho. Again this is not correct and in fact is a gross misrepresentation of the actual outcome should the Willapa commercial seasons be implemented as put forth in the Willapa CR 102. Again in attachment 2 you can clearly see that the Willapa planning model predicts the 2014 season proposal will result in commercial and sport interests increasing harvest by 16,136 total fish (Chinook & Coho combined). Of that number, 87% of the increase in combined catch numbers will incur on the commercial side and only 13% on the sport side. Using a comparison of the fish counts expected to be caught this year versus last leaves an opposite perception than the one created by WDFW using a 10 year average in percentages and ex vessel sales that were miscalculated by a formula error in the model.
3. Provides a larger closure around North River and Smith Creek to protect natural-origin Chinook in those streams to meet our management objective and some of the extra protection identified by the recreational sector. This is correct in the context that this brief statement provides but again is misleading. North River Native Chinook are the last remaining stock unimpaired by hatchery practices in Willapa Harbor. In addition SaSSI identifies that the North River Chinook return earlier than the rest of the Willapa Chinook. Region 6 Fish Program Manager Steve Theisfeld proposed a limited closure area to protect the returning fish that was woefully inadequate and so additional proposals expanding the area were proposed by myself and others.
While the closure area was adopted with the intent to protect the early returning North River Chinook the effort was negated by allowing a mislabeled dip in fishery targeting Columbia bound Chinook in Willapa 2T at the very same time the highest concentration of the North River Chinook are present. In the early commercial fishery scheduled to take place between August 3 to14th a 2T exclusion of commercial fishers needs to be imposed and maintained until September 15th to provide truly meaningful protection to North River Native Chinook .
4. Except during the weeks beginning October 5 and November 9, provides 2-3 days without commercial fishing during each week to allow additional natural-origin spawners upstream, as well as additional hatchery and natural origin fish for the freshwater recreational sector. Note that these windows are not consecutive days as provided for in the Grays Harbor Policy. The 4/3 policy implemented in the new Grays Harbor with three consecutive days was a major step by the Commission to address the inequities of harvest allocation as the commercial fisheries, be it tribal or non treaty, harvested the vast majority of the fish. In attachment 1 Mr. Hughes identifies the fact that the 4/3 Willapa is different than Grays Harbor's 4/3. This is correct and duplistic at the same time. The one day or two days a week of no commercial harvest starting September 14 in week 38 to the end of week 41 is a attempt at deception again. During this time frame in Willapa Bay returning salmon are primarily Coho and the size and topography of Willapa precludes major distances being covered by returning fish in such a short period of time. The 4/3 concept is dependent on the three net free days being consecutive.
The average citizen would be led to believe that they have a greater opportunity but as outlined previously this is nothing but a shell game intended to misinform the average citizen. What Region 6 District 17 has proposed is a nearly complete wipeout fishery by commercial fishers which precludes any reasonable sharing of harvest. Instead the harvest is misrepresented by Kirt Hughes 5/21/14 " Provides the recreational sector with 38% of the Chinook harvest and 22% of the Coho harvest. This compares to the average from 2003-2012 of 34% of the Chinook and 10% of the Coho" when in reality if represented truthfully it is the Willapa planning model predicts that the 2014 season proposal will result in commercial and sport interests increasing harvest by 16,136 total fish (Chinook & Coho combined). Of that number, 87% of the increase in combined catch numbers will incur on the commercial side and only 13% on the sport side. Using a comparison of the fish counts expected to be caught this year versus last leaves an opposite perception than the one created by WDFW using a 10 year average in percentages and ex vessel sales that were miscalculated by a formula error in the model. ( attachment 2 )
5. Willapa estuary fisheries, both commercial and recreational, are mixed stock fisheries that are not managed to the weakest stocks with equal harvest pressure throughout the entire run timing , a practice disavowed by most present day managers. It appears District 17 staff agree with the Willapa Gillnetters President that there is no need to manage harvest and escapement for natural origin fish only hatchery, which we feel is a rather barbaric view in this day and age. In the model none of the streams flowing into Willapa Bay will make Natural Origin Chinook escapement before either recreational or commercial harvest and fall wildly short after harvest. ( Willapa Model attachment 3 ) This is despite a exploitation rate reduction in the 2014 recreational and commercial seasons from 30% to 20% in an attempt to overcome District 17 Willapa model failures to predict accurately the true impacts of harvest in the Willapa Estuary. This we feel is not a acceptable management policy for Willapa Harbor. In our review several knowledgeable citizens reviewing past model performance believe the model performance is such that the exploitation rate would need to be reduced to 10 to 15% to have any possibility for escapement goals being met for Natural Origin Chinook in the Willapa Harbor estuary.
6. The Willapa model identifies a substantial number of Chum, both hatchery and wild, are killed in the targeted commercial Coho fishery. While it is normal for there to be collateral impacts to non targeted stocks in both commercial and recreational fisheries, some of the proposed weeks in the Willapa commercial seasons are extreme.
In the period October 8th through the 14th the model projects a Coho harvest of 3,380 with a by catch mortality of 2,922 Chum which is nearly 1 to 1. The commercial fleet is kept off the water for the days of October 15th through the 31st but return November 1st through the 10th. The model projects a Coho catch of 4,593 with a Chum by catch of 1,163 which results in approximately a 4 to 1 by catch ratio. The proposed by catch of Chum in both weeks is unacceptable and both of these weeks in the commercial should be cancelled and the possibility of alternate days without such extreme by catch explored.
7. It is our understanding that the Chum release mortality rate is calculated at 56% based upon the assumption of 90% compliance by the entire commercial fleet. Having broodstocked with tangle nets, participated in the filming the Grays Harbor Non Treaty Commercial fishers, and understanding that time is money to a commercial gillnet fisher one has to conclude that this is not a valid compliance percentage. It appears rather than identify the proper number of observers to achieve a 90% compliance rate that Region 6 District 17 staff simply picked the 90% rate to extend the commercial seasons to the maximum number of days possible. It is our belief that a minimum of 24% of the commercial fleet must have observers onboard in a 24 hour period to remotely come close to the 90% compliance staff is using in the model. Failure for WDF&W to achieve 10% observers fleet wide should result in a much higher mortality rate being utilized for released fish.
In closing we would like to state that while as citizen advocates we realize the Commission has no desire to nor should it desire to " micro manage " Willapa Recreational or Commercial seasons but the gross misrepresentation of information provided to citizens by District 17 staff for the Willapa Commercial CR 102 leads us to believe that the APA process has been compromised. In addition to the previously outlined actions to modify the Willapa Harbor Non Treaty Commercial Fishery we urge the Commission to consider implementing the following additional steps:
A. Instruct staff to withdraw the Willapa Commercial CR 102 and start again regardless if the action results in delays in the Willapa Commercial seasons. Deception and misleading citizens is not acceptable and possibly violates Washington State Law in our view. The APA process and WDF&W's responsibility to comply with it are paramount!
B. We urge the Commission to use its authority to create the ability for Fish Program Manager Jim Scott and Region 6 Fish Program Manager Steve Theisfeld to replace current underperforming Region 6 & District 17 staff. From continuing model errors, lack of any conservation standards, misrepresentations to the public ( including the Grays Harbor process to the Commission ), and a bias leading to discrimination imposed upon the recreational fisher in Willapa, it is clear that WDF&W Region 6 and District 17 staff lack the desire, the ability, or leadership to properly manage harvest in Willapa or Grays Harbor.
The complete lack of any harvest conservation standards in Willapa is simply one of the most appalling that we have observed in our many years as citizen advocates for the resource. It is our view that without Commission intervention little will change.
Sincerely,
XXXX
CC: Director Phil Anderson WDF&W Fish Program Manager Jim Scott Region 6 Fish Program Manager Steve Theisfeld
The link is to a number of documents created by the Advocacy commenting on the proposed Willapa CR 102 Commercial non treaty net seasons. The models are best viewed after down loading as they are basically reassembled so one better understand them. https://drive.google.com/#folders/0B2tWjgmgVy3yOVZoZzhjV0lVRXc
The letter below is to the Commission from the guys basically calling Bullsheet on Region 6 Willapa process and links to documents are in it also. This is a bit of reading but if you take the time to read the letter to the Commission and the CR 102 comments it pretty much captures the process, such as it is. Keep in mind C&P suffers a bit on PP as the formatting kinda / sorta runs off ....... someplace but you should be able to make heads or tails of it.
Also if anyone would want the documents e mailed so you can send them to others just send your e mail address and I will get them out to you.
May 17, 2014
The Honorable Commissioners Washington Fish & Wildlife Commission 600 Capitol Way N. Olympia, WA 98501
Re: 2014 Willapa Commercial Season
Dear Members of the Commission:
The Twin Harbors Fish & Wildlife Advocacy is a nonprofit corporation “.....organized for education, science, and other efforts that encourage the public, regulatory agencies and private businesses to manage or utilize fish, wildlife and other natural resources in a fashion that insures the sustainable of those resources on into the future for the benefit of future generations......”
As you are aware, the members of the Advocacy settled a legal challenge to the 2013 Willapa Bay commercial gillnet season under terms agreed by the Department that included three components as follows:
1. An Independent Fisheries Science Panel (IFSP) would be retained to provide recommended mortality rates for selective fishing in Willapa and Grays Harbor;
2. The Advocacy would assist the Department in improving its image and restore public confidence through a series of jointly sponsored meetings would be held to educate the public on season setting processes;
3. The Director would petition the Commission to reopen the Management Plan for Willapa Bay terminal this year.
The first component has been completed. The other two have not and at this point the Advocacy questions whether the goals of any of the three can be reached. However, we do not seek Commission support to complete these conditions. We have legal remedies available to insure the Department keeps its side of the deal.
At this point in time, the Department has filed the CR102 for the 2014 season in Willapa. The season set and WAC language inserted are expected to be adopted on or shortly after the public hearing set for June 24th. The filing of the CR102 with its current language has pushed all to the brink of the cliff. Shortly after the hearing, we fully expect the Department to force all over the edge by adopting the current proposal. Within days, if not hours of adoption, the Advocacy and others will have no choice but to file yet another legal challenge and the Department will be embroiled in yet another round of contentious and prolonged litigation that pits the state treasury against the wallets of its citizens. The goals we had hoped to achieve when entering into the original settlement seem to be rapidly fading away.
The Advocacy has invested significant resources into a presentation that has been provided the Department and duly filed on the record of the APA process for the season. In a candid, critical, and specific fashion, we explain our concerns regarding the current WDFW proposal. The presentation includes specific language change recommendations and three season options set forth in individual Excel spreadsheets created from the one used by WDFW to establish its proposed season.
Another Excel spreadsheet is included that conducts an economic and harvest impact analysis comparing the season proposed by the Department with the options proposed by the Advocacy. This spreadsheet shows why the Advocacy believes its recommendations and the three season options we have developed offer the Department an opportunity rethink its proposal and incorporate provisions that decrease management costs, provide increased profit potentials for the commercial fleet, prevent thousands of fish being killed only to be flung overboard, improve conservation performance and dramatically reduce gear conflicts between the stakeholders.
Review of the Advocacy’s presentation shows that it is not impossible to develop a season that promotes conservation while maximizing harvest opportunity. Unfortunately, while it tries desperately to do so, the Department cannot satisfy all the stakeholders, as it cannot “create 3 full filets out of one salmon.” This is especially true in Willapa for the commercial season as:
• the decline in run sizes diminishes the available harvest;
• the historical fishing practices have decimated natural spawning stocks that the Department is mandated to protect; and
• The ever-increasing costs of taxes, labor and fuel incurred by the gillnet fisherman, combined with the large number of licenses issued (fewer fish per boat) makes the success of the commercial fleet reliant upon the state delivering larger numbers of fish into the nets than are available for harvest.
Recognizing these obstacles, what does seem impossible for the Department is to deliver a season acceptable to the commercial sector even if the season put every one of the few returning natural spawning fish entering the bay into a tote on the deck of a gillnet boat. As a result, the Advocacy accepts the Department staff face a “damned if you do and damned if you don’t scenario” and any season it proposes would likely disappoint the fleet.
However, the Advocacy refuses to accept the notion that it is impossible to improve the performance of the Department when setting seasons. As an example, the Department issued a statement to the public as it filed the CR 102 several weeks ago that claimed the expected “exvessel value” or gross sales of fish to the fleet of the season was “$594K”.
Disclaimer: The Advocacy repeatedly advised the Department during the NOF process that a cell in its harvest model was miscalculating the exvessel value due to a missing parenthesis in a formula inserted in a particular cell. To open the model, find the cell, and make the correction took the Advocacy less than a minute. For some unknown reason, the Department failed to make the correction. If corrected, the model calculates the exvessel value of its current proposal at $736,595.
Regardless, at the point it filed the CR102 containing its proposed season, the Department believed the season it was proposing provided $594K of exvessel value, fished nearly to the last available fish, necessitated extensive investments by the Department into onboard programs during selective fishing cycles (funding source unknown), and killed 5,459 Chum that were to be flung over the side as crab bait. We believe these statements are undisputable facts as documented in WDFW’s own harvest model used to file the CR 102 and create the presentation materials provided the public thereafter.
The Advocacy simply will not accept this proposal is the “best that we could do”. The three season options that the Advocacy is presenting for consideration exceeds the Department’s claim for its proposal with its own model predicting exvessel sales opportunity of $535,569, $636,940, and $742,641. Non-selective 24 hour gillnet seasons with shortened days are offered that allow the fisher flexibility in selecting net mesh sizes and times to be on the water reducing the costs to the fleet as a means to improve the bottom line, which is the true goal of a commercial fisherman.
Conservation standards are improved by avoiding fishing to the last fish. Enhanced protection of native spawning stock is provided and not a single salmon is killed and thrown overboard as crab bait. When selective fishing is utilized, the season is structured to reduce the compliance costs to the fleet and the Department. The Advocacy even goes to the point of offering to provide financial support to help cover the Department’s cost of onboard observer programs to maximize time on the water for the fleet.
The Advocacy is not requesting that the members of the Commission either individually or jointly attempt to intervene in the season setting process or micromanage the Department. However, we do believe it is time to error to the side of candidacy and “lay all cards on the table, face up”. Simply put, the process utilized to set season reflects a Department that is politically polarized and without help from the Commission, it’s all going to come to a head on or shortly after June 24th.
Many in the public are convinced that a season was determined in negotiations outside of public view between upper management and a small number of commercial license holders who consistently turned to key legislators for support and leverage. The basic parameters of the agreed season were supplied to Fish Program staff assigned the dubious task of massaging and manipulating the harvest model to get the predetermined season to fit under the harvest caps set in the model as conservation standards. Then came development of presentation materials to promote the season as the CR 102 was filed.
Not being skilled in the arts of forensic accounting, legalese, and political spin, the presentation to the public came across clumsy at best. The ever-growing number of critics look over the model used and quickly determine where and how the “books have been cooked” to fit the season into the model. Since staffers are not skilled in the art of political spin, review of the sales presentation lead many to the conclusion all is a blatant attempt to deceive (reminiscent of the public reaction to staff’s presentation to the Commission during the re-writing of the Grays Harbor Management Plan). Since the season also fails to deliver the number of fish needed to deliver the desired profit, the commercial interests join in the fracas. Fish Program staff is hung like a punching bag in a gym and the poles and the nets combine forces to work them over.
While it may seem unbelievable to some reviewing its presentation, the Advocacy is convinced the staff within Fish Program have all the education, experience, expertise and experience needed to adopt a season appropriate for Willapa Bay. Key leadership needed is in place. While it unlikely we will reach consensus on all issues, the Advocacy believes Jim Scott and Steve Theisfeld have the talents and abilities to get the job done. However, due to the political polarization and management culture found within the Department, we are also convinced they will not be allowed to actually do the job for which they are paid.
This all leads us to the point where we ask for the support of the Commission. Again, not to adopt or oppose any particular season and, certainly not to micro-manage. Rather, we simply ask that the members of the Commission use individual or combined influence to insure the public that the professional staff within Fish Program have the freedom to make the final decisions for a 2014 commercial season based on their combined professional judgment using the education and expertise they hold and to do so without fear of damage to their careers.
The Advocacy remains committed to protecting and enhancing fish resources in Willapa and Grays Harbor. We fully recognize reasonable people can “agree to disagree” and pledge to remain open-minded until the WAC is adopted. If the current season proposed rules the day, we will honor our commitments to protect these valuable public resources with conviction and vigor.
The Advocacy believes it has done everything possible to avoid yet another legal confrontation and at this point, fear all our efforts have failed. We now pass the ball over the net into the Commission’s court. We stand ready to respond to any questions or requests for additional information.
The Advocacy presentation provided the Department, with attachments, and all the previously referenced Excel files that include the season options referenced have all been posted on Google and are available for downloading at the following addresses:
The letter below is self explanatory but if one ever wanted a break out of how & what the turmoil in WDF&W Enforcement has been this should take care of that problem in short order.
To: WDFW Commissioners, WA State Legislators, and Governor Jay Inslee From: WDFW Detective Todd Vandivert (retired) Re: WDFW “Issues”
We want to take this opportunity to tell you about several significant issues with WDFW (WA Dept. of Fish and Wildlife) in hopes that you can help to resolve these problems, get WDFW back on track, and allow the dedicated employees of WDFW to do their jobs without fear of abuse, corruption or retaliation.
I need to first introduce myself to all of you. I worked for WDFW for about 34 years, before retiring in December 2012. I spent ~22 years as a uniformed fish and wildlife officer before promoting to fish and wildlife detective, where I worked undercover on commercial fish and wildlife criminal cases until my retirement. I have been stationed on both sides of the state, have worked both land and marine duties, and have twice received the statewide officer of the year award.
Over my 34-years with WDFW (I started with the Game Dept.) I have seen some tough times, but nothing as severe as in the last several years. Under Director Phil Anderson’s lead, I have seen cronyism become the norm, employees being threatened berated and retaliated against, and corruption in promotions and discipline. I have watched as top-notch senior officers have fled to other jobs or retired early, while the administration grew more top-heavy with “yes men”. I have watched the WDFW enforcement program virtually unmerge, back into two separate entities (marine officers and land officers) as it was before the merger of Dept. of Fisheries and Dept. of Wildlife.
Shortly after my retirement, I wrote a book (OPERATION CODY) which detailed both the most successful investigation of wildlife trafficking in Washington’s history, and the absolute disfunctionality of WDFW enforcement. As most of my experience is with the enforcement program, that is the perspective from which I will address you, but in the 2013 DOP “State Employee Survey” only one state agency had lower “(employee) General Satisfaction” survey results than WDFW, and WDFW tied for 2nd worst in “(employees) Treated with respect”, so it’s safe to assume these issues at least somewhat cross all programs in WDFW. I also want to make it clear that I do not speak for all WDFW enforcement employees. That being said, I would guess that if you ask WDFW land officers you will find most agree with my position (but are afraid of coming forward) while most marine officers would not. The distinction between the satisfactions of marine officers vs. land officers is largely attributed to Deputy Chief Mike Cenci (a former Dept. of Fisheries officer). Cenci is, without a doubt, the most abusive supervisor I have ever heard of in state government. Many officers have pleaded with Director Anderson and former Chief Bruce Bjork to remove or at least demote Cenci, but to no avail. In-fact Director Anderson ignored those pleas for help until finally in early 2013 when WDFW hired an “investigator” to look into many serious allegations against the deputy chief. The “investigation” was (in our opinion) a sham and read as if it was written by the deputy chief himself, but did verify several disturbing allegations (other allegations were either not investigated at all, or were only partially investigated, while some allegations were determined to be unfounded). Why the director has allowed enforcement to run out of control, and even protect those whose behavior is well below professional standards is an unanswered question. Perhaps it is because those same offenders (the administration of WDFW enforcement) gave the director’s son a fish and wildlife officer job, or perhaps he just doesn’t care. The following pages will provide you with some examples of what motivated us to write this letter, in hopes of protecting our resources, as well as the fine officers of WDFW left behind when I retired. If any of you so desire, I can provide you with written materials documenting and supporting the allegations we list below. These same allegations, and supporting documentations have also been provided to several investigative reporters with both the print and television media. The below allegations listed have been investigated to best of our abilities but interviews and further investigation, by a truly independent law enforcement investigator (NOT A WDFW EMPLOYEE), should be conducted to substantiate these allegations independently.
Supporting documentation, for the allegations listed below, is available upon request. 1) Within months of Steve Crown being appointed to the Chief of enforcement, he fired the vice-president of the F&W (Fish and Officers) Guild and demoted the president of the F&W Sergeants’ union.
2) Cronyism. Enforcement always promotes from within, and eliminates anyone with opposing views/opinions. Experience seems to no longer be a factor. A) When Chief Bjork retired (summer of 2013), a “nation-wide search” for a new chief was conducted, by posting the job announcement on the WASPC (WA Association of Sheriffs and Police Chief’s Association) website. The posting lasted 23 total days, including 6 weekend days and a holiday (only 16 work days in total). B) Newly appointed Chief Crown worked in the same office with ex-chief Bjork, yet had only supervised one uniformed officer in his entire career. He now supervises the entire force. C) When Chief Crown was the training/hiring Lt., he earned a reputation for being lazy, non-responsive and disconnected. He rarely responded to emails or phone calls from officers who were to train the newly hired officers, and often sent new officers into the field without the necessary equipment or training materials. D) On 07/09/13 the F&W Officer’s Guild asked Director Anderson to be included in the selection process for the new chief. On 07/15/13, Director Anderson agreed to allow WDFW officers and sergeants to assist in selecting a new chief. In an email Anderson said; “It is important to me to gain the insights from the Guild and the other sectors of the Enforcement Program prior to making the final selection. I would like to ask the Guild to designate four officers to participate in a group made up of representatives of the Program that will be afforded an hour to interact with our finalist(s) prior to my making the final selection.” On 07/22/13 Director Anderson sent out the following email; “We have selected Lt. Steve Crown as the finalist for the Chief's position. Joe and I have offered an opportunity for representatives of the Officer, Sergeants, Captains, and headquarters Staff to interact with Steve on Wednesday afternoon here in Olympia at the NRB in room 172 beginning at 3:00 p.m. Our meeting will consist of two 45 minute segments, one to hear from and interact with Lt. Crown and the second 45 minute segment will be for Joe and I to hear from you regarding your perspectives on what you heard and the abilities of our finalist to be a strong and effective leader of the Enforcement Program.” Before the panel, including officers and sergeants, were to convene Director Anderson had already narrowed the application pool to only one candidate; Steve Crown, even though he had agreed to include F&W officers in the selection process. F&W Officer’s Guild President Mark James then asked Director Anderson why he had already selected one candidate without including the guild, to which Anderson answered; “So to be clear, a job offer has not been extended to anyone yet. After conducting a thorough review of applications and interviews of those meeting the minimum qualifications, we have a single candidate that rose to the top.” At the 07/24/13 meeting (a meet and greet with the new chief), Director Anderson stated he recognized there were significant issues with enforcement (and listed many of them out), then assured the participants (including sergeants and officers) these issues would be resolved within 6 months. 15 months later things have only gotten worse. E) When region 4 (Seattle region) Captain Bill Hebner retired, both Sgt. Rich Phillips and Sgt. Hobbs applied for the promotion. Sgt. Phillips had over 30 years of experience, had been a Sgt. many years more than Hobbs, was very well respected, had experience in negotiating tribal issues as well as labor contracts, and had served as assistant commander of the WA CJTC (Criminal Justice Training Commission) police academy, but also served as the F&W Sergeants Union President. Hobbs had very little experience, yet somehow beat out Phillips for the promotion. F) Chief Crown recently promoted Alan Myers to region 4 Captain. When the position was first announced, only Lt. Eric Anderson (not related to Director Anderson) applied. Crown closed the position and retested, stating he would not award the promotion to Anderson because Anderson had been the only applicant, and Crown wanted the process to be competitive. The irony was that Eric Anderson had been the only applicant for the Lieutenant, when he had applied for and was awarded that position. Upon re-announcement of the captain position, four candidates applied, and Crown awarded it to Alan Myers (a friend of Crown’s who worked in the same office). Myers has a reputation of using poor judgment, and he had absolutely no supervisory experience (other than training new hires). When Alan Meyers was an officer in Clarkston, he created so many problems with the community, the citizens had a public meeting to discuss how to get rid of him. G) Deputy Chief Hobbs, went from a 34-year old F&W officer to Sergeant, to heading up SIU (the statewide investigative unit), to Captain of region 4 to Deputy Chief in approximately 3 years. Once Hobbs was promoted to the head of SIU he was stationed in Olympia, where he remained (never moving his family, even when he was then promoted to the Captain of the Mill Creek office), until he ultimately ended up as one of the two deputy chiefs in Olympia.
3) Top-heavy. Under Director Anderson, enforcement has removed positions from the field, and moved them to headquarters in Olympia. Enforcement now has a chief, has two deputy chiefs (historically only had one), a captain (removed from the field office in region 6), two lieutenants and one sergeant in the office, for 7 total commissioned officers in the headquarters office. They also employ five communications staff members, a radio technician, and nine “administrative support” employees, for a total of 15 non-commissioned enforcement employees in headquarters. In 2000, administrative positions (Lt. and above) made up 5.5% of the commissioned staff. Now, that has risen to 8.7%. Under this administration officers spend ~35% of their work time on “Administrative duties” (including training).
4) Unequal treatment- A well respected sergeant was recently demoted because he had knowledge of one of his subordinates having handled “evidence” (it was actually not evidence, but firearms from a WDFW employee, held for safe-keeping) improperly, yet Chief Crown’s (while he was acting as a WDFW designated Property/Evidence Custodian) own drug evidence from one of his own cases, was lost, and Crown apparently never notified the defense or defendant of such, and there was an effort to classify the missing evidence as “destroyed” by preparing to incinerate the evidence envelope (but the evidence destruction witness refused to sign the destruction form since the envelope did not contain the listed evidence items). Chief Bjork’s “investigation” of Crown’s missing drug evidence amounted to having Crown write a memo (in which Crown said he didn’t even remember the case, nor could he find anything in his officer’s notebook), then Chief Bjork signed off on the evidence as “closed- undetermined”. Recently, the vice-president of the officer’s guild (Dave Jones) was fired, in part, for the same “evidence” situation (improperly handling property for safe-keeping) as the Sgt. was demoted for. The investigation of Officer Jones and Sgt. Phillips was handled by Deputy Chief Hobbs who, when he was in-charge of the detectives, ignored warnings that evidence was being mishandled, by a detective, during the single largest wildlife trafficking case in WDFW’s history (Operation Cody). Once it was determined that the evidence was so badly handled that prosecutors needed to be warned of the evidence issues (Brady exculpatory evidence disclosures were attached to all reports), Hobbs apologized to the involved detectives for not properly supervising the detective in charge of evidence. The very same issue (but to a much lesser degree) is why Sgt. Phillips was demoted, yet no disciplinary actions were taken against Hobbs for failing to supervise the detective who mishandled the Operation Cody evidence, and within months Hobbs was promoted to captain and then (a few months later) to deputy chief.
On 02/14/14 I submitted a Public Disclosure Request to WDFW demanding any and all written documents relating to “Evidence Irregularities and/or Evidence Discrepancies”. On 02/19/14 I received confirmation of receipt of my PDR. On 02/21/14 (two days after WDFW enforcement received my PDR) WDFW Sgt. Dan Chadwick (Deputy Chief Cenci’s neighbor and best friend) entered a pistol into evidence for Deputy Chief Mike Cenci. The report states the pistol was seized in 1992. The narrative of the evidence report reads; “On 02/21/14 at about 1230 hrs., Deputy Chief Mike Cenci was cleaning out his old files in the Long Beach Office. He came across an old handgun with an evidence tag on it dated 10/13/1992. The tag indicated the gun was seized on that date from xxxxxxxxx (unk dob). Violation indicated poss. of a firearm when under 21 yoa. I ran the name in CODY and observed that an xxxxx was cited on the same date by then Wildlife Agent Corky Roberts. Current address lists the defendant in Aberdeen now and the evidence tag had a Hoquim address. I placed the firearm in Evidence locker no. 1 Long Beach.” When this pistol was seized by Dept. of Wildlife Agent Roberts in 1992, the pistol would have been held in the Dept. of Wildlife Montesano office evidence locker, but somehow the gun made it from the WDFW Montesano (where Cenci later was stationed as a sergeant) evidence storage to Cenci’s “old files in the Long Beach Office”. It certainly appears that for some reason Cenci retained a seized pistol, (which he had no role in, as he worked for a totally separate agency (Fisheries) at the time) for an extended period of time, then just “found it” while cleaning his office, two days after receiving my PDR regarding “evidence irregularities and/or discrepancies”, yet they demoted a Sgt. and terminated an officer for not properly logging in firearms held for safe-keeping.
Cenci has received at least four written reprimands, including one suspension without pay (for 2-days). The only reprimands, to Cenci, I received through PDRs are for: 2007- losing night vision equipment and a digital camera ($2,000+ of equipment), 2006- vehicle accident/speeding ($11,000+ damage), 2005- profanity directed at a citizen, 2005- vehicle accident/speeding (total loss of patrol vehicle). Out of Cenci’s 8 known vehicle and vessel accidents (just since 1998), he has only been reprimanded for 2 of the accidents. Despite Cenci’s less than stellar record, he has been promoted to Captain, and twice promoted to Deputy Chief.
While Chief Crown was the training/recruiting Lieutenant, he put into place a policy which disallowed officers from being FTOs (Field Training Officers- officers who train the new hires) if those officers had a founded disciplinary actions against them, yet despite Cenci’s personnel record, Crown immediately re-promoted Cenci into a deputy chief position.
In 2010, WDFW Officer Brian Alexander charged a suspect and the suspect’s wife for hunting without a license, exceeding the limit, wastage involving several elk in Ocosta. Alexander placed the bull elk antlers into evidence (in the Montesano impound yard). In preparing for the WDFW antler sale (http://wdfw.wa.gov/news/may2412a), Lt. O'hagen gathered up antlers, including the antlers seized in the above criminal case and brought them to Olympia where they were later sold. Lt. O’Hagen photographed all the antlers he took, and claimed there were no evidence tags on the antlers he sold. When O’Hagen gave Officer Alexander a picture of the rounded up antlers, Alexander could clearly see evidence tags on some of the racks. During an evidence audit by Lt. Dennis Nicks, it was found that the Ocosta case antlers were missing. In searching for the missing evidence, Alexander found the missing evidence antlers in the photo that O'hagen took of the sold antlers. The loss of evidence was reported to the prosecutor, since the case was still open. Captain Dan Brinson was assigned to do an investigation into the missing antlers. Lt. Nicks also reported the incident to Chief Bjork in the evidence audit, but Lt. O'hagen was never disciplined for misconduct.
5) WDFW enforcement program values fish and shellfish above wildlife. A) Deputy Chief Cenci has, several times, stated “Nobody gives a [Bleeeeep!] about deer and elk. If they are so important, then why do we give out kill permits for them?” When confronted with this statement, he will likely respond with “I have made more deer and elk cases than most officers” or “those statements were taken out of context”, but it’s difficult to understand in what context a deputy chief of fish and wildlife enforcement would feel that statement is appropriate. B) The statewide investigative unit (Detectives) has spent a disproportionate amount of time, effort and money on shellfish (primarily geoduck), yet makes very few actual geoduck cases. C) Director Anderson came from a fisheries background (Pacific Fisheries Management Council, charter captain), as did Cenci (who came from Dept. of Fisheries).
6) I have three different sworn and signed statements, from officers who spoke directly with Officer Apple and/or read Apple’s original report to support the following (even though the documentation I presently have does not include the original report referred to in this section): WDFW Officer Mike Apple recently made a strong criminal case of illegal trapping of otter on Vashon Island, including surveillance video of the suspect with the illegal traps, but Captain Alan Meyers apparently instructed Apple to not file charges (likely because of fear of potential political fallout). On 04/30/14 I submitted a PDR for the case report (report # 14-001121). According to officers who spoke directly with Officer Apple; a couple of days after the PDR was filed, Captain Myers reportedly ordered Officer Apple to change his case report so that it would not show that Myers had instructed Apple to resolve the serious wildlife violation with a verbal warning. Apple refused to change the report. On 05/06/14 I received the PDR response including case report 14-001121, which had apparently been altered and no longer made reference to Captain Myers telling Apple to resolve the crime with a warning. Officer Apple stated he did not make the changes to the report, yet the report was changed. Someone from WDFW changed Officer Apple’s report, then WDFW sent me the PDR response which worked more favorably for the administration. If WDFW employees altered an official police report, then purposely sent me an altered inaccurate response to my PDR, those actions would likely constitute a crime.
7) Disclosure of confidential information to the media by WDFW administrators- On Sept. 18th 2012, DC Cenci was on television and internet telling the world (at 11:15 am) about an undercover WDFW case (Operation Cody) and the warrants which would be served across the state that same date. Many warrants were scheduled to be served later that same day (as late as 7pm), yet Cenci warned the state (by way of the media) about the warrants; thus jeopardizing the case evidence as well as his own officer’s safety; http://www.king5.com/news/local/Raids-target-alleged-wildlife-poachers-170212656.html The above-listed release of confidential information was certainly not the only incident of such Cenci has made, but perhaps the most egregious in that it also violated a written contract (Cooperative Agreement) between the US Fish and Wildlife Service and WDFW. On 06/29/11, WDFW Chief Bjork and USFWS Special Agent in Charge (Paul Chang) signed a case specific contract/agreement for Operation Cody. Section IV I states; “All press releases associated with this investigation shall be reviewed and approved by the Special Agent in Charge of Region 1 and Chief of WDFW and will be released only upon mutual agreement of both. All press releases will be coordinated with the appropriate State District Attorney and US Attorney’s Office.” No such approval was made for Cenci’s new releases, nor were the US Attorney’s Office or the USFWS even contacted about such. After the initial news release, regarding Operation Cody, Cenci conducted other media releases (also without clearing the releases with the US Attorney or the USFWS), including a radio interview in-which he describes a portion of Operation Cody which was a federal investigation of paddlefish caviar (strictly a federal crime), and untruthfully described the suspects as engaged in international smuggling (there was no indication the caviar had entered international markets); http://kuow.org/post/back-alley-caviar . Apparently Cenci either spoke about the case without bothering to check his facts, or he embellished the truth because “international smuggling” sounded better than the truth.
In response to a PDR I submitted (asking for the internal investigative report of Crown’s missing drug evidence) WDFW provided a suspect’s complete confidential criminal history, including his conviction records. WDFW redacted the suspect’s social security number, but left all remaining information in-place, including his name and date of birth (WDFW actually did this on two of the PDR returns). This is a violation of RCW 10.97 (Washington State Criminal Records Privacy Act) punishable by a criminal misdemeanor and potential loss of criminal history access.
8) Quoted from retired WDFW Sgt. Matt Nixon- “I heard him (Cenci) direct HQ staff to change timesheet coding to reflect the spending of federal grant money in ways it were not worked. I heard him direct investigators to find crimes committed by tribal members to embarrass the tribes publicly. I believe a forensic audit of the program's use of federal monies would show vast abuse of overtime and misdirected funds.”
9) Under Bjork and Cenci’s administration, F&W Officer changed to “F&W Police Officer”. The change was more than just a change of title, as WDFW Officers are now praised for law enforcement work which has nothing to do with WDFW’s mandate to “To preserve, protect and perpetuate fish, wildlife and ecosystems while providing sustainable fish and wildlife recreational and commercial opportunities”. While most officers did not object to the title change, they have found they are now spending far less time doing what the general public expects of them; catching poachers, and more time seeking out violations of “general authority” crimes. WDFW “Police” are now rewarded for working duties outside of F&W violations; officers are also being praised for spending huge amounts of time on marijuana eradication, traffic violations, check fraud, metal theft, etc., all the while spending less time working fish and wildlife crimes.
10) Many officers and Sergeants are retiring early, to escape the abuse and mismanagement.
11) WDFW Officer Dave Jones, as the F&W Officer Guild vice-president, pushed for Director Phil Anderson to conduct an investigation into multiple allegations of wrong-doing by Deputy Chief Cenci. For months, Director Anderson refused to investigate and when Anderson finally conducted an “investigation” it was incomplete and biased. Months after Jones pushed through an investigation of Cenci, Jones was fired.
12) Loss of officers in the field- WDFW continues to shift officers from the field to administrative positions. In 1997 WDFW had ~122 F&W officers in the field. Currently WDFW has ~96 officers in the field, a reduction of over 23%, despite the fact the legislature has funded “additional F&W officer positions”.
13) Cenci interjecting himself into WDFW investigations- Due to his love of cameras and the media (as well as the money he receives from unnecessary travel expenses) Cenci frequently interjects himself into WDFW investigations, at the take-down stage. Multiple times a year Cenci interjects himself into WDFW high profile investigations or patrols, normally at the culmination of the cases. He does so without always bothering to attend briefings and reading all the applicable reports, but rather shows up and takes over, normally taking the lead role in the interview/interrogations of key suspects, then stands before the media to brag about WDFW’s success. In no other large law enforcement agency, does the deputy chief interject himself or herself in such a manner, as doing so is unnecessary and can jeopardize the success of the operation (i.e.- interrogation of key suspects without full knowledge of the case, can lead to missed opportunities for full confessions). Also; such behavior costs the state unnecessary travel expenses.
Cenci also misleads younger officers into inappropriate behaviors. One such example seemed to have occurred in the San Juan Islands, in November of 2013, when Cenci came all the way from Olympia to lead a routine deer decoy patrol on Lopez Island. It is our understanding that under Cenci’s supervision the decoy deer team (consisting of Officer Rosenberger, Officer Stout, and Cenci) trespassed and placed a decoy deer on the private property, in hopes of enticing suspects into unlawfully shooting the decoy deer, but the landowner caught the officers trespassing on his property (this information has not yet been verified, due to those involved being totally supportive of Cenci (all marine officers)).
14) Reckless driving- Cenci has a well-earned reputation for reckless driving. Cenci has reported at least 5 vehicle accidents, in state owned vehicles, since 2000 and an additional one in 1998 (it is unknown if there are additional unreported accidents). Cenci has also been involved in at least 2 boating accidents/incidents, and has been stopped for speeding. In several of Cenci’s vehicle accidents, he admitted to speeding and/or reckless driving. These accidents have cost the state 10’s of thousands of dollars, but fortunately have not yet hurt or killed any citizens. Cenci’s accident record is rather impressive considering he spends the majority of his time behind a desk.
15) Promotions- Several promotions were custom made for specific officers- examples: Chris Clementson (a personal friend of now retired Captain Volz’s). Captain Volz crafted the Detective job announcement to Clementson’s background and geographical location, told SIU detectives he was going to make Clementson the next detective, and reduced minimum qualifications (as Clementson came nowhere near the existing minimum qualifications), then announced (at a retirement luncheon with the chief and deputy chief present) that Clementson would be the next detective, before the position announcement even came out.
Deputy Chief Cenci “self-demoted” to captain when Chief Bjork retired, but weeks later when Steve Crown was appointed the chief, Crown gave Cenci a deputy chief position back without even announcing the position, or interviewing for it. Crown also created a second deputy chief position, which he held interviews for. Several years ago, Charles “Alan” Myers (now Captain Myers) said this about the promotional process in WDFW (under Cenci and Bjork’s leadership): “Charles Myers wrote: I had some experience recently in interviewing for a detective position this past summer. I interviewed for the position that was filled by Brad Rhoden. Anyone planning on applying for the position needs to know some things right up front. For example, If you are not networked in with anyone from SIU, especially Ed Volz do not bother applying. Until and unless someone from SIU is your children's god-parent, or something else just as intimate, it will be a waste of time. Also, get a heads up on the interview questions. They ask you questions that demand that you have extensive commercial investigation experience and knowledge. Also, check and see who was already pre-ordained to fill the spot. This is relatively easy information to find out. It seems that most know ahead of time who is more apt to be given the golden pass. If it's not you, then don't bother, unless you're just a sucker like me who was looking for a soul crushing, ego stomping experience to have. But, don't cry for me Argentina. I should have done more to prepare myself. Like move to the west side and become marine officer for one. That definitely would have helped.” Shortly after writing this email, Officer Myers took an undesirable office job in Olympia which allowed him to gain access to the administrative inner circle. He then was quickly promoted up the ladder to Captain.
16) Investigation of Deputy Chief Cenci- When guild representative (Officer Dave Jones) was investigated for an allegation of inappropriate behavior, the investigation was handed to WSP and the Whatcom County Sheriff’s Office. When WDFW finally investigated Deputy Chief Cenci, a private attorney was hired by WDFW to conduct the “investigation”; many witnesses were not contacted, and the report was badly skewed and incomplete.
17) Wasting money by retaining unused vessels- One large patrol vessel (vessel #1- protected by Cenci) is believed to have zero hours from November 2010 through June 2011, but the moorage bill for that vessel is over $380 per month for it to just sit there. That is well over $3,000 in moorage costs alone (not including power and maintenance), over 8 months for an unused vessel.
18) Petition- In late March 2014, retired WDFW Detective Todd Vandivert started a petition to remove Director Anderson, Chief Crown and Deputy Chief Cenci (this was at least the second petition to remove Cenci, as the citizens of his own county had one going in 2006). Vandivert obtained well over 1,000 signatures in the first week! Many present and past WDFW employees signed the petition.
19) WDFW employees have been harassed by WDFW administration for supporting the petition to remove the administration, including a WDFW office worker who was brought to tears by administrators (including Captain Myers) for “liking” the petition on her personal Facebook page; in what seems to be a clear violation of freedom of speech.
20) Many WDFW employees voiced support for the petition to remove administrators, but would not sign it due to a valid fear of retaliation.
21) WDFW Officers have been ordered to not have any contact with myself or Officer Dave Jones, as we are both known to be involved in investigating wrongdoing by WDFW enforcement personnel.
22) Almost all of the marine officers support the administration, and very few land officers support them, which shows clear favoritism towards marine issues and programs.
In an 04/12/13 letter to Director Anderson, the F&W Officers’ Guild attorneys stated “Upon review of this investigation, it appears that the following allegations against Cenci are SUSTAINED by the investigator, or SUPPORTED by the investigative report” (Director Anderson was made aware of the investigative report findings on March 12th 2013): 23) Cenci failed to file a WDFW boating accident report for a boating accident he had at Seafair. 24) Cenci engaged in sexual intercourse, with a dept. employee, while at work. 25) Cenci called a female officer a “bitch”. 26) Cenci commented, in a restaurant, about a waitress’ breasts. 27) Cenci called officers (including a female officer) “cowards” and “pussies” for not jumping into the water to find a missing boater, and failed to listen to their explanation of why they did not do so. 28) Cenci has, on different occasions, told officers “you don’t know @#$#” 29) Cenci made a comment, in reference to a Sgt., that he was “going to kick his ass”. 30) Cenci has stated, several times when discussing work priorities, “Nobody gives a [Bleeeeep!] about deer and elk” and “if it doesn’t have fins, it doesn’t mean [Bleeeeep!]”. In Director Anderson’s response letter to the F&W Officers Guild (regarding the Cenci “investigation”), Anderson ended his letter by stating; “From the Department’s perspective this concludes the matters associated with the allegations of unethical and unlawful actions on the part of either Chief Bruce Bjork or Deputy Chief Mike Cenci. It is regrettable that these two outstanding and dedicated employees were subjected to these type of unwarranted allegations.” As you digest and process the above-listed information, keep in mind that WDFW just demoted an outstanding sergeant (Rich Phillips) and terminated a dedicated K-9 officer (Dave Jones). The sergeant was demoted for failure to supervise Officer Jones (because the Sgt. had knowledge that Officer Jones had allegedly not properly handled “safe-keeping property”). Officer Dave Jones (the officer who initiated the investigation of Deputy Chief Cenci) was terminated, in part, for not properly handling property held for safe keeping. Yet Chief Crown mishandled drug evidence, Deputy Chief Cenci “found” a pistol in his files, which had been missing for 22 years, and Deputy Chief Hobbs (who conducted the investigations of Sgt. Phillips and Officer Jones) had himself failed to supervise one of his subordinates resulting in severe evidence issues in a major case. We don’t think we need to point out the hypocrisy of the WDFW administration terminating/demoting employees for the same, more serious, acts they have committed themselves. What saddens me the most it that for 25+ years, when any young college student would ask me what it’s like to be a Fish and Wildlife Officer in Washington, I always answered; “It’s the best job on earth”. Now, I (like many others) tell them to look elsewhere. We sincerely thank all of you for your attention to these serious issues, and I will avail myself to questions, comments or requests for supporting documentation.
The prior post is self explanatory but if one ever wanted a break out of how & what the turmoil in WDF&W Enforcement has been this should take care of that problem in short order. This is relevant to the current mess in Grays Harbor and Willapa as the lack of honesty and conservation ethics exhibited by District 17 ( GH & Willapa ) staff will not change until we have a different Director. The current WDF&W Director is 100% old school and those who hope for some form of enlightened management are going to have to wait until there is a change at the top.
WDFW Enforcement went through a pretty extensive and expensive certification program a while back. If memory serves, they are one of the few LE agencies in WA that achieved that. Might be better to forward the information to them rather than the Press because the certifiers can actually take a public/professional action if warranted.
CM - Are you referring to CALEA (Commission on Accreditation for law enforcement agencies) accreditation the WDFW enforcement received a decade or so ago?
That accreditation meant that the agency had met some pretty serious communication and training standards. If only part of the claims in that letter are true it is obvious that meeting those standards was largely a expensive "paper" exercise. Though at the time the enforcement leadership made a big deal of getting that accreditation.
While I don't recall what the cost was to go through that accreditation process I do recall that in a time of tight budgets it was pretty controversial at the time when the agency did it. Again as I recall most of the national fish and wild agencies as well as most Washington County Sherriff departments have not gone through that process and some folks wondered whether that money would have been better spend on keeping agents in the field.
WOW! Saw that you posted this to piscatorial pursuits, but man this needs to get out to newspaper editorials, King 5 and Komo 4 news outlets, and iFish and Gamefishin websites. I don't have accounts on those sites...but man. This is coming from the ONLY 2 time OFFICER OF THE YEAR for WDFW, so you have to immediately give the guy some amount of credibility. Getting the word out right now is crucial, as it seems like a lot of issues that lay at director anderson's feet are finally coming home to roost, as you can only sweep so many skeletons in the closet before the door wont shut and they all spill out. I can't say enough thanks to Mr. Todd Vandivert and his years of service, and continued service in retirement. He should be given an honory award for this investigative attempt to clear the agency of such wrongdoings. I am contacting my state reps to make sure they recieve a copy of this letter and do something about it.
This came in my e mail so I thought I would post it. Not for our reading benefit but for the gentleman that wrote the letter to the Commission that I posted previously. One never knows about letters that harsh but it seemed authentic and had the proper bells and whistles. What I did not know was the fact that this is coming from the ONLY 2 time OFFICER OF THE YEAR for WDFW. The loyalty the former employees have is often difficult to grasp but I think if this gentlemen is who the e mailer says he is then I am going with someone who is fighting FOR the agencies credibility which under Mr. Anderson has reached the level of about ZERO / to NONE!
I question many things I see on the net, so contacted a good friend of mine that is also retired WDFW enforcement.
He knows this writer well & says that the writer is meticulus enough that he would never write anything that he can not back up. He says the writer only sees things in black & white, with no gray areas. And if you buy the book, you will not be able to put it down.
Now this is a beauty!!!! This is a attorney for the Willapa Gillnetters trying to intimidate WDF&W with findings from a bio they hired. Now the consultants report is 13 pages long so I will put it up in two or three parts later. That said this is interesting reading as ........................ oh hell I do not know but trying to intimidate a government agency is not such a good idea!!!!!!!! I did not fix the formatting as this is exactly as received but converted from a PDF to Word.
Washington Department of Fish and Wildlife Attn: Joanna Eide, WDFW Rules Coordinator 600 Capitol Way N. Olympia, WA 98501-1091 rules.coordinator@dfw. wagov
RE: Comments to CR'102 WAC 220-40-021- Willapa Bay salmon summer fishery WAC 220-40-026)- Willapa Bay salmon fall fishery
Dear Ms. Eide:
The undersigned and this law firm represent the Willapa Bay and Gr.ays Ha.rbor Gillnetters Associations ("Associations"). The following are the Associations' comments to CR 102 draft regulations for the Willapa Bay sahnon sununer fishery and Willapa Bay salmon fall fishery promulgated under WAC 220-40-021 and WAC 220-40-027, respectively.
BACKGROUND
In January 2014 the Washington Department of Fish and Wildlife ("WDFW''), Tim Hamilton, Arthur Hohnan, and Ron Schweitzer settled litigation under Thurston County cause nos. 13-2-01741- 2 and 13-202050-2 ("Settlement Agreement"). Attached hereto as Exhibit "A" is a. copy of the Settlement Agreement. The Associations did not have an opportunity to participate in the Settlement Agreement. The Settlement Agreement requires the WDFW to procure consulting services from independent fishery scientists. The scientists and their scope of work were jointly selected by the parties to the Settlement Agreement and the WDFW. The Associations did not have the opportunity to participate in this process.
The WDFW further agreed to use public funds to establish a private non-profit organization. The organization is intended to promote recreational fishing in Willapa Bay and Gray's Harbor. The organization is called the Twin Harbors Fish and Wildlife Advocacy ("Advocacy"). The officers of the Advocacy are Tim Hamilton, Arthur Hohnan, and Ron Schweitzer. Itisunclear how the public funds were used by the Advocacy or its officers. The Associations have never received similar funds.
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The.scientists engaged by the WDFW and the Advocacy convened a panel identified as the Independent Fisheries Science Panel ("IFSP"). On.March 31, 2014, the IFSP produced the Grays Harbor and Willapa Bay Commercial Salmon Fisheries Mortality Rates ("IFSP Report"). The IFSP was requested to address only the following issues:(1) Chinook and chum salmon release mortality rates for Willapa Bay and Grays Harbor with fishermen complying with the regulations; (2) Chinook and chum salmon release mortality rates for Willapa Bay and Grays Harbor in light of actual fishing practices; and (3) identifying compliance problems with fish-friendly tactics. The issues posed to the IFSP also appear to have been created by the Advocacy. The Associations again did not have the opportunity to participate in the IFSP's formulation of its scope of work and they did not receive any meaningful opportunity to comment on the IFSP's draft report.
On May 21, 2014, the WDFW issued CR-102 filed as WSR 14-11-105 for the 2014 North of Falcon commercial salmori rules for Willapa Bay. On June 23, 2014, Ian Courter of Mount Hood .Environmental prepared a Teehnical Memorandl.}!Il which consists of a Review of the IFSP Recommendations and the 2014 Proposed Rules for Willapa Bay Commercial Salmon Fishing. Attached hereto as Exhibit "B'' is a copy of the Technical Memorandum. Mr. Courter observes that release mortality rates for naturally spawning chinook are one of the most significant factors impacting the 2014 commercial gillnet season. (Technical Memorandum, p. 3). Regarding the mortality rates,Mr. Courter finds that "[i]t appearsthat the WDFW used the IFSP Report exclusively to arrive at these figures." (Technical Memorandum, p. 3). As a result, the WDFW's Willapa Bay rule-making process for 2014 suffers from the e flaws as the IFSP Report discussed in the Technical Memorandum.
ANALYSIS
The statutory mandate for the WDFW state5 as follows:
The department shall conserve the wildlife and food fish, game fish, and shellfish resources in a manner that does not impair th resource. Ina manner consistent with this goal, the department shall seek to maintain the economic well-being and stability of the fishing industry in the state. The department shall promote orderly fisheries and shall enhance and improve recreational and commercial fishing inthis state.
The commission may authorize the taking of wildlife, food fish, game fish, and shellfish only at times orplaces, or inmanners or quantities, as inthejudgment of the commission does not impair the supply of these resources.
RCW 77.04;012. To further these broad objectives, the Legislature directed that "[t]he commission acts in an open and deliberative process that encourages public involvement and increases public confidence in department decision making." RCW 77.04.013.
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These objectives grant the WDFW regulatory authority to manage fish within the waters of this state for purposes of conservation. Purse Seine Vessel Owners Ass'n v. State, 92 Wn. App.381, 391, 966 P.2d 928 (1998);see also Northwest Gillnetters Ass'n v.Sandison, 95 Wn.2d 638, 641, 628 P.2d 800 (1981). In order to manage a fishery for conservation, WDFW is permitted to do the following:
[i]t •enables the agency to collect data regarding the size, plaeement, and harvest of runs, to regulate the type of gear and times at which it can be employed in fishing specific varieties and runs •of fish, to discriminate among classes of users by gear and purpose, to artificially enhance the fishery through hatchery programs, and even to force the owners of existing dams to improve fish passage facilities.
The grant of broad discretion to an agency includes the corresponding obligation to take actions that are not arbitrary and capricious under the Administrative Procedure Act ("APA"). RCW 34.05.570(2)(c). Arbitrary aild capricious is defined as follows:
Arbitrary and capricious action has been defined as willful and unreasoning action, without consideration and in disregard of facts and circwnstances. Where there is room for two opinions, action is not arbitrary and capricious even though one may believe an erroneous conclusion has been reached.
Pierce County Sheriff v. Civil Service Com'n of Pierce Cowtty, 98 Wn.2d 690, 695, 658 P.2d 648 (1983) (quoting State v.Rowe, 93 Wn.2d 277, 284, 609 P.2d 1348 (1980).
Based on the above analysis and the Technical Memorandum, the WDFW has failed to discharge its statutory mandate and acted in an arbitrary and capricious manner.
A. The WDFW violated its statutory mandate and the APA by failing to treat the Advocacy and the Associations equally in the IFSP process without adequate justification .
The statute states:
The department shall conserve the wildlife and food fish, game fish, and shellfish resources in a manner that does not impair the resource. Ina manner oonsistent with this goal, the department shall seek to maintain the economic well..being and stability of the fishing industry in the state. The department shallpromote orderly fisheries and shall enhance and improve recreational and commercial fishing in this state.
RCW 77.()4.012. In accord with this statute, the WDFW •must balance both commercial and _recreational interests. Puget Sound Crab Ass'n v. State, 174 Wn. App. 572, 581-582, 300 P.3d 448
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(2013). The WDFW must also treat both the commercial and recreational industries equally. Id. at 584. The WDFW may onlytreat the groups differently if it has an adequate explanation on the record. The failure to treat two similarly situated groups equally without adequate explanation is arbitrary under the AP. Petroleum Communications. Inc. v. F.C.C., 22 F.3d 1164, 1172 (D.C. Cir. 1994); Muwekma Ohlone Tribe v. Kempthorne, 452 F.Supp.2d 105, 115 (2006).
• The commercial industry and recreational industry were not treated equally here and the WDFW lacks any justification for such disparate treatment during its rule-making process. Rather, the Settlement Agreement and the IFSP process, at the expense of public funds, provided the Advocacy access to agency rul(}-making to the exclusion of the Associations. Such an exclusive practice reSulted in disparate treatment of two similarly situated groups - the Advocacy and• the Associations. Disparate treatment violates the WDFW's mandate and it violates the APA because there is no basis to treat the groups differently during a process intended to encourage public involvement. The WDFW has not only failed to encourage the Associations' involvement inthe IFSP process, it excluded the Association8 by agreemen with the Advocacy. Accordingly, the WDFW caruiot adopt the IFSP's conclusions without adequate justification for treating the Advocacy and Associations differently during the IFSP process. The IFSP Report must be excluded from the WDFW rule- making process on this basis alone. •
B. The application of a 10% actual practices adjustment to naturally spawning release mortality rates is arbitrary and capricious because it is not supported by any reliable data and it is contrary to the on-board observer data collected by the WDFW.
The IFSP concludes that release mortality rates will be higher in actual practice due to the failure of the commercial fleet to comply with fish friendly tactics. To support this conclusion, the IFSP relied upon unqualified lay opinion testimony and video presented at workshops. This evidence lacks any credibility and is directly contrary to the WDFW on-boat observer data collected during the gillnet seasons.
Further, Mr. Courter finds that the application of a noncompliance rate is subjective, lacks empirical .evidence, and is duplicative of factors already included in the FRAM model. (Technical Memorandum, p. 6). The WDFW's decision to apply the IFSP's 10% adjustment renders the WDFW's action similarly subjective, duplicative, and arbitrary.
To consider information that lacks any indicia of reliability or credibility which is contrary to actual data in the WDFW's possession disregards the facts and circumstances available to the IFSP, it lacks any rational support, and it duplicates a factor Blready included in the model. A final rulethat relies solely upon the IFSP Report and disregards the attending facts and circumstances is arbitrary and capricious Puget Sound Harvesters Ass'n v. Washington State Dept.. of Fish and Wildlife, 157 Wn.App.935, 945, 239 P.3d 1140 (2010). Accordingly the non-compliance rate adjustment must be removed and the mortality rates adjusted accordingly.,
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C. There is no data_ to su1mort a drop-out mortality rates of 3% for commercial fisheries.
Based on the information available from WDFW, there isno empirical data.to support a drop out rate for Willapa Bay commercial gillnetters. It apPears, based upon the _available infoation from the WDFW, that the WDFW and tribal co-managers have agreed upon these rates, but the WDFW has no data to support the conclusion that such rates pccur in actual practices. Mr. Courter finds that the drop-out rates arenot based on objective data and redundant. (Technical Memorandwn, p. 7). Accordingly, the drop-out rates must be removed and the mortality rates adjusted accordingly.
D. The application of spring Chinook test fishery data from the Colwnbia River must be adjusted to reflect the time frame and migration distance expected inWillapa Bay and Grays Harbor.
Tl1e IFSP report finds that data from Ashbrook et al. (2004) does not need to be altered because mortality of spring Chinook in the Colwnbia River did not differ substantially between trea1ment and control fish upstream ofthe McNary Dam. Grays Harbor and the Willapa Bay fall runs are materially different than the Colwnbia River spring run. The Columbia River fishery has significantly lower long-term survival rates and higher corresponding mortality rates because of the presence of hydroelectric dams, the significant distance traveled by returning fish before reaching spawning grounds, and the significant time in fresh water before spawning.
Mr. Courter also disagrees with the IFSP' s :findings because there is affirmative data to dispute the IFSP'sunsupported conclusions. The IFSP Report appears to concede that it made an affirmative conclusion based upon a perceived lack of evidence. An affirmative conclusion based upon the lack of evidence here is inappropriate because of the material differences between the fishenes. Mr. Courter sites VanderHaegen, G.E.et al (2004) and Ashbrook et al. (2009) forthe conclusion that there are significant capture-related mortality occurring upstream of McNary Dam on the Colwnbia River. (Technical Mernorandwn, p. 8-9). Therefore, distance of travel distinguishes the Columbia River spring runs and Willapa Bay fall runs.
Moreover, the U.S. v. Oregon Technical Advisory Committee ("TAC") reached a similar conclusion to Mr. Courter by applyiri.g a 4()0/o long term release mortality rate •to Columbia River Chinook based on "study design biases" inAshbrook et al. (2004). (Technical Memorandwn, p. 9). The IFSP's analysis is clearly inconsistent with the Technical Memorandum and the TAC despite reviewing the exact same data.
The IFSP and subsequently the WDFW are disregarding the attending facts and circwnstances available to adequately inform the 2014 rule-making process. A final rule based solely upon the IFSP Report that disregards the actual facts and circumstances is arbitrary and capricious. Puget Sound Harvesters Ass'n v. Washington State Dept. of Fish and Wildlife, 157 Wn. App. 935, 945, 239 P.3d 1140 (2010). .
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The WDFW must develop a scalar to adjust the mortality rates accordingto actual Willapa Bay conditions and the study • design biases observed in Ashbrook et al (2004). . (Technical Memorandwn; p. 13). Without adequate adjustment, the WDFW's rule .disregards the weight of available scientific evidence on this issue.
E. The imposition of tangle nets on Willapa Bay fails to consider the economic impact on the commercial industry.
The WDFW's statutory mandate requires it to consider the economic burden ofits regulations on the fishing industry. Puget Sound Crab Ass'n v. . State, 174 Wn. App. 572, 581-582, 300 P.3d 448 (2013). The imposition of tangle nets on Willapa Bay, only a few months before the season commences, fails to.account for the economic impact of such a change on the commercial industry. Itis impossibleto purchase atangle net in time forthe2014 summer and fall Willapa Bay commercial salmon season. Manufacturers are not capable of filling orders for tangle nets in the allowed time frame. As a result, the economic burden will be significant as the commercial industry will not be permitted to fish as a result of this change in equipment. e Associations request the WDFW to delay the imposition of tangle nets in order to provide the Associations a commercially reasonable time to acquire the new gear.
CONCLUSION
The Associations request that the WDFW disregard the IFSP's Report. The Associations request that naturally spawning chinook mortality rates be adjusted according to the Technical Memorandum 's recommendations. The Associations request that the WDFW promulgate a regulation for the 2014 commercial gillnet season in Willapa Bay that complies with RCW 77.04 and RCW 34.05.
Sincerely,
.GOOwffi
cc: Clients Mike Grossman, Washington Attorney General's Office
We are still working on Public Document Request and here comes this gem. Key is to read bottom up as it is the Director starting the thread. Now let us say this right now absolutely ZERO misconduct is present here. It is appropriate for any citizen to contact their elected representative and request assistance but I think this takes Rep. Blake out of the even handed approach column. You choose!!!!
From: Thiesfeld, Steven L (DFW) Sent: Sunday, March 23, 2014 2:38 PM To: Anderson, Philip M (DFW) Cc: Warren, Ron R (DFW); Scott, James B (DFW) Subject: RE: willapa/Blake
Attached are the other 2 items we handed out. DraftResponse is the preliminary recommendation from the Independent Fishery Scientist Panel on gillnet release mortality rates for Chinook. The other two are the Chinook and Coho FRAM mortality rates used by state/tribal/PFMC modelers. Net drop out would be represented by “Other Mortality”.
Concerns expressed by the commercial industry that I noted (it may not be all of them):
1. The drop out rate used was not based on a study of commercial fisheries in Willapa Bay and their fisheries are now very different than other areas such as Puget Sound. Differences such as soak time need to be considered.
2. The IFSP was not an independent committee. They specifically cited that one member fishes with Jim Martin often and Martin’s son is married to Liz Hamilton or her daughter.
3. They want money from the agency to conduct an independent review of hooking mortality.
4. With regard to the 20% limitation: they told us the Naselle couldn’t support the goal when the management plan was drafted; none of the Chinook in Willapa are wild anymore; NFMS has said they wouldn’t list Willapa Chinook under ESA; and we need to go back to managing only for hatchery fish.
5. If part of the bay is closed to commercial, it needs to be closed to recreational also.
Please let me know if there are other items you need prior to Tuesday morning.
From: Anderson, Philip M (DFW) Sent: Saturday, March 22, 2014 8:01 PM To: Thiesfeld, Steven L (DFW); Warren, Ron R (DFW); Scott, James B (DFW) Subject: willapa/Blake
All:
Got a message from Brain today. He said his phoning was ringing off the hook about Willapa, I assume that was generated from the meeting Friday night. He requested a breakfast meeting with me soon. If you happen to see this e-mail and have an electronic copy of any hand-outs that were used Friday night or the three pieces we referenced on Friday that you could send to me, that would be great. thanks, Phil
The Willapa Commercials Consultant report was a bit large and simply did not take to C&P as the formatting really took a hike! So here are his recommendations such as they are but keep in mind he was hired by a user group to develop a supporting document for the Willapa Gillnettters and NOT as the IFSP that the Commercials ( and District 17 staff ) hate. The IFSP were hired by Jim Scott ( AD Fish Program ) charged with working INDEPENDENTLY to develop mortality rates in fisheries for Grays Harbor and Willapa. Rec hooking mortality went up as did the commercial release mortality but the Gillnetters who have never been held accountable ( particulary by District 17 staff WHO WERE SUPPOSED TO BE MONITORING COMMERCIAL FISHINGS ) and it appears the guys are having problems with the concept that " it ain't OK to cook the books"!
Quote:
The Department should provide the commercial fishing fleet with information pertaining to the need/justification for a 4% increase in the recreat ional fishing harvest allocation.
This is my personal favorite. The Commercial Fleet take over 85% of the harvest in Willapa and this guy wants justification for the 15% or less the Recs get? " You got to be kidding me" is about the nicest way to respond to that with "Your shi--- me" closing in for the lead.
So here you are:
Recommendation Summary
list of primary recommendations in order of priority:
l) The Department should not use the IFSP to address noncompliance with regulations, and the noncompliance rate adjustment should be removed because it has no empirical basis. Moreover, a subjective noncompliance rate has already been applied to FRAM harvest rate estimates and inclusion of the same rate in the planning model would be redundant.
2) The Department should remove drop-out/off mortality rates from the Willapa Bay planning model because they have no empirical basis and subjective rates have already been incorporated into FRAM harvest rate estimates. WDFW should also develop a study plan to inform true estimates of drop-out and drop-off mortality.
3) The assumed post-release mortality rate for large and small mesh sizes should not exceed the rate agreed to by the TAC (40%) to account for bias in study results reported in Ashbrook et al. (2004). Furthermore, The number of factors affecting prespawning mortality increases with migration distance and time; therefore, additional reductions in assumed non-retention mortality must be made to account for life-history differences between spring and fall Chinook salmon.
4) WDFW should provide a clear explanation of the need to reduce the harvest impact on natural origin Naselle River Chinook salmon before finalizing rules for the 2014 commercial season.
5) To facilitate the comment/review process, justification for model structure and inputs should be compiled into a single report rather than relying on reviewers to compile numerous memos, reports, and public meeting synopses.
6) The Department should build upon and/or modify my explanation as needed to develop an accurate reflection of how the proposed fishery differs from previous seasons.
7) The Department should provide hind-cast estimates of the commercial fishery length (days) for the last l0 years under the new management regime proposed for 2014.
8) Efforts should be made to collect species-specific data to improve the accuracy of chum salmon non-retention mortality estimates.
9) The Department should provide the commercial fishing fleet with information pertaining to the need/justification for a 4% increase in the recreat ional fishing harvest allocation.
4. With regard to the 20% limitation: they told us the Naselle could’t support the goal when the management plan was drafted; none of the Chinook in Willa pa are wild anymore; NF MS has said they would’t list Willa pa Chinook under ESAU; and we need to go back to managing only for hatchery fish
after reading the statement that there are no wild Chinook left in the willapa I remembered reading in the vidette that in the 1890's the canneries on Gray's harbor planted "blacks" from the Sacramento river to have an early run king in the Chehalis to can. so does this mean that there are no native early run kings in the chehalis
Link is to SASI and look to North River/ Smith CR. The assertion by the gillnetters and some Rec fishers fearful of managing for a wild native fish, none exist in Willapa is BS. Willapa has issues of a total management failure and it is coming home to roost.
With the mass marking of the Chinook hatchery production through out the Willapa Bay basin I would be very interesting to see what information is available on the mark rate of Chinook carcasses recovered in the North River/Smith Creek (elsewhere in the basin).
Collection of that information should be straight forward; is it available?
If memory serves, Willapa was the poor stepchild for stock assessment. From what I recall, there were years with not much done because of the need to do Grays because of Indian/non-Indian sharing/co-management.
Neither watershed has much for chum surveys; wind up Rivrguy on how those escapements are "estimated".
Not sure Curt but I will look around. The thing folks miss with the gillnetters claim that illegal private hatcheries are the source of the North River Chinook is pretty much delusional and why some in the REC community run around braying that [Bleeeeep!] is something well past hard to understand. The simple fact is that most folks have ZERO idea of survival rates. Unfed or some feed time fry have almost zero survival. Now you can get around that by rearing to about 150 fry to the lb, correct brood, and planting sites that are in ideal habitat but it is almost impossible to get enough eggs of that quality outside the Chehalis Basin.
SaSI was done quite a ways back prior to the implementation of that ridiculous piece of crap management plan R-6 put together under Ron Warren and Kirt Hughes. Also before the use of selective fishing ( which is selective in name only and a farce ) with few observers and the Region 6 staffer charged with the Commercials and never seeing a near death or dead fish come in to the boat in a commercial gillnet that needed to be revived. Willapa salmon harvest management, be it Commercial or Rec, is nearing to point that the local communities could loose a lot of the hatchery production in the near future.
The Chum thing is amazing and I will use Grays Harbor but Willapa is similar but I do not know the details as well. So in Grays Harbor they take three locations on the East Fork Satsop ( near Simpson 1, Cramer's Spawning Channel, and on Decker Creek ) and Stevens Creek on the Hump, add them up and then extrapolate basin wide. First Stevens Creek is the best Chum stream on the Hump and the three reaches of the Satsop are influenced by 300k to 500k of Chum released ( broodstocked parents ) that come back and spawn with the natural origin adults.
Now the purpose of the program was to rebuild the Satsop Chum which has happened but by utilizing spawning numbers heavily influenced by the hatchery Chum it results in a inappropriate break out of the number of harvestable adults resulting a steady destruction of Chum stocks above Satsop in the Chehalis and upper tributaries. The reason is simple in that upper basin Chum do not reproduce at the same rate as lower basin Chum. So they are quite willing to write off and exterminate native Chum stocks from 1/3 of the Chehalis Basin. That simple yet complex. The thing is commercial fisheries, be it tribal or non treaty, once established you play hell getting those things reformed. It usually follows the pattern of they are not there anymore kill em all, they were never there, ( when bounced and shown pictures you usually get " oh before my time" ) or to few remain to worry about and it is a real shame that happened. Oh did I mention that WDF&W WAS in charge then to? I do believe the words used are ZERO accountability with Region 6 District 17 staff past & PRESENT!
My e mail has gone to a reoccurring theme as to questions on the Grays Harbor & Willapa commercial seasons. So no I do not know the final season lay out for either and WDF&W has time with the APA process ( CR 102 to create the WAC ) in GH as it is 60 days after submission with two public comment periods.
That said the current Director and AG ( Attorney General's staff ) assigned to WDF&W have used the CR 103 or Emergency Rule Change to circumvent the APA process before. Yes you can sue them but unless you prove financial dislocation it will finish up legally AFTER the season and why the guides have not used this route is beyond me. Also interesting how WDF&W utilizes this to fend off citizens more or less enraged over being screwed one more time.
So in Grays Harbor they could get to mid August before dropping the Commercial CR 102 as it will be late Oct before time is available under the 3 consecutive net free days. No I do not know how Region 6 gets around the issue that Humptulips Wild Coho have not made escapement for 23 years. It should not effect the in river Rec as it will be C&R on Wild with a low hooking mortality but 2C both Commercial & sport no idea as the numbers are very much in the minus column for escapement before ANY harvest with much higher release mortalities.
It is my understanding that the proposed QIN seasons DO NOT violate any court agreed to escapement goals as they get 50% of the harvestable at the bar. The separation of the Hump and Chehalis is a WDF&W thing that the QIN DID NOT agree to and are NOT bound by. It does create problems for Region 6 in that the Recs can mold around the QIN seasons but NOT so the NT nets. WDF&W really has problems getting away from this Indian vs White Boy thing with commercial fisheries.
In Willapa WDF&W is close to or out of time for the infamous Commercial Dip In fishery in 2T. More commonly know as the screw the REC and Wild Chinook this lovely piece of unholy crap takes place in late July or early August. They have time for the remaining commercial fisheries.
One last item. Through the PDR process ( Public Document Request ) I and others have attempted to gather information. We make it public and when this rolled out in a PDR by the Advocacy I was startled. So let us go back to 2013 when one of our local fishers, well known on PP, yelled about no creel count in the Grays Harbor Bay fishery so off District 17 went AND CLOSED THE BAY SEASON. So now was it retribution or conservation or both? Well the creel census September 18 through September 21 had 589 angler trips with a harvest of 152 Wild Chinook & 27 marked Chinook harvested. In other words FISHING sucked! So why the closure? You choose but there is little doubt that what data District 17 had obtained did NOT show a major over harvest.
after reading the statement that there are no wild Chinook left in the willapa I remembered reading in the vidette that in the 1890's the canneries on Gray's harbor planted "blacks" from the Sacramento river to have an early run king in the Chehalis to can. so does this mean that there are no native early run kings in the chehalis
No not really. The Chehalis has one Chinook run that starts around may and ends in December. Our Chinook run starts with the Springers ( which are not Springers in the normal sense but the front end of the summer component ) followed in July by the primary Summer Chinook coming in through mid September. The last part of the run is mid Sept through the first part of October finishing with the late component latter part of October and November. The December Chinook that went to the E. & W. Folks Satsop, and two tributaries near Elma are pretty much wiped out. The Summers are primarily E. Fork Satsop & Upper Chehalis. Now the Wynoochee did have a true Springer run that Spawned in the gorge ( pre dam ) that WDFW did not recognize and are gone despite local efforts led by GHTU which DW can tell you about as he baby sat the brood.
Now hatchery releases of different numbers and stocks have occurred and some rather substantial. The second Satsop hatchery built was next to Schafer Park and one year they took 5 or 50 million eggs ( typo or ?? as no one knows ) and transferred them to the old Upper Chehalis Hatchery which lost them due to facility failure. Another is when the Hump went to native stock Chinook the entire Hump hatchery run of Chinook was transferred to the East Fork Satsop, reared to yearlings and released.
So in the Chehalis we have a Chinook run that has three distinct run timings as to spawning but the entry through the bay gets muddled. The thing is not many Chinook come in from the salt Nov & Dec but rather enter the bay and stage ( hold ) in the tide water areas in the Chehalis, which is to the South Elma Bridge on the Chehalis. Adults returning to some streams stage pretty hard up to several months, which is why they take a real pounding by commercials fisheries as they have a real habit of hanging out in the tidal zones of the river which is where the commercial fisheries are.
Recently I filed a PDR ( Public Document Request ) regarding communications concerning the Grays Harbor Management Plan Redo. I took this action as I was having difficulty getting frank responses from WDF&W to questions which is not acceptable. Once / twice / thrice I will accept duplicity / evasion / stone walling but after three it is a PDR time. So below is the compilation of public comments unfiltered ( at least by me ) and it will give everyone the wide range of views that citizens have.
I must say though that in this and other documents my favorite was the commercial fisher who identified 77,000 sport fishers should not get a greater allocation of harvest than a few hundred ( in GH about 25 ) commercial fishers. Seems they can not fathom that the tribal catches ARE COMMERCIAL fisheries. This Indian / White Boy thing needs to be put away, once and for all!!
So here you go the Washington citizen comments on Grays Harbor Management. ( condensed by WDF&W )
11 January 2014
Summary of public comment regarding draft Grays Harbor Salmon Management Policy.
Included below are excerpts from written comment received between October 21, 2013 and January 9, 2014, and verbal testimony summarized from the December 7, 2013 Fish and Wildlife Commission meeting. Comments have not been edited for content or to correct spelling, grammar, or punctuation.
Comments were summarized into ten (10) categorizes including: allocation, alternative fishing practices, communication/transparency, conservation, data rigor, economic value, enforcement/accountability, hatcheries, limit effort, and miscellaneous.
Categories are collated by major reason for which the policy is needed (Enhance Conservation Focus, Restore and Maintain Public Trust, and Clarify Sharing of Impacts), followed by a section with remaining categories.
Enhance Conservation Focus
Conservation • The state wants to kill down to the last fish. We need to think about conservation. • Calculated in FRAM down to the last fish the bycatch to the last fish. • complete closures have been implemented before and the fish come back. It that is what it takes fine. It comes down to conservation. We need the fish in the gravel. • ESCAPEMENT GOALS and SALMON CONSERVATION must be the #1 Priority. Once the resource is gone, everyone loses. • Escapement ,We must meet escapement goals each and every year. This is imperative to the survival of the fish that swim and spawn in these waters. Any type or length of fishery should always be secondary. I am well aware that this could mean on lean years that we do not have a directed fishery by anyone and if that is what it takes then so be it. • It was abundantly clear from the vast majority of attendees that consevation of Grays Harbor wild salmon is their highest priority. Several topics were included within the conservation umbrella; opposition to the Chehalis River dam, ocean-derived nutrition, harvest management and more. • The state is driving to ESA. • As for Conservation, everyone needs to do their part. • My big thing is in-season management. I think conservation needs to be the top priority, even if it limits my opportunity to fish ensuring that over-forecasting doesn't have to result in overharvest, and subsequently missed escapements. • This fishery must have season checks and balances to ensure that we do not over harvest on any given year • Guiding Principles Item 14; When a mark-selective fishery occurs, the mark-selective fishery shall be implemented, monitored, and enforced in a manner designed to achieve the anticipated conservation benefits. Everytime the WDFW feels that the selective harvest is expected to impact fishery escapements goals, the fishery is shut down, but it's only shut down to sport fisherman and not tribal/commerical havesting. Escapement goals are not being met, yet we allow the tribal fisheries to run nets 7+ days a week which has a much greater impact on returning salmon than any sportsman catch.
• 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. • concerned about failure of Reg 6 management. Not making escapement. • Continuing to fail for the last 10 years. • Escapement goals are not being met. • for too many years too many fishermen taking too many fish. • Blatant overharvest by the QIN, particularly Chinook. Late coho and steelhead are in a similar state as Chinook. • Millions of dollars have been spent by tax payers and Logging companies to create more habitat yet WDFW has not increased any Escapement Goals, provided more fish to the gravel, increased wild populations, to match the third largest watershed on the Pacific Coast on the United States. I see some great opportunities to increase fish populations in this wild river system that is capable of providing a better future of this resource. • The people of our state have invested a lot in enhancing habitat for salmon yet Region 6 has been content to leave goals low and then seldom meet them. In a region which has been satisfied and enjoyed management job security while missing escapement goals for Gray's Harbor and Willapa Bay 9/10 of the time, a culture change would be needed. • 30 years of experience in the legislative projects. I have worked on habitat recovery and still no fish in Wildcat Creek. • Unfortunately, too little time was provided for indepth discussion regarding policies to achieve wild salmon recovery in Grays Harbor and its tributaries - far too much time was again consumed for allocation discussions • If you are concentrating on the escapement maybe you should start in the ocean fishery. You don’t want to admit to the amount of fish you are allowing to be killed in the “catch ten and release to keep one fishery”. • Article about Alaska Kenai Salmon - "Catch and release practices prevent many salmon from reaching a spawning location or result in poor spawning success." • For the recreational fishery in Grays Harbor I would like you to consider the following: Any year there are not enough chinook to have a retention fishery that area 2.2 from the Chehalis River bridge (highway 101) to the mouth of Johns River (piling number 8) be closed to all fishing before the first of October. This is needed to save chinook salmon from over harvest via hook and release. Large numbers of fishers show up to see how many chinook they can catch in one day even though they release them. One fisher bragged to me they caught 17 chinooks in one day when it was non retention only. • The spring chinook fishery is a joke. The only reason the tribe fishes for spring chinook is to harvest wild steelhead that are returning. This practice need to STOP! • If CTRC is the non-treaty tribes then this draft does not allow a non-treaty spring Chinook fishery in the Chehalis River system. I support no non-treaty tribal fishing for spring Chinook in Grays Harbor and the Chehalis river system. • Another issue I have is why is ANY spring salmon fishery of any kind allowed on the Chehalis River system?
Limit effort • I would like to state for the record that I believe that until you curtail the tribal fishery it will be of little use to keep restricting the non tribal fishers. • One partial solution is to LIMIT GUIDES AND CHARTER OPERATORS TO A SINGLE TRIP PER DAY. It would probably be prudent to have logbooks for guides to get a more accurate reporting of the true catches for salmon, sturgeon, steelhead and walleye. • A quicker and more effective option would be to use a “drawing” similar to elk harvesting wherein a preset number of license holders will be granted the ability to fish in the upcoming season. While the number of fishers active each season would decrease, establishing a drawing avoids seasons where all the participants suffer when sales of fish caught “….didn’t cover the cost of the diesel”. • for too many years too many fishermen taking too many fish.
Alternative fishing practices • We must require sustainable forms of fishing. Currently Recreational fisherman utilize barbless hooks and selective or non-selective fishing as a means of ensuring the right fish are taken at the right times. Entanglement nets are not a sustainable fishing method. • Make everyone even that's commercial fishermen go back to hook and line • Following the example set in harvesting razor clams, crab, and shrimp, we propose that WDFW consider establishing commercial seasons wherein recreational and commercial license holders harvest with the same gear (poles), in the same geographical areas and at the same time throughout the entire season. License fees and bag limits could be adjusted as well. One example would be a commercial license at three times the recreational license and the commercial bag limit at three times the recreational in a corresponding fashion.
Restore and Maintain Public Trust
Communication/ Transparency • The Grays Hbr. Advisory Committee, WDFW Fish biologists, and GH gill net assoc. should be on record as to their method, data and tools used to recommend the catch sharing percentages for each sector outlined in this "draft". I would like to see fishery decisions in Washington State made on biologically sound information. It appears that political influence now dictates many decisions made by WDFW. • The public needs to be informed that the catch allowed by the non-treaty Chehalis Tribe(s) comes out of the recreational sector. If the category designated as CTCR in the charts is the non- treaty Chehalis Tribe(s), it needs to be designated as such in the draft policy. Non-treaty catch quota should not be taken from the recreational sector. How can WDFW give the non-treaty Chehalis Tribe(s) a catch percentage when they provide no catch figures to WDFW? My recommendation is "no catch figures", "no fishing". • The Director and the Region need to bring co-management back to Grays Harbor. • We need to talk about the QIN. They overharvest year after year. Then tell the state what they are going to do without any say from the state. WDFW needs to take them to court. • There is no co-management in Grays Harbor. If the state is not fishing then the tribe will. • WDFW needs to include previous run estimates, escapement goals and final catch statistics for each sector to determine an equitable catch percentage. The percentages "proposed in the draft" , for each sector have no meaning without inclusion of above mentioned data from previous years. The percentages outlined in the draft are meaningless w/o previous data. • Overall the GH management plan is too vague and unclear. It is good to see a committment for an annual review but there is little mention of metrics against which performance would be measured by the commission. This is a region that has regularly underperformed on escapement goals for multiple species for over a decade. • The current draft does not have specificity. What we are looking for in the policy are deadlines and goals. • These guidelines are only a tweaking of the current guidelines. In Willapa there are no co-managers – even with no co-managers the results are the same. Guiding principles, communicate, document, etc. these are not principals they are window dressing. • I offered comment, those are not in the policy; asked for teeth in the policy they are not there either. • Comments about communication – with the internet, communication is easy. With short notice through the internet look at all the people who are here. • Thirdly, All participants in this fishery must meet their obligations to be involved in the process of season setting and ensure that their numbers and dates are published in the proper manner. • I want to see the Public more involved in the WAC process before North of Falcon. This process has only involved a fee people invited by WDFW. The Commercial Fleet has dominated this process for many years with WDFW supporting them over Conservation. The Tribes are also part of the Commercial harvest and should be regulated in the same process instead of WDFW letting them do what they want.
• The APA process is not being followed. I have spent $10K’s of my money bringing lawsuits against WDFW, and have 1000’s of hours of time invested. The public trust is lost. Kehoe, you said for us to write the document, we did that. None of that is in this document. Don’t close the door or your mind on this. • far too much time was again consumed for allocation discussions… it amounts to nothing more than a wishing session between the gillnetters and the sporties.
Data Rigor • The tools the department has is like a butter knife. The first improvement needed is the CRC. Like to see timelier reporting like in the PS crab CRC. Adaptive management, like in PS, monitor the fishery more closely and shut the fishery down when the quota is reached. Need a policy that passes fish to the spawning beds. There is no co- management in Grays Harbor. If the state is not fishing then the tribe will. • Region 6, forecasts runs before fish hit the hatchery; need to let the fish hit the hatchery then forecast. I fish the Skookumchuck and have seen the enhancements. • needs to be a framework for in-season management, ensuring that over-forecasting doesn't have to result in overharvest, and subsequently missed escapements. • Science and biology should drive management. • Calculated in FRAM down to the last fish the bycatch to the last fish. Then set the season in days. The mortality percentages - 45% is not in the Columbia studies. The study is only long-term, where is the short term? Other studies should be reviewed. • The current Management plan and models for the Chehalis Basin and Willapa Basin are not acceptable anymore and out dated. Millions of dollars have been spent by tax payers and Logging companies to create more habitat yet WDFW has not increased any Escapement Goals, provided more fish to the gravel, increased wild populations, to match the third largest watershed on the Pacific Coast on the United States.
Enforcement /accountability • The sports fisherman are getting more and more of the allocation every season. The sports fishers are not being held accountable for their catches as we the commercial fisheries are being held accountable for every fish harvested. • Anglers on guide trips would also furnish license numbers to the guide to record days fished and actual catches to avoid cheating on the annual limits.Daily recording in the logbook should be mandatory and all entries should be made within 24 hours of the trip completion. Alaska uses this system but when boat launch areas are super busy then it is easy to forget to complete the log on site and a 24 hour allowance for recording final catch info would be fair. AK imposed fines for non completion on site and that was strictly a revenue operation and lead to many confrontations between guides and enforcement personnel. • Selective fishing if its going to happen it needs to follow scientifically designed procedures and protocols. In Grays Harbor they violate all internationally recognized rules. • They need to fish selectively like they have been trained. • It was also made clear that there is considerable support for increasing the number of WDFW enforcement officers in order to maximise conservation efforts to recover Grays Harbor wild salmon • there is considerable support for increasing the number of WDFW enforcement officers in order to maximise conservation efforts to recover Grays Harbor wild salmon. • The public needs to be informed that the catch allowed by the non-treaty Chehalis Tribe(s) comes out of the recreational sector. If the category designated as CTCR in the charts is the non- treaty Chehalis Tribe(s), it needs to be designated as such in the draft policy. Non-treaty catch quota should not be taken from the recreational sector. How can WDFW give the non-treaty Chehalis Tribe(s) a catch percentage when they provide no catch figures to WDFW? My recommendation is "no catch figures", "no fishing". • We need to monitor the Quinault’s and take them to court.
Clarify Sharing of Impacts
Allocation • 77,000 people sport fish salmon in the state of Washington (1.1%); the commercial fishers provide fish to the rest of the state. Allocation should be 50:50 on all species. • In the survey the sports zeroed out commercial allocation. Sport have lots of opportunity statewide. • I fully support the non-treaty commercial salmon fishing in Grays Harbor. Generations of families in Grays Harbor have been supported by the salmon gilnetting season - I strongly encourage you to consider those families - it's very important to them. • I have been a gillnetter for over forty years. In the 70s we would get to fish from the 6th of July till sometime in November. The fleet of boats was over four times what it is today. We had a very valuble sport fishery during those times also. • I support the non-tribal commercial salmon fishery in Grays Harbor. The non-tribal commercial salmon fishery is vital to many families in our area. Please keep this is mind when determining future allotment of our resources. • There are other fisheries in GH, we need to be mindful of the share that comes to the state. That is the portion that should be fairly distributed to sport and commercial fisheries. The sports emphasize that there are two fisheries; sport and commercial - and that commercial include the tribes. • The sports fisherman are getting more and more of the allocation every season. The sports fishers are not being held accountable for their catches as we the commercial fisheries are being held accountable for every fish harvested. Washington gives the tribal fishers 58% of the allocation. Start there. The commercial catch is nominal compared to the tribal and the sports fishers • The Chehalis side should have a small amount of Chinook set aside for the commercial to access to coho. There are large surplus of coho – hatchery and natural both. • Divide the catches of Chinook equally between the recreationals and gillnetters for wild chinook. Since wild coho has been the run of concern for the last several years they will be used as incidentals during chinook and chum fisheries. Impacts to be used when run size is below escapement goal will be divided 60% gillnetters and 40% recreationals. The only exception to this is if the run size is 156% greater than the escapement goal then there could be a directed wild coho fishery divided 60% recreationals and 40% gillnetters. Between 110% and 156% of escapement goal the wild coho will be divided 60% recreational and 40% gillnetters. Hatchery chinook and hatchery coho will be taken during other Humptulips fisheries. • The goals for recreational fishing involving "experience" or "opportunity" are inappropriate. We are already seeing this concept being abusedd in plans for alternative gear elsewhere in the Columbia. OR officials are talking about closing sport fishing during peaks of runs to allow enough mark selective commercial harvest using purse seines! Sports not to worry, you will get extra days during off peak run times. Seines get the harvest, sports get the "experince" of more fishing with less opportunity per day. This is how sports fishing is to be minimized, along with its superior econiomic benefits. The draft guidelines need to be changed to prevent this approach in Region 6. • They should not be fishing more than 3 days / week. They are taking huge sections out of the run. • the commercial gill nets should be in the water one day less than what it was this year. Ive been keeping an eye on the nets in the river because I drive over the Chehalis river bridge in Aberdeen every day and have seen nets in the river, either commercial or native american, 5 days a week. That is unacceptable for recreational fishing because when they take the nets out on Friday, it takes a while for those fish can get through to get up the river to where bank fisherman can have some fun and try and catch some salmon to allay the exorbitant cost for the license. I have no problem paying the license cost but expect the recreational fishery to be given more emphasis. • One good thing is to allow 3 d/wk without nets. Need a change in the current conscious approach. End of year review – compared to what? Need more in the policy. • Support 3 days/week proposal for net free.
• The 3 day proposal for net free; what does that mean? The treaty fishery is already fishing 4 days/week, does this leave the NT fleet sitting on the beach? • The rec option offered 3 days sport and 4 days commercial. The Commercial won’t offer a compromise. Recreation is willing to have days on and days off. • Tribal and commerical netting should only be allowed on a Sun (1200) - Thursday (1200) during the fishery. If the catch goals are not met, extensions or additional netting days can be addressed and granted, but only after escapement data is reviewed. • I want to see the Public more involved in the WAC process before North of Falcon. This process has only involved a fee people invited by WDFW. The Commercial Fleet has dominated this process for many years with WDFW supporting them over Conservation. The Tribes are also part of the Commercial harvest and should be regulated in the same process instead of WDFW letting them do what they want. • Similarly, it was very clear that future, non-treaty salmon harvests should be guided by the greatest benefit to cost ratio - from the data shared this evening it seems that recreational fishing accounts for far greater revenue to Washington state than does the commercial sector. • 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. • The QIN fishery represents more than a meaningful commercial opportunity, and it should be the only one they are obligated to allow. I would like to state for the record that I believe that until you curtail the tribal fishery it will be of little use to keep restricting the non tribal fishers. • Commercial netting should be stopped immediately within Grays Harbor and its tributaries. This is an outdated practice that is not sustainable today in this location due to overharvest and impacts on sensitive species as it does not allow of selective release listed groups of fish. Addtionally there is not the abundance of fish in Grays Harbor that allow this practice to continue. The economic benefit of having a strong sport fishery in Grays harbor and its tributaries far out weigh the small benefit that harvesting the remaining fish by commercial fisherman • The public has repeatedly stated that a tribal net or a non-tribal net is a commercial net under state law. The legislative mandate of the Commission and department states, "The department shall promote orderly fisheries and shall enhance and improve recreational and commercial fishing in this state." (RCW 77.04.012). You will notice the law does not require the Department to provide three commercial fishing opportunities based on tribal affiliation. The attached AGO shows the Attorney General was asked if a non-tribal commercial fisherman who opted to take the buyout could sell the boat back to a tribal fisherman. The AG opined that a tribal fisherman was a commercial fisherman under state law and such could not be done. Since the Chehalis and the Quinault commercial fishing takes approximately 58% of the available harvest in Grays Harbor, the mandate is fulfilled without the Department imposing yet another third commercial fishery. • The inland community does not perceive a difference between the commercials. This ain’t Mobile Alabama 1963 the state needs to get over it, the tribes have the right to take their fish. • Steady decline in the Chehalis. You see that there are two different gillnets, this is one fishery. We are fishing behind all these nets. There should be a focus on one netting season – 60:40 commercial. • Two fishing interests – rec and commercial. Both interests desire the maximum allotted to them. The commercials scoop hundreds, the recs use one hook, and can only keep two. • Economics we important, look at where the money comes from; you are supporting a welfare system for the GH commercial fleet. • Allocation should be developed on science not public opinion. It needs to be understood that nets are not in the water 24hrs / day, the fish get through. Sound fishery science.
Other
Economic value • Commercial value does not account for 1000’s of coho that go un-harvested. • Increasing the sales price of the fish harvested commercially would provide compensation for the reduced harvest volume. WDFW should consider eliminating the would allow the commercial license holders the ability to market the fish caught at retail (i.e.commercially in its seasons in Grays Harbor be sold at wholesale to a licensed fish buyer. This requirement that fish caught “Fresh Tuna” on the dock in Westport, fresh salmon at the farmer’s market in Olympia, etc.). • I'm a sportfishing guide based out of Olympia. I spend the majority of my days fishing in the Chehalis Basin. A dependable season would make my job much easier. I can book trips without fear of in season shutdowns. • I look at things in terms of money. Are you getting your numbers up? That is an investment. If we are not getting fish back then why are we spending the money? • The economic benefit of having a strong sport fishery in Grays harbor and its tributaries far out weigh the small benefit that harvesting the remaining fish by commercial fisherman. • Also, the economic impacts do help the local economy in a big way My clients, for a two person trip pay me around $175 a person for a days fishing. Many people come from out of the area, spending money on motels, dinner, lunch and assorted other items plus licensing. This benefits many in the local area. I also try and buy my supplies locally as well as fuel and my licensing. Thanks for taking this into account when looking at fishings impacts to the local economy. • recreational fishery has more economic value than the commercial fishery (at least that is what your data suggests even though you say that it is not comparable to commercial data), that the commercial gill nets should be in the water one day less than what it was this year. • it was very clear that future, non-treaty salmon harvests should be guided by the greatest benefit to cost ratio - from the data shared this evening it seems that recreational fishing accounts for far greater revenue to Washington state than does the commercial sector • Economics we important, look at where the money comes from; you are supporting a welfare system for the GH commercial fleet. • I am writing to express my interest in the Grays Harbor non treaty gillnet fishery. South Bend Products purchases a large percentage of the harvested fish from Grays Harbor. The fishery produces high quality fish that are marketed throughout the country. Please consider the fact that in addition the income the fishery provides to the fisherman, it provides jobs to on- site buyers and crew, truck drivers, plant workers and office staff. Reduction or elimination of the non-treaty fishery is a reduction of jobs in Gray’s Harbor and Pacific Counties. I would appreciate your consideration of maintaining the non treaty fishing opportunities in Gray’s Harbor. • The GN licenses actively used are about 50% of those sold. You could cut that by 50% again and you might have viable fishery. • late 1970-80’s commercial buyback. The commission mandate in state law is to maintain the viability of the fishing industry. • sport fishery $1.5M, in current dollars is close to $2M.
Hatcheries • We also need to restore the hatchery production that has been lost. • Also you have to fertilize the River you have to put the salmon carcasses back in the River to fertilize the River, most of the rivers are stale and dead now because they have not had the salmon carcasses that the bugs need to feed on. Let's revive the rivers. Then also put as many fish in the River as possible. Then it would make no difference whether it was a hatchery fish are wild spawned fish it would be in the River and you'd have as many fish as you need.
• As for the hatchery's put the hatchery's at full speed raise as many fish as possible get them in the River, it doesn't have to be a year later after they have attached, put them in immediately. • enhancing the Salmon returning to Grays Harbor. I only see maintaining what we have now.
Miscellaneous • Neither current escapement goal methodology nor eelgrass management practices by WDFW take into account the natural carrying capacity of these bays • Region 6 has been content to leave goals low and then seldom meet them. In a region which has been satisfied and enjoyed management job security while missing escapement goals for Gray's Harbor and Willapa Bay 9/10 of the time, a culture change would be needed.
Willapa commercial seasons are moving forward. R6 Fish Program Steve Theisfeld is trying get them to folks but a link will be coming. If you want them in a e mail attachment PM me and I will forward them. And yes the commercials are in 2T in mid August for 3 1/2 days along with two other mid areas so yes it will be a clean sweep so plan accordingly as there will not be crap in that bay for 2 1/2 weeks after the debacle !
The link below is to the WDFW rule making page on their website. Always interesting this time around it is even more so and not the CR 103 ( CR 101 starts / CR 102 puts forth a proposal / CR 103 finishes it up with modifications ) but rather the CES. ( Concise Explanatory Statement ) The CES is the legal response to citizen comments and this time around it is not the C&P crap but rather a 41 page item by item response. Now if one does not care to take the time to read it don't but I would urge you to if you fish Willapa or Grays Harbor. This CES was done by the agencies attorney or someone with one hell of a legal mind and as you have the gillnetters threatening to sue if they do not get a wide kill em all fishery on one side and the Advocacy at them on the otherside over the complete collapse and failure of the infamous Willapa Management Plan and the continued destruction of native stocks. Keep in mind the CES has a lot of well thought out information right along with some things that are totally misrepresented followed closely by utter fabrication.
The Willapa CES on page 32 had this gem. It is the response to a citizen objections to favoritism shown the commercial fisheries. The most disturbing part of this is that Willapa is managed to the commercial side to achieve statewide balance for commercial / Rec. This is utter BS and why Willapa is important to ALL Rec fishers. Now the bit below where the CES more or less says the Commission must agree as they have not objected or provided different guidance. I will us take back several months when the Commission Chair Wecker grilled Mr. Anderson on the issue if the Agency was going to bring Willapa to the Commission for review. Watching Mr. Anderson stammer around trying not to give a direct answer was a classic.
So part of the settlement with the Advocacy was the Agency has to ask the Commission to reopen the Willapa Management Plan. It is about to be ground zero on how you create a management plan that respects natural stocks, protects them, and provide maximum economic benefit on the harvest of hatchery fish. That isn't with a gillnet and the massive economic loss to Pacific County tourism as a destination fishing region has been catastrophic for Pacific County. Nah I doubt if the Commission truly understands what has been done to Willapa during the time Mr. Anderson has been Director but I do believe they are about to learn.
1) Many commenters expressed that the Department did not properly assess the economic value of each fishery sector.
The Department understands there is value in both recreational and commercial fisheries. Commercial fisheries are easier to assess. Market prices and the number of fish caught and sold are known values. Reporting requirement of the commercial fishery allows for quick processing of data. Evaluation of the
recreational fishery isn’t as simple. There are limited creel survey data available for the marine area recreational fishery that could be used to estimate effort and subsequent economic value of the fishery. There are no recent data available for freshwater fisheries in Willapa Bay. In order to make an estimate of effort, the Department would have to make assumptions about individual angler catch rates, likely by using data from other basins.
The Commission North of Falcon policy notes: “Willapa Bay harvest management objectives shall include meaningful opportunities for both recreational and commercial fisheries” and “When assessed from a statewide perspective, fishing directed at chinook, coho, pink, sockeye, or chum salmon will not be exclusively reserved for either sport or commercial users.” The adopted rules are predicted to provide $662,759 in ex-vessel value for the commercial sector (compared with a preliminary estimated ex-value of $638,000 in 2013).
However, the comment suggests that WDFW needs to allocate catch between sectors based on economic value derived from the fish harvested. This issue is much more complex given the “statewide perspective” direction in policy. A simplistic re-allocation within Willapa Bay would not address the balance of opportunities across the state. The majority of Chinook and coho are prioritized for recreational fisheries in most other regions. For example: “The Puget Sound harvest management objectives for chinook and coho stocks, in priority order, are to: (1) provide meaningful recreational fishing opportunities; and (2) identify and provide opportunities for commercial harvest.” Willapa Bay is the one region of the state where pre-season planning has resulted in more Chinook and coho harvested by the commercial sector on a regular basis over the past decade. The Department has complied with specific policy direction to allocate resources when provided. No such direction has been provided in Willapa Bay, suggesting that the Commission is comfortable with the current opportunity and catch balance. WDFW anticipates that the Fish and Wildlife Commission will be reviewing Willapa Bay salmon management this fall and additional guidance will be forthcoming. In lieu of current prescriptive guidance regarding opportunity and catch sharing, the Department believes the adopted rules provide meaningful fisheries for both sectors and comply with Commission policy.
The comments below are a response by the Advocacy to the Willapa Commercial season for 2014 outlined in the CES. It was the Advocacy that brought the legal action in 2013 challenging the Commercial season that basically started the effort to protect natural origin spawners ( wild ) so I thought this might be of interest to some folks following the many issues surrounding Willapa salmon harvest.
Phil Anderson, Director Washington Department of Fish & Wildlife 600 Capitol Way N. Olympia, WA 98501-1091 RE: 2014 Willapa Commercial Season Dear Director Anderson: The Twin Harbors Fish & Wildlife Advocacy offers the following comments on the 2014 com- mercial season recently adopted for Willapa Bay. In addition, the Advocacy feels that the parties should move forward with completing their performance under the agreement reached as a result of the 2013 season challenge.
The Advocacy recognizes significant improvements in the NOF process used to develop the 2014 commercial season. We believe more improvements are in order, especially in the area of reliabil- ity and accuracy of presentation materials. That being said, we compliment the efforts undertaken by the staff this year to improve the public’s ability to participate in the process. We take special note of the efforts undertaken by Region 6 staff under the leadership provided by Steve Thiesfeld.
Another noteworthy improvement related to public participation is the season adopted actually re- flected many of the comments and input provided by the public during NOF. While many will be disappointed that their points of view were not adopted in the fashion they sought, the CES draft- ing improved significantly and the public could actually recognize the process they participated in and see where the Department agreed and WDFW’s rationale when it didn’t agree with their points of view.
The Advocacy further recognizes that the season adopted shows significant progress in regards to the Advocacy’s concerns over selective fishing utilization and conservations standards. We note the following highlights:
• The installation of a protection zone for the North River Chinook stock;
• Reducing the harvest cap for Chinook from 30% down to 20%;
• Seeking support from the commercial fleet to find alternative gears;
• Increasing onboard observers from <1% historically to 15% during selective fishing periods;
Page 2, Willapa Commercial Season Comments
• Reducing the reliance upon selective fishing and moving toward a non-selective approach with retention to reduce discarding large numbers of dead bycatch;
• Language changes in the WAC that require all bycatch to be released be placed into a recovery box and remain there until fully recovered;
• Insertion of net free days during weekly cycles rather than continuous 7 day a week seasons to help get fish upriver; and
• Insertion of several weeks of net free time during the high point of the Chum run cycle.
Unfortunately, the Advocacy also has significant concerns over the season that was adopted. In our view, the 2014 season once again fails to rise to the legislative mandate that the Department manage first for conservation and harvest second.
We highlight the following concerns:
a. The CES only references inseason adjustments to increase the commercial season when professional fisheries management protocols recognize that inseason monitoring (the purpose of quick reporting of landings) and reducing harvest if over-harvest is underway is a key to insuring conservation standards are met. (In season management is used regularly for recreational seasons and other commercial fisheries in Washington);
b. The season adopted installs unlimited net pressure (number of boats) into 2T during much of the run cycle for North River Chinook dramatically negating the intended benefits of the protection zone
c. The decision to once again install a net season of this magnitude in 2T as a means to deliver the fleet the maximum-possible ex-vessel values from hatchery Chinook will continue the downward trend of natural spawning Chinook reaching the gravel in the Willapa, Nasalle, and other streams (evolved after the Department installed a lucrative net season into the area now known as 2T over 5 years ago);
d. The Department states that it will increase observers but doesn’t provide any assurance that observers will be properly trained and enforcement staff will be present in adequate numbers to deliver the 90% compliance rate assumed by the Department;
e. Reliance on an assumed 90% mortality figure without adequate historical justification and when WDFW possesses ample evidence that fisher compliance with Fish Friendly Practices is inconsistent, at best;
Page 3, Willapa Commercial Season comments
f. While the Department adopted the Advocacy and others recommendation to allow the fleet to retain Chum as a means to avoid wasting fish while increasing the ex-vessel value to the fleet, it failed to adopt the key reason for supporting such a move, adding another week cycle of net free time during the prime time of the Chum run cycle (practicing avoidance).
While we had sincerely hoped it would be otherwise, due to the above stated concerns, the Advocacy cannot endorse the season that has been adopted. As a result, we intend to reserve our rights to object in the future if the problems identified above in a. through f. are proven valid during the 2014 season or similar conditions reappear in an adopted WAC in the future.
Hopefully, Mr. Theisfeld and others within the Department will conduct the fisheries in such a fashion that our concerns are not proven valid. The natural spawners and future generations of citizens would benefit greatly if the Department can prove us wrong and the Advocacy members would like nothing better than to admit the Department did so. The question remaining is “Will the Department conduct the season in a manner that actually delivers the conservation results that are implied by or expressed within the text of the CES?”
The decision to opt not to challenge this year’s season was difficult in many ways. A pri- mary driver was the Advocacy’s recognition that the department faces the difficult task of correcting decades of unsuccessful hatchery and harvest practices and success will depend greatly on a concerted effort by all involved.
The Advocacy is ready and willing to move forward in a positive fashion. To that end, we look forward to receiving notification that you have requested that the Commission revisit the Willapa plan. We also stand ready to begin working directly with WDFW staff to schedule and conduct the four public meetings called for in the settlement agreement.
Again, we compliment the Department on its improvements installed this year over the experience of last year. We feel that now is the time to continue with those improvements and complete the performance of the 2013 settlement agreement.
The letter below is to Director Anderson from the QIN regarding budget and hatchery cuts / production and while it was written in 2009 not much has changed. I think I will try something and see if it helps folks understand the letter or rather the dance that WDF&W the QIN have had going on since the late 1990's. I will put my comments in RED so they easily distinguished from the letters author's comments. Now the formatting will be rough as in going from a PDF to word to PP things ...... ah ....... get strange?
So here goes ............................
Phil Anderson Interim Director Washington Department of Fish and Wildlife 600 Capitol Way N. Olympia, WA 98501-1091 Dear Phil:
RECEIVED APR 8 2009
OFFICE OF THE DIRECTOR
Thank you for your letter dating January 27, 2009 providing us with the opportunity to review and comment on the potential impacts of the Washington Department of Fish and Wildlife (Department) budget shortfall and the proposed hatchery program reductions. Our comments pertain primarily to proposed reductions in production for facilities located within Grays Harbor.
Factors similar to the four listed in your letter to help identify and rationalize specific program reductions across multiple species and geographic regions are appropriate. However, we believe that two additional considerations should also be taken into account: (1) The extent to which hatchery operations are related to mitigation agreements or requirements to offset damage to habitat or as a condition for obtaining permits or other authorization; Yes & no. The QIN is correct that the hatchery production IS mitigation for the loss of natural production but only to harvest not spawners in a stream. (2) The effect on total allowable harvest mortality of wild and hatchery production from Grays Harbor, for treaty and non-treaty fisheries both within and outside Grays Harbor, under management constraints directed at protection of comingled naturally-produced stocks. 100% correct BUT ( seen that coming didn't you? ) the QIN view is to the court agreed to escapements for Grays Harbor and it's tributaries. The simplest way I know to explain that is if tributary fails to make spawner escapement that is OK as long as the total escapement goal for spawners is acheived. Now the state side is managed down to the tributaries ( larger streams only ) level for Coho & Chinook but not Chum. So what to do? I am clueless as for the last 15 years the co managers have operated a dual management system with each taking care of their share of harvest. Sure the fish and public have suffered but what is new?
Generally, we believe that WDFW and the QIN should work collaboratively as co¬ managers to identify adjustments to hatchery production programs that are focused on improving specific program effectiveness, efficiency, scientific defensibility and reduction of risks to natural salmonid populations. Priority considerations for reducing hatchery production at facilities located within Grays Harbor:
• Programs that do not provide mutual harvest benefits to co-managers within Grays Harbor or pose ecological risks to indigenous populations of naturally produced fish should be eliminated first. For example:
• Out-of-basin transfer programs. I beleive this is directed toward the issue that WDF&W stopped producing salmon ( other than the 300K Skookumchuck Dam mitigatin ) for the Chehalis Basin and rear nearly 1,500,000 Coho for Puget Sound at the Skookumchuck Facility and thank you QIN for objecting.
•Non-local origin summer-run steelhead programs. Non-local origin lake stocking programs. Now this one is just plain BS. The Rec sports fisheries license fees pay a huge portion of WDF&W's bills and to complain about Summerrun Steelhead is rather self serving. Now the non local lake stocking are the Rainbow lake plants for heaven's sake directed primarily at families and children. That the QIN would feel this is inappropriate is a bit of a reach. My goodness the thought that tax payer dollars and citizen license fees only go to things that benefit QIN commercial fisheries defies logic.
• We recommend that WDFW discontinue the Stevens Creek summer run steelhead program in the Humptulips, Lake Aberdeen releases in the Wynoochee, and Eight Creek in the Upper Chehalis. Non-local origin summer run steelhead programs should be eliminated before any reductions for local origin winter run steelhead programs in Grays Harbor are considered. I addressed this previously. Elimination of these programs will potentially reduce fish health risks to other stocks in Grays Harbor and adjacent watersheds because IHN virus is currently being harbored in Lake Aberdeen and Humptulips steelhead. Now this one is a bit stunning as e mails identify objections from another tribe objecting to releases salmon by the QIN of smolt showing signs of IHN. Having some Rainbow we were rearing years back sequestered due to IHN and the fish showed zero signs of the disease but it was detected. I think this one is best left to the Bio's. Rearing capacity that becomes available due to reductions in the summer steelhead program should be utilized to reduce loading densities for on-station winter steelhead production to reduce stress and improve the capacity to manage future IHN virus outbreaks.
• The highest priority for production program goals for the Skookumchuck facility should be directed at providing mitigation for habitat degradation in the Upper Chehalis basin. In-basin mitigation for past and current habitat degradation in the upper Chehalis and future habitat impacts caused by potential flood control projects should receive the highest priority when considering adjustments to enhancement production for Upper Chehalis facilities. This is a bulls eye of the first order. Part of the Governor Dan Evans Salmon Enhancement package the Skookumchuck facility was built and produced salmon for the Chehalis. WDF&W ended the program transferred the 300k mitigation Coho smolt to Bingham Hatchery on the Satsop ( in violation of the mitigation agreement which was ended when Friends of the Chehalis threatened legal action several years back ) Out-of-basin transfers of fish produced in Grays Harbor facilities should have lower priority than in-basin releases. The Skookumchuck hatchery is currently utilized for incubation and rearing of 1.65 million Skykomish origin hatchery coho. Eyed eggs are transferred from Marblemount hatchery to Skookumchuck in January and subsequently transferred to South Sound and Squaxin Island net pens as juveniles in February of their release year. Consequently, the largest release group of hatchery coho raised within Grays Harbor does not contribute to Grays Harbor fisheries. Again thank you QIN as most folks in the Chehalis Basin are unaware that WDF&W continues to utilize one of the most cost effective hatcheries in the state to benefit Puget Sound fisheries. The losses to our community are simply just huge! The proposed reductions to Grays Harbor total 16% whereas a 13% reduction in total production is proposed for South Puget Sound. We note that no reductions are currently proposed for Puget Sound net pen programs that utilize hatchery capacity within Grays Harbor. Right on target folks! No BS here as the QIN pegged this one.
• We support the elimination of Satsop origin coho transfers to Upper Chehalis facilities in favor of the use of Upper Chehalis origin stock as broodstock for the Skookumchuck facility. Now this is interesting. Prior to the present Director being appointed the local communities worked collaboratively on several issues. This was one of the issues and the mitigation Coho were moved back to the upper basin to comply with the mitigation requirements after Freinds of the Chehalis threatened legal action BUT three release sites were to be utilized for this production to disperse harvest opportunity for Rec fishers over a wider area of the upper basin and utilized a LATE ( Dec / Jan ) Satsop Coho stock. Now the rub, bump in the road, a say what moment, WDF&W was supposed to have conversations with the QIN to insure it was not a issue and evidently this DID NOT happen. Bad our side as both the QIN and Chehalis Tribe concerns should ( and were supposed to be ) addressed.
• We request additional information regarding the basis for WDFW's proposal to reduce Chehalis coho production by 40% while proposing a 15% reduction for Humptulips production. The largest release group within Grays Harbor occurs from the Stevens Creek hatchery in the Humptulips River. Hatchery escapements (rack + strays) over the last decade averaged over 25,000 for on-station releases. This program consistently produces the largest hatchery surpluses within Grays Harbor. Adjusting the size of the Stevens Creek coho program was recommended by the HSRG in 2004 as one option for reducing the number of strays and reducing the annual surplus returning at the rack. The Humptulips NOR Coho ( natural origin recruits or Wild ) have not made escapement for 23 years or more and when it did it was only because of the influx of up to 4 hatchery origin Coho for every 1 NOR Coho. Right here things get weird and not just a little but way way out there. Because the Humptulips utilizes pumped river water and does not have a weir a very large percentage of returning adults simply swim right past the hatchery and do what salmon do when they return, they spawn! So for years local advocates from Tom Pentt, Jerry Paveltich, and myself and many others attempted to get a hatchery modification done to utilize Stevens Creek water to reduce straying. In fact the current Fish Program Manager and several Science Division staff tried to get funding for the modification only to have Olympia veto it.
Presently the modification is to be completed this summer ( courtesy the former Governor's job package ) and Rep. Blake's effort must be recognized. That said we have a problem on the Humptulips with NOR Coho as they have been overwhelmed for so many years by the hatchery stock that the QIN appears to accept that it will take hatchery strays to supplement the NOR Coho to make escapement. Take this year as an example. Before harvest the Humptulips NOR Coho will not make escapement. So what to do? Shut down harvest? Recs can selectively fish in river and get the impacts very low by releasing NOR ( unclipped ) Coho. Not so the QIN or NT Nets for that matter. Add to the mix the new Grays Harbor policy that dictates managing for NOR stocks and you have a recipe for something that looks like two trains meeting head on.
Blame the QIN? I think not as WDF&W knew of the problem but just ignored it, as did the QIN. Blame WDF&W? Yes / No but remember as knowledge of hatcheries limitations have grown it culminating with HSRG ( Hatchery Scientific Review Group ) and as with everything the dollars to make changes are scarce and competition for funds fierce and the Humptulips lost out. So now WE ( QIN / WDF&W / citizens ) have a problem and on this issue the blame game will get neither the tribal fisheries or non treaty fishers out of this mess. Only the QIN & WDF&W can map a path out of this mess and mess is a simplistic term to describe what exist with Humptulips NOR Coho. Well I guess another route is available and it would be a judge saying you shall.
• In additional reductions in production are necessary, impacts of adjustments to each program should be evaluated in terms of the distribution of harvest opportunity among treaty and non-treaty commercial and recreational fisheries, particularly within each Grays Harbor management area. Based on information currently available to us regarding program effectiveness and program specific contributions to Grays Harbor fisheries, we recommend the following,:
•No reductions should be made to current levels of Aberdeen net pen releases of 150,000 coho. Proportional reductions should be larger for off-station Westport net pens and on-station Hurnptulips releases than on-station Satsop releases to help reduce hatchery stray rates and improve "sharing"of reductions in production. This one is really locked in the history of Bingham Hatchery. When Mr. Blum was Director of WDF&W he directed that Simpson Hatchery ( now renamed Bingham ) be closed due to a lower than normal survival rate of out migrating Coho smolt which appeared to take place in the South Monte reach of the river which became known as the "line of death". Well now the meeting at Monte Square with the public was ah .... loud? So a compromise was developed and part of the compromise was to move Bingham Hatchery presmolt to net pens at the Port of Grays Harbor and Westport Marina to get a larger return and provide opportunity in the Westport Marina for tourism. In addition Senator Brad Owen obtained funding for a study of the so called "line of death".
While the net pens do offer up opportunity straying is pretty much a given so it has always been a bit dicey as WDF&W did not really address it in the beginning as it should have. Now that was easy to whack em with but remember at the time the knowledge of hatchery / wild interaction as to genetices was just beginning to emerge. Around Grays Harbor things just seem to run on auto pilot which can come home to bite one's self in the rear, big time.
Lastly, when considering plans for future production from Grays Harbor facilities independently from budget-drive modifications, we suggest that we jointly explore reduction of on-station releases of Humptulips River coho and reallocation of funds to increase production of Chinook within the Chehalis system. This would be nice but I am not going to hold my breath.
We appreciate the opportunity to comment on your proposed hatchery program reductions and look forward to working with you to develop a final package.
Sincerely,
Ed Johnstone Quinault Fisheries Policy Spokesperson
Here is what R6 D17 ran in the model. It is essentially the 2013 schedule but I would not bet it is the final word. Sorry about the formatting but C&P goes nuts when dropped in PP but at least you can get a general idea. The thing is despite public posturing the state & QIN do not exactly go out of their way to get along.
Stat Week Actual # Days schedule Date Fished 36 Sept. 1- Sept. 7 0.0 37 Sept 8 - Sept 14 0.0 38 Sept 15 - Sept 21 0.0 0 39 Sept 22 - Sept 28 2.0 2 40 Sept 29 - Oct 5 3.0 3 41 Oct 6 - Oct 12 4.0 4 42 Oct 13 - Oct 29 4.0 2 43 Oct 20 - Oct 26 2.0 0 44 Oct 27 - Nov 2 2.0 0 45 Nov 03 - Nov 09 1.0 3 46 Nov 10 - Nov 16 2.0 5 47 Nov 17 - Nov 23 5.0 5 48-53 Nov 24 - 5.0 24 30
This came through my e mail and I thought it hit right on.
The Recs (and even the Commies) should recognize that the tribes are their "friends" if all they want to do is catch more fish. QIN would be ecstatic if Hump, Satsop, and Skook, plus Satsop Springs absolutely maximized releases of quality fish.
They use habitat and wild fish as a hammer to get what they want (the Feds are real responsive, too). The big fear in the halls of power is having to protect habitat and actually produce fish in it. GH does not need a single hatchery fish in order to have robust wild runs that would support a larger in-Harbor fishery-sport and Commercial- than you have today. It would take continuing to protect the habitat and require significant changes in AK, BC, and WA ocean fisheries in the short term. Over the long term some ocean fisheries could be put in place. Not as big, but probably limits for all when open.
Couple of things folks have questions about. As to Grays Harbor the simple fact is nobody knows for sure on the QIN or NT net schedules. First the QIN have not posted it and WDF&W has not come an agreement with the QIN on the 2014 seasons. Best guess here is about the same as last year. While some may think they know, the simple fact is until WDFW files a CR 102 for the NT Commercial season nobody will know for sure just what the days / dates are. As to the situation regarding Humptulips Wild Coho numbers way below escapement thus hitting some critical directives in the new Commission Guidelines yes / no / say what is around? It is a interesting as to how Region Manager Steve Theisfeld resolves this bit and stays out of court.
In the July issue of the Reel News has a guest editorial by the U of W on the conflict between Rec and Commercial fisheries in Willapa Harbor on page 4. It is a good read and for folks who would like a copy the Reel News provided us a PDF of the issue to send to folks. So if you would like a electronic copy PM me and I will send it to you. Also on Page 3 is a letter to the editor outlining the process utilized which is a really good read.
CR 102 for Grays Harbor for the Non Treaty Commercial Gillnet season has been filed and posted on WDF&W's website. A review is underway but here is the link to take a look. The QIN is to be similar to last year, or at least that is what we have been told.
Not really but could. It is 4/3 but if the QIN goes for five and does not violate the court decisions then that week would only have two days net free. But it should not happen often if at all. The 4/3 was not intended to restrict the court mandated tribal harvest so the state side ( NT Nets ) is the restricted entity.
Another way to look at is 4/3 in a calendar week and the QIN normally start at noon and take out at noon. Now two 24 hr periods occupy 3 calendar days and 3 QIN days occupy 4 calendar days resulting in no NT nets. A end run was tried using 96 hours but did not fly ( after clarification ) so the QIN maybe doing five is offset by the manner they conduct fisheries. This means that R6 can not try to dodge 4/3 by backing NT nets behind QIN using hours ( part of days ) rather than calendar days. In other word I minute of a 24 calendar day takes all 24 hrs up. No games no reinterpretation.
Little more. Region 6 Fish program Manager Steve Theisfeld sent the model out so if you would like it PM me. On the NT tab it has the combined Humptulips & Chehalis net schedules lined out by week. Handy little thing!
The information below is from QIN President Fawn Sharp published in a Tulalip Tribal news lettere and reflects the QIN comments on the new WDF&W Commission policy for Grays Harbor. ( & the tributaries ) Many will reject the positions put forth by President Sharp but one should temper that rejection with a understanding that history drives perception for most folks tribal or non tribal. That said in the last 15 years ( or more ) co management in Grays Harbor has went from co management to dual management with both the QIN and WDF&W pretty much managing their portion of the harvest pretty much independent of each other.
President Sharp: " Rather than confronting the major threat to natural fish production in the Grays Harbor Basin, destruction and degradation of habitats, the Commission has chosen to focus on harvest by a small segment of the fishing community." Two things come to mind here. First it was a major revolt by citizens that resulted in the new Commission policies not just a idle thought by the Commission. It was a diverse and substantial number of citizens not a small group of self serving individuals. Secondly the inland communities in the Chehalis Basin have shouldered the vast majority of the burden of habitat reform and believe the purpose to be to get fish back to the streams for healthy runs. The QIN relationship with the Chehalis Basin salmonid stocks is primarily harvest. If you have more fish due to restoration you have more for harvest BUT that does not necessarily mean more spawning salmon in the streams that the fish spawn. In fact the Chinook escapement goal was recently reduced for Grays Harbor .
President Sharp: “As co-managers, the Quinault Nation and State should be working collaboratively and cooperatively to conserve Grays Harbor salmon. Yet the Commission didn’t even bother to meet with us. The Commission’s plan is a stark reminder of the decades-long battles in the federal courts which found that the so-called ‘conservation’ actions of the State of Washington were in fact ‘wise use’ decisions that unlawfully discriminated against treaty fishing. It is inconceivable that today, some 40 years after the decision of Judge Boldt in US v Washington, the Commission would still choose to ignore tribal rights and interests,”
I guess this is one view but the following is from the new Grays Harbor Management plan. 2) Meet the terms of U.S. v. Washington and other federal court orders and promote a strong relationship with the Quinault Indian Nation. Spawning escapement goals, fisheries, and artificial production objectives will be developed and jointly agreed with the Quinault Indian Nation. Agreements between the Department and the Quinault Indian Nation related to salmon in the Grays Harbor Basin shall be made available to the public through the agency web site.[/b][/I]
So take a look and draw your own conclusions.
TAHOLAH, WA (2/18/14)— “I am extremely disappointed that the State Fish and Wildlife Commission has chosen to unilaterally develop a management policy for Grays Harbor salmon,” said Fawn Sharp, President of the Quinault Indian Nation. Her comment referred to a recent news release in which the Commission announced its February 8 approval of a new salmon-management policy to conserve wild salmon runs and clarify catch guidelines for sport and commercial fisheries in the bay.
“As co-managers, the Quinault Nation and State should be working collaboratively and cooperatively to conserve Grays Harbor salmon. Yet the Commission didn’t even bother to meet with us. The Commission’s plan is a stark reminder of the decades-long battles in the federal courts which found that the so-called ‘conservation’ actions of the State of Washington were in fact ‘wise use’ decisions that unlawfully discriminated against treaty fishing. It is inconceivable that today, some 40 years after the decision of Judge Boldt in US v Washington, the Commission would still choose to ignore tribal rights and interests,” said Sharp.
“Quinault Nation has consistently demonstrated leadership in habitat restoration, enhancement and all aspects of good stewardship. The State’s pursuit of fish-killing dams in the Chehalis River and the Commission’s actions reflect continuation of a disturbing pattern. Rather than confronting the major threat to natural fish production in the Grays Harbor Basin, destruction and degradation of habitats, the Commission has chosen to focus on harvest by a small segment of the fishing community. The State also continues to ignore the orders of federal courts. Proper management of Grays Harbor fishery resources requires a comprehensive and cohesive approach developed through collaborative processes at state/tribal, regional and even international levels. By acting on its own, the Commission violated the principles of cooperation and trust and even such agreements as the Centennial Accord. While the Commission’s policy can’t apply to our fisheries, implementation of the Commission’s policy could well set the stage for future conflict and confrontation,” said President Sharp.
It would be interesting to look at the abundance of wild salmonids in the Quinault. Almost all of the watershed is in reservation or National Park. Which means the evil state of WA is not doing land/habitat management. As fish managers for the Quinault, isn't it the Tribes who would set the appropriate escapement goals? If there is one place in WA where the Tribes can showcase how well they manage natural reosources it would be there, right? Or did I miss something?
I can usually find a few things I agree with in these tribal rants, but in this case, all I can find to agree with is that the State and the Tribe are deeply divided on these issues. That much is crystal clear. Rather than waste time and energy pointing out the flaws in Ms. Sharp's assertions, I'll simply state how refreshing it would be to JUST ONCE see a treaty tribe admit to SOME degree of accountability for the declining salmon populations. I won't argue that they dealt the major blow (that was us, back in the cannery era), but if they want their "half" to be some number larger than zero 50 years from now, they might want to take a quick glance in the mirror while planning their 5 days/wk. "winter steelhead fishery." It would also be nice to see the QIN send a representative to NOF or any other regional meeting to address co-management issues, as opposed to claiming they were never invited to the discussion.
It just makes me wonder what bridges they intend to build with this sort of self-serving ranting. Bitching about what we're trying to do to ensure a future for wild salmon while they refuse to make any changes of their own won't do much to improve relations or our salmon runs. Sometimes, I think they're interested in neither.
It would be interesting to look at the abundance of wild salmonids in the Quinault. Almost all of the watershed is in reservation or National Park. Which means the evil state of WA is not doing land/habitat management. As fish managers for the Quinault, isn't it the Tribes who would set the appropriate escapement goals? If there is one place in WA where the Tribes can showcase how well they manage natural reosources it would be there, right? Or did I miss something?
YES. The Queets is another shining example of how their "stewardship" has made a huge difference (in terms of the rapid rate of decline among salmon and steelhead populations)... And all that despite the habitat on the Queets being among the best left in the lower 48. Most impressive.
I'll simply state how refreshing it would be to JUST ONCE see a treaty tribe admit to SOME degree of accountability for the declining salmon populations.
Without ranting I will put this out to chew on. The QIN asked R-6 Fish Program if their proposed 2014 seasons violated any court agreed to escapement goals" & the answer was NOPE. The court mandated escapement goals are for Grays Harbor and all the streams empting into it and do not break them down by tributary streams. So the QIN manages itself ( no co management here ) for 50% harvestable across the bar FOR THE ENTIRE WATERSHED COMBINED. Now the state separated the Humptulips and Chehalis years bck but the tribe did not agree to amend their court rights and frankly appear unwilling to consider doing it either. So you have two different views on how things are managed. When all streams are combined in that manner then the total of escapement has been met or is close in recent years. This results in the final total looking OK but tributaries some down ( about 1/3 of the Chehalis watershed crashing with Chum & Humptulips Wild Coho never making escapement ) and some way up depending on the year & all three species run size.
WDFW changed how Region 6, Chehalis/Humptulips, was managed......change was done for a few reasons, major was to benefit the growing sports marine fishery.
QIN stayed with the "time honored way" of management.
WDFW needs to change back to the management style, that seemed to keep peace, with all the parties concerned.......IMO
Time for WDFW needs to understand that a gill net is a gill net. QIN and Chehalis tribe can meet commercial fishery, from GH, for the salmon eating public.
NOF process could be made a lot easier, less costly and State coffers, enlarged with a more active sports fishery in the Chehalis basin.....again, IMO
[quote Fawn Sharp]“As co-managers, the Quinault Nation and State should be working collaboratively and cooperatively to conserve Grays Harbor salmon. [/quote]
Yes they should Fawn, so why don't start working on that?
Sometimes in the ongoing conflict between the Rec & Commercial fishers we forget that the discussion ( sounded better than brawl ) has a very human element. The following two letters one addressing Grays Harbor and the other Willapa, obtained in a PDR, capture that rather well. It is rather easy to blind one's self to the human cost to REC families and traditional Commercial fisheries but it is very real.
A Commercial perspective: To the Members of the Washington State Salmon Commission,
I am the wife of a 4th generation gillnetter out of Grays Harbor. Adolf Bold, our great grandfather, made and fished his gillnets by hand as he worked as a German immigrant coming to the United States in hope of a better life. This year my son was the 5th generation from our family to step on a grays harbor gillnet boat. This fishery is very much a part of our family's history and heritage. We value commercial fishing, specifically gillnetting as it has supported our family for over a century .
I am saddened to learn that commission is favoring sport fishing over commercial fishing. I am also disappointed to see that many other avenues of conservation have not been explored. It seems that all accounts of fishery depletion are being pinned on the gillnet fleet. Commercial gillnetters are following the guidelines clearly set out by WDFW, and yet they are being "punished" for following the rules. While I understand that Chinook salmon runs are low and concerns are high, I do not believe that allocating more fish to the sportsmen will do anything to further conservation efforts. With the introduction of live boxes and net changes, gillnetters have adapted and have seen decreased mortality. We would like to see similar efforts made on the part of the sportsmen whether it be isolation of spawning grounds, regulations on jet boats, decreased catch limit, or limited entry, there must be concessions made on both sides- not continually on the part of the commercial gillnetters alone.
Please keep in mind that these fishermen are family driven people, they work very hard to make a living and are dependent on the resources that they harvest. There is continual accusation of the moral character of the fleet, the honesty of their catch and the professionalism of their endeavors. While sportsmen continue to advocate for increased observation and supervision among the gillnet fleet, we would like to see increased observation among the sport fishery. The assumption that an individual has better intentions, better moral character, and stronger inclination to follow the rules simply because of fishing for sport vs. fishing for income is ridiculous. Assume the best of these men, their work ethic alone speaks volumes on the strength and endurance of their character.
While we all recognize that changes must be made, I certainly hope the commission will consider the impacts of the continual cut back of the non-tribal gillnet fleet. These impacts certainly will have an immediate impact on our income, and the incomes of those in the fishing community, but in the long term they will impact the legacy of family's like ours. Please do end our way of life in order to silence the present demands of those who are unwilling to compromise.
Commercial fishing is our heritage; it is our history and our future.
And a Recreational Fisher Perspective: Westport/Grayland Chamber of Commerce
I am contacting you on behalf of recreational fishers in Willapa Bay and Grays Harbor. Business owners should be able to support both commercial and sport fishing. They should not be bullied into making a choice. Most of the gill netters in this area are fine people. There is a very small fraction that want the sport fishers out by any means. There has been name calling and harassment on the Tokeland docks. Here is an example, a man was walking down the dock to his boat in the morning. He passed by a few gill netters standing by one of their boats. He said nothing to them but after he walked by one of them shouted "we gotta get these ---- suckers outa here". They threaten business people with the loss of their dollars if they support us in any way. My wife and I stayed a month per year in Tokeland for 18 years and spent a considerable amount of money from South Bend to Westport. We don't fish there anymore because of what I have encountered. I won't elaborate on what I have been called.
In past years, we had to struggle but both sides got a decent season at the annual salmon meetings. In 2010 the WDFW made no pretense of fairness. The sport fishing representatives that attended thought it was not a legitimate negotiation. They held private meetings with the gill netters before each of the last two meetings. Towards the end of the last meeting, one of the commercial fishers said something like, "we've wasted enough time, isn't it time to tell them how it's going to be?" Soon after his statement the DFW did just that. In recent years the gill net fishing started around mid September in Willapa Bay. In 2010 They received a so called "test fishery" with not many boats but quite a few dates. They got two full fleet openers in August just when the recreational season is beginning. They started their regular season about four days earlier than the recent average.
The DFW also required us to release all unmarked Chinook and coho. This is very frustrating, many anglers reported a 50% release rate. With Chinook, the naturally spawning and hatchery salmon are all the same stock. The native silvers that are scarce don't come in until nearly a month after the marine sport fishery is basically over. They required the gill netters to release the unmarked salmon also. Catch and release gill netting makes no sense. At the mortality rate they are assessed at, they wasted 940 kings and 9,544 silvers, then add the sport fishing mortality. This is an awful waste of food and I was told it was a disgusting sight, the dead salmon drifting down with the tide.
Westport spends a lot of money attracting us to this area. The DFW and the gill netters appear to be trying to get rid of us. The Department totally ignored the letter the Chamber sent last year. If this doesn't change there will be a constant decline in recreational fishing. I was told the South Bend launch was down about 50% last year, Tokeland was down too. Some members of the Legislature seem to have some leverage on the DFW. You probably know a lot more about that than I do. We do not want to take over, we just want what is fair for us and for the business community. I am sending a copy to the 19th District Legislators.
On the subject of South Grays Harbor, as you know a great Chinook sport fishery has been lost. It was good for us and for you. The DFW still allows a non tribal gill net Chinook mortality and they have allowed a sport fishing Chinook mortality with a coho fishery. With Tribal fishing, I wondered if you had tried talking directly to them. This could be of interest to sport and commercial fishers also. There is also the habitat destruction in the Chehalis headwaters. I really hope we can make some progress on all these problems.
This letter is to inform you of commercial salmon gillnet fishery regulations in Willapa Bay during 2014.
Please be aware that not all commercial fishing areas are open during each opener and that the area around the North River (see summary of schedule for a specific description of closed area) in area 2T is closed to fishing prior to 6:00 p.m. on September 30, 2014. Retention of sturgeon and steelhead is strictly prohibited. Encounters of sturgeon with tags of any sort should be reported. DO NOT REMOVE tags; carefully obtain and submit information from tags to the Washington Department of Fish and Wildlife, 48 Devonshire Rd., Montesano, WA 98563.
During all commercial fishing for salmon in Willapa Bay: - Commercial fishers MUST: o Have in their possession a WDFW-issued “fish Friendly” certification card. o Carry an on-board observer when requested by Washington Department of Fish and Wildlife (WDFW) to do so. o Report encounters of green sturgeon through the Quick Report system or to a dealer for reporting. Direct reporting by fishers shall include name of the fisher and vessel #, date, catch area, and number of green sturgeon encountered.
- Wholesale dealers and fishers retailing their fish MUST o Report purchases of salmon including all “take home” to WDFW by 10:00 A.M. of the day following the commercial landing. The quick reporting requirement does not preclude the obligation of buyers to report catches on fish tickets. A copy of the “Statewide Quick Reporting Summary Sheet” can be downloaded on our website at: http://wdfw.wa.gov/fishing/commercial/. Dealers should use the “buyer only” portion of the fish ticket to list the number of green sturgeon encountered with any landing and in the pounds/price columns label as ‘encountered’.
These regulations are subject to change based on in-season information. You are advised to verify schedules and regulations on the WDFW hotline at (360) 902-2500 or (360) 249-4628 before fishing. You may obtain a copy of the Washington Administrative Code (WAC) for this fishery at http://wdfw.wa.gov/about/regulations/2014/wsr_14-15-052.pdf .
This letter and other relevant information regarding this fishery are available on the WDFW website at http://wdfw.wa.gov/fishing/commercial/salmon/netting_schedules.html. For additional information or questions, please contact Barbara McClellan at (360) 249-1213 at the Region 6 Montesano office.
Summer Fishery (openers occurring between July 22 and August 15 annually): 6:00 a.m. August 12, 2014 through 6:00 p.m. August 15, 2014; Areas 2N, 2T (excluding North River closure area), and 2U ONLY. Retention of any species other than coho, Chinook, and chum is prohibited; 9-inch maximum mesh size.
Fall Fishery (openers occurring between August 16 and November 30 annually): Gear restrictions: - Openers occurring prior to 7:00 a.m. September 8 the maximum mesh size is 9 inches. - Openers occurring between 12:01 p.m. September 8 and November 30 the maximum mesh size is 6 ½ -inches. Area restrictions: - No openers will occur in areas 2K and 2P during 2014. - During the fall season no openers are scheduled in Areas 2M, 2R, and 2T until 6:00 p.m. September 15. - Area 2T north of a line from Toke Point channel marker 3 easterly through Willapa Harbor channel marker 13 (green), then northeasterly to the power transmission pole located at 46°43.1907'N; 123°50.83134'W), is closed to fishing prior to 6:00 p.m. September 30. - Each week from September 15 through October 3 Areas 2M, 2N, 2R, and 2T close at 6:00 p.m. Friday evening; each of these weeks 2U closes one day prior at 6:00 p.m. Thursday evening each week (September 18, September 25 and October 2).
Mark selective fishery and recovery box requirements: - From 12:01 p.m. September 8 through 12:00 p.m. (noon) September 22, 2014. o Soak time is limited to 45 minutes during any set. o Recovery boxes are required and must be operated when gear is being retrieved and when a wild (unmarked) Chinook or steelhead is being held to recover. o All wild (unmarked) Chinook and all steelhead MUST be placed in an operating recovery box and remain until they are not lethargic and not bleeding; ALL wild (unmarked) Chinook are required to be released. o Regulation Compliance Incentive Day, please be aware that an opening noon September 21 - noon September 22 may occur provided that compliance as accessed during previous days fishery openings exceeds 90%, this day will be implemented by e-rule.
Atlantic Salmon Wholesale dealers and fishers are asked to contact the Washington Department of Fish and Wildlife should Atlantic salmon be taken during any fishery in Washington waters. Please notify the appropriate WDFW staff member of when and where the fish was encountered or contact Fish Program in Olympia at (360) 902-2700.
2014 Summary of Willapa Bay Summer and Fall Commercial Gillnet Fisheries This summary sheet is provided as a courtesy for use as a quick reference and does not fully describe 2014 rules. For additional information or questions, contact Barbara McClellan at #360-249-1213 or Mike Scharpf at #360-249-1205.
The following are in effect for ALL commercial openers in Willapa Bay:
• Retention of STURGEON is PROHIBITED. ALL encounters MUST be reported to Wholesale Buyer or Quick Reporting • For QUICK REPORTING (by 10am the day following landing), NOTICE OF INTENT, and reporting GREEN STURGEON ENCOUNTERS: Fax 360-249-1229; telephone 1-866-791-1280; email harborfishtickets@dfw.wa.gov • Notice of Intent to fish any opener during 2014 is REQUIRED by August 5, 2014. • All participants MUST have attended a "Fish Friendly" best fishing practices workshop and have their department-issued certification card in their immediate possession. • Date and Time Area Mesh size stretched Requirements and gear restrictions: 6:00 AM, Aug. 12 through 6 PM, Aug. 15, 2014 2N, 2T (except those waters north of a line from Toke Point channel marker 3 easterly through Willapa Harbor channel marker 13 (green) then northeasterly to the power transmission pole located at 46° 43.1907’ N, 123° 50.83134’ W), and 2U 9-inch maximum
RELEASE STURGEON
7:00 PM, Aug. 25 through 7:00 AM, Aug. 26, 2014, 7:00 PM, Sept. 1 through 7:00 AM, Sept. 2, 2014, AND 7:00 PM, Sept. 7 through 7:00 AM, Sept. 8, 2014. 2N and 2U 9-inch maximum 7:00 PM, Sept. 8 through 7:00 AM, Sept. 9, 2014, 7:00 PM, Sept. 9 through 7:00 AM, Sept. 10, 2014, 7:00 PM, Sept. 10 through 7:00 AM, Sept. 11, 2014, AND 7:00 PM, Sept. 14 through 7:00 AM, Sept. 15, 2014. 2N and 2U 6 ½ -inch maximum RELEASE ALL WILD (UNMARKED) CHINOOK AND STURGEON
Live boxes are REQUIRED to be used on-board
Soak times are limited to 45 minutes (from gear entering the water until fully removed) Continued on next page
Date and Time Area Mesh size stretched Requirements and gear restrictions: 6:00 PM, Sept. 15 through 6:00 PM, Sept. 19, 2014, 2M, 2N, 2R, and 2T (except those waters north of a line from Toke Point channel marker 3 easterly through Willapa Harbor channel marker 13 (green) then northeasterly to the power transmission pole located at 46° 43.1907’ N, 123° 50.83134’ W) 6 ½ -inch maximum RELEASE ALL WILD (UNMARKED) CHINOOK AND STURGEON
Live boxes are REQUIRED to be used on-board
Soak times are limited to 45 minutes (from gear entering the water until fully removed) 6:00 PM, Sept. 15 through 6:00 PM, Sept. 18, 2014, 2U 6 ½ -inch maximum 6:00 PM, Sept. 22 through 6:00 PM, Sept. 26, 2014, AND 6:00 PM, Sept. 28 through 6:00 PM, Sept. 30, 2014 2M, 2N, 2R, and 2T (except those waters north of a line from Toke Point channel marker 3 easterly through Willapa Harbor channel marker 13 (green) then northeasterly to the power transmission pole located at 46° 43.1907’ N, 123° 50.83134’ W) 6 ½ -inch maximum
RELEASE STURGEON 6:00 PM, Sept. 22 through 6:00 PM, Sept. 25, 2014, AND 6:00 PM, Sept. 28 through 6:00 PM, Oct. 2, 2014
2U 6 ½ -inch maximum
RELEASE STURGEON
6:00 PM, Sept. 30 through 6:00 PM, Oct. 3, 2014, 2M, 2N, 2R, and 2T 6 ½ -inch maximum 6:00 PM, Oct. 4 through 6:00 PM, Oct. 7, 2014,
12 AM, Midnight, Nov. 2 through 11:59 PM, Nov. 7, 2014, 12 AM, Midnight, Nov. 10 through 11:59 PM, Nov. 14, 2014 AND 12 AM, Midnight, Nov. 17 through 11:59 PM, Nov. 19, 2014. 2M, 2N, 2R, 2T, and 2U 6 ½ -inch maximum
This issue is a very interesting. For many the thought that Director Anderson gives a preference to Commercial fishers is rather dominate. From the Commercial side I bet that view is not shared, to say the least. For my part I will take you back to the final North of Falcon at Olympia a couple years back. Region 6 District 17 utilized nearly 3 1/2 hours putting forth just what was possible and what was simply unattainable. Then Director Anderson came down from his office and set in a bit until we broke for lunch. Coming back into the meeting following lunch we were witness to staff pounding away on the lap top keyboard utilized to display the model and options on the wall. What happened next was a bit mind boggling as now what was not possible was possible and what was possible ( for the Recs ) was now not! This prompted one attendee to state in a rather load voice "it isn't safe to go to lunch around here!"
So did Director Anderson use his position to influence the outcome for the Commercial and Recs in Grays Harbor? Depends on your view as the Recs yup but no from the Commercials I imagine. It is the Directors role to guide WDF&W through processes but out of the public forum underway? Behind closed doors? Nah ain't buying that BS. Mr. Anderson is a knowledgeable man and if he has views he should state them openly, in a forthright manner to the ENTIRE group of folks in attendance. The failure of WDF&W to grasp that the lack of openness and transparency continues to erode the public's faith in WDF&W as a government institution. Frankly lack of openness and transparency helps drive WDF&W's lack of ability address the many challenges facing the users and resource itself.
Offhand these guys need to do a serious reboot if they have any desire regain the public's trust. The real question is do they give a damn?
The letter below is a response from Commission Chair Wecker who does appear to care and attempted to address the Advocacy's concerns about the Directors influence.
July 18, 2014 Twin Harbors Fish and Wildlife Advocacy PO Box 179 McCleary, WA 98557
Dear Sirs:
I am writing in response to your letter dated May 17, 2014. The gist of what you request is contained in this paragraph from your letter:
"This all leads us to the point where we ask for the support of the Commission. Again, not to adopt or oppose any particular season and, certainly not to micro‐manage. Rather, we simply ask that the members of the Commission use individual or combined influence to insure the public that the professional staff within Fish Program have the freedom to make the final decisions for a 2014 commercial season based on their combined professional judgment using the education and expertise they hold and to do so without fear of damage to their careers."
The Commission views its role in holding the Department accountable as one of its more important jobs. I have no evidence that Department staff have been unable to use their professional judgment due to "threat of damage to their careers." That said, I do understand that season setting in Willapa Bay has become increasingly contentious and likely will become more so. It is vital that the public have confidence that the Department is adhering to high standards of professionalism especially with respect to our conservation mandate.
This year, some changes have been proposed in setting the Willapa salmon fishing seasons. The Commission will not be able to thoroughly review Willapa fisheries management options until we begin our official consideration of the development of a policy for Willapa salmon management -- a process we expect to begin in October.
However, in the next couple weeks, I will have a conversation with the Director regarding the mechanisms that are in place to assure that staff can offer their best professional judgment in the decision-making process that leads to the setting of seasons in Willapa Bay.
Thank you again for your comments,
Miranda Wecker, Chair Washington Fish and Wildlife Commission
The information below is from Region 6 and the CR 102 Commercial Grays Harbor. A link is provided to WDF&W's website.
In an effort to reduce unnecessary printing costs and help protect our environment, we are asking those interested in viewing the CR-102 proposed WAC changes to access it electronically at the following web site, where it can be viewed or downloaded.
A public hearing will be held in accordance with RCW 34.05.325 at the Region 6 Montesano Office in the large conference room, 48 Devonshire Road, Montesano, WA 98563 on Tuesday, August 26, 2014.
Discussion times will be:
1:00 p.m. – 3:00 p.m. WAC 220-36-023 - Rules for commercial salmon fishing in Grays Harbor.
In case you are unable to or do not wish to attend the public hearing you may submit written comments to: Rules Coordinator via mail at: WDFW Enforcement 600 Capitol Way N., Olympia, WA 98501-1091, via e-mail: Rules.Coordinator@dfw.wa.gov or via fax: (360) 902-2155 by August 19, 2014.
If you would like an email copy or need a printed copy of the proposed rules, please send a request to: Rules.Coordinator@dfw.wa.gov or call (360) 902-2700.
In sorting a Public Document Request I happed upon this document. It is a summary of comments to the Commission from the public as the Commission developed the new plan. Some may find this to be Interesting reading and there is a wide range of thought to be sure.
11 January 2014
Summary of public comment regarding draft Grays Harbor Salmon Management Policy.
Included below are excerpts from written comment received between October 21, 2013 and January 9, 2014, and verbal testimony summarized from the December 7, 2013 Fish and Wildlife Commission meeting. Comments have not been edited for content or to correct spelling, grammar, or punctuation.
Comments were summarized into ten (10) categorizes including: allocation, alternative fishing practices, communication/transparency, conservation, data rigor, economic value, enforcement/accountability, hatcheries, limit effort, and miscellaneous.
Categories are collated by major reason for which the policy is needed (Enhance Conservation Focus, Restore and Maintain Public Trust, and Clarify Sharing of Impacts), followed by a section with remaining categories.
Enhance Conservation Focus
Conservation • The state wants to kill down to the last fish. We need to think about conservation. • Calculated in FRAM down to the last fish the bycatch to the last fish. • complete closures have been implemented before and the fish come back. It that is what it takes fine. It comes down to conservation. We need the fish in the gravel. • ESCAPEMENT GOALS and SALMON CONSERVATION must be the #1 Priority. Once the resource is gone, everyone loses. • Escapement ,We must meet escapement goals each and every year. This is imperative to the survival of the fish that swim and spawn in these waters. Any type or length of fishery should always be secondary. I am well aware that this could mean on lean years that we do not have a directed fishery by anyone and if that is what it takes then so be it. • It was abundantly clear from the vast majority of attendees that consevation of Grays Harbor wild salmon is their highest priority. Several topics were included within the conservation umbrella; opposition to the Chehalis River dam, ocean-derived nutrition, harvest management and more. • The state is driving to ESA. • As for Conservation, everyone needs to do their part. • My big thing is in-season management. I think conservation needs to be the top priority, even if it limits my opportunity to fish ensuring that over-forecasting doesn't have to result in overharvest, and subsequently missed escapements. • This fishery must have season checks and balances to ensure that we do not over harvest on any given year • Guiding Principles Item 14; When a mark-selective fishery occurs, the mark-selective fishery shall be implemented, monitored, and enforced in a manner designed to achieve the anticipated conservation benefits. Everytime the WDFW feels that the selective harvest is expected to impact fishery escapements goals, the fishery is shut down, but it's only shut down to sport fisherman and not tribal/commerical havesting. Escapement goals are not being met, yet we allow the tribal fisheries to run nets 7+ days a week which has a much greater impact on returning salmon than any sportsman catch.
• 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. • concerned about failure of Reg 6 management. Not making escapement. • Continuing to fail for the last 10 years. • Escapement goals are not being met. • for too many years too many fishermen taking too many fish. • Blatant overharvest by the QIN, particularly Chinook. Late coho and steelhead are in a similar state as Chinook. • Millions of dollars have been spent by tax payers and Logging companies to create more habitat yet WDFW has not increased any Escapement Goals, provided more fish to the gravel, increased wild populations, to match the third largest watershed on the Pacific Coast on the United States. I see some great opportunities to increase fish populations in this wild river system that is capable of providing a better future of this resource. • The people of our state have invested a lot in enhancing habitat for salmon yet Region 6 has been content to leave goals low and then seldom meet them. In a region which has been satisfied and enjoyed management job security while missing escapement goals for Gray's Harbor and Willapa Bay 9/10 of the time, a culture change would be needed. • 30 years of experience in the legislative projects. I have worked on habitat recovery and still no fish in Wildcat Creek. • Unfortunately, too little time was provided for indepth discussion regarding policies to achieve wild salmon recovery in Grays Harbor and its tributaries - far too much time was again consumed for allocation discussions • If you are concentrating on the escapement maybe you should start in the ocean fishery. You don’t want to admit to the amount of fish you are allowing to be killed in the “catch ten and release to keep one fishery”. • Article about Alaska Kenai Salmon - "Catch and release practices prevent many salmon from reaching a spawning location or result in poor spawning success." • For the recreational fishery in Grays Harbor I would like you to consider the following: Any year there are not enough chinook to have a retention fishery that area 2.2 from the Chehalis River bridge (highway 101) to the mouth of Johns River (piling number 8) be closed to all fishing before the first of October. This is needed to save chinook salmon from over harvest via hook and release. Large numbers of fishers show up to see how many chinook they can catch in one day even though they release them. One fisher bragged to me they caught 17 chinooks in one day when it was non retention only. • The spring chinook fishery is a joke. The only reason the tribe fishes for spring chinook is to harvest wild steelhead that are returning. This practice need to STOP! • If CTRC is the non-treaty tribes then this draft does not allow a non-treaty spring Chinook fishery in the Chehalis River system. I support no non-treaty tribal fishing for spring Chinook in Grays Harbor and the Chehalis river system. • Another issue I have is why is ANY spring salmon fishery of any kind allowed on the Chehalis River system?
Limit effort • I would like to state for the record that I believe that until you curtail the tribal fishery it will be of little use to keep restricting the non tribal fishers. • One partial solution is to LIMIT GUIDES AND CHARTER OPERATORS TO A SINGLE TRIP PER DAY. It would probably be prudent to have logbooks for guides to get a more accurate reporting of the true catches for salmon, sturgeon, steelhead and walleye. • A quicker and more effective option would be to use a “drawing” similar to elk harvesting wherein a preset number of license holders will be granted the ability to fish in the upcoming season. While the number of fishers active each season would decrease, establishing a drawing avoids seasons where all the participants suffer when sales of fish caught “….didn’t cover the cost of the diesel”. • for too many years too many fishermen taking too many fish.
Alternative fishing practices • We must require sustainable forms of fishing. Currently Recreational fisherman utilize barbless hooks and selective or non-selective fishing as a means of ensuring the right fish are taken at the right times. Entanglement nets are not a sustainable fishing method. • Make everyone even that's commercial fishermen go back to hook and line • Following the example set in harvesting razor clams, crab, and shrimp, we propose that WDFW consider establishing commercial seasons wherein recreational and commercial license holders harvest with the same gear (poles), in the same geographical areas and at the same time throughout the entire season. License fees and bag limits could be adjusted as well. One example would be a commercial license at three times the recreational license and the commercial bag limit at three times the recreational in a corresponding fashion.
Restore and Maintain Public Trust
Communication/ Transparency • The Grays Hbr. Advisory Committee, WDFW Fish biologists, and GH gill net assoc. should be on record as to their method, data and tools used to recommend the catch sharing percentages for each sector outlined in this "draft". I would like to see fishery decisions in Washington State made on biologically sound information. It appears that political influence now dictates many decisions made by WDFW. • The public needs to be informed that the catch allowed by the non-treaty Chehalis Tribe(s) comes out of the recreational sector. If the category designated as CTCR in the charts is the non- treaty Chehalis Tribe(s), it needs to be designated as such in the draft policy. Non-treaty catch quota should not be taken from the recreational sector. How can WDFW give the non-treaty Chehalis Tribe(s) a catch percentage when they provide no catch figures to WDFW? My recommendation is "no catch figures", "no fishing". • The Director and the Region need to bring co-management back to Grays Harbor. • We need to talk about the QIN. They overharvest year after year. Then tell the state what they are going to do without any say from the state. WDFW needs to take them to court. • There is no co-management in Grays Harbor. If the state is not fishing then the tribe will. • WDFW needs to include previous run estimates, escapement goals and final catch statistics for each sector to determine an equitable catch percentage. The percentages "proposed in the draft" , for each sector have no meaning without inclusion of above mentioned data from previous years. The percentages outlined in the draft are meaningless w/o previous data. • Overall the GH management plan is too vague and unclear. It is good to see a committment for an annual review but there is little mention of metrics against which performance would be measured by the commission. This is a region that has regularly underperformed on escapement goals for multiple species for over a decade. • The current draft does not have specificity. What we are looking for in the policy are deadlines and goals. • These guidelines are only a tweaking of the current guidelines. In Willapa there are no co-managers – even with no co-managers the results are the same. Guiding principles, communicate, document, etc. these are not principals they are window dressing. • I offered comment, those are not in the policy; asked for teeth in the policy they are not there either. • Comments about communication – with the internet, communication is easy. With short notice through the internet look at all the people who are here. • Thirdly, All participants in this fishery must meet their obligations to be involved in the process of season setting and ensure that their numbers and dates are published in the proper manner. • I want to see the Public more involved in the WAC process before North of Falcon. This process has only involved a fee people invited by WDFW. The Commercial Fleet has dominated this process for many years with WDFW supporting them over Conservation. The Tribes are also part of the Commercial harvest and should be regulated in the same process instead of WDFW letting them do what they want.
• The APA process is not being followed. I have spent $10K’s of my money bringing lawsuits against WDFW, and have 1000’s of hours of time invested. The public trust is lost. Kehoe, you said for us to write the document, we did that. None of that is in this document. Don’t close the door or your mind on this. • far too much time was again consumed for allocation discussions… it amounts to nothing more than a wishing session between the gillnetters and the sporties.
Data Rigor • The tools the department has is like a butter knife. The first improvement needed is the CRC. Like to see timelier reporting like in the PS crab CRC. Adaptive management, like in PS, monitor the fishery more closely and shut the fishery down when the quota is reached. Need a policy that passes fish to the spawning beds. There is no co- management in Grays Harbor. If the state is not fishing then the tribe will. • Region 6, forecasts runs before fish hit the hatchery; need to let the fish hit the hatchery then forecast. I fish the Skookumchuck and have seen the enhancements. • needs to be a framework for in-season management, ensuring that over-forecasting doesn't have to result in overharvest, and subsequently missed escapements. • Science and biology should drive management. • Calculated in FRAM down to the last fish the bycatch to the last fish. Then set the season in days. The mortality percentages - 45% is not in the Columbia studies. The study is only long-term, where is the short term? Other studies should be reviewed. • The current Management plan and models for the Chehalis Basin and Willapa Basin are not acceptable anymore and out dated. Millions of dollars have been spent by tax payers and Logging companies to create more habitat yet WDFW has not increased any Escapement Goals, provided more fish to the gravel, increased wild populations, to match the third largest watershed on the Pacific Coast on the United States.
Enforcement /accountability • The sports fisherman are getting more and more of the allocation every season. The sports fishers are not being held accountable for their catches as we the commercial fisheries are being held accountable for every fish harvested. • Anglers on guide trips would also furnish license numbers to the guide to record days fished and actual catches to avoid cheating on the annual limits.Daily recording in the logbook should be mandatory and all entries should be made within 24 hours of the trip completion. Alaska uses this system but when boat launch areas are super busy then it is easy to forget to complete the log on site and a 24 hour allowance for recording final catch info would be fair. AK imposed fines for non completion on site and that was strictly a revenue operation and lead to many confrontations between guides and enforcement personnel. • Selective fishing if its going to happen it needs to follow scientifically designed procedures and protocols. In Grays Harbor they violate all internationally recognized rules. • They need to fish selectively like they have been trained. • It was also made clear that there is considerable support for increasing the number of WDFW enforcement officers in order to maximise conservation efforts to recover Grays Harbor wild salmon • there is considerable support for increasing the number of WDFW enforcement officers in order to maximise conservation efforts to recover Grays Harbor wild salmon. • The public needs to be informed that the catch allowed by the non-treaty Chehalis Tribe(s) comes out of the recreational sector. If the category designated as CTCR in the charts is the non- treaty Chehalis Tribe(s), it needs to be designated as such in the draft policy. Non-treaty catch quota should not be taken from the recreational sector. How can WDFW give the non-treaty Chehalis Tribe(s) a catch percentage when they provide no catch figures to WDFW? My recommendation is "no catch figures", "no fishing". • We need to monitor the Quinault’s and take them to court.
Clarify Sharing of Impacts
Allocation • 77,000 people sport fish salmon in the state of Washington (1.1%); the commercial fishers provide fish to the rest of the state. Allocation should be 50:50 on all species. • In the survey the sports zeroed out commercial allocation. Sport have lots of opportunity statewide. • I fully support the non-treaty commercial salmon fishing in Grays Harbor. Generations of families in Grays Harbor have been supported by the salmon gilnetting season - I strongly encourage you to consider those families - it's very important to them. • I have been a gillnetter for over forty years. In the 70s we would get to fish from the 6th of July till sometime in November. The fleet of boats was over four times what it is today. We had a very valuble sport fishery during those times also. • I support the non-tribal commercial salmon fishery in Grays Harbor. The non-tribal commercial salmon fishery is vital to many families in our area. Please keep this is mind when determining future allotment of our resources. • There are other fisheries in GH, we need to be mindful of the share that comes to the state. That is the portion that should be fairly distributed to sport and commercial fisheries. The sports emphasize that there are two fisheries; sport and commercial - and that commercial include the tribes. • The sports fisherman are getting more and more of the allocation every season. The sports fishers are not being held accountable for their catches as we the commercial fisheries are being held accountable for every fish harvested. Washington gives the tribal fishers 58% of the allocation. Start there. The commercial catch is nominal compared to the tribal and the sports fishers • The Chehalis side should have a small amount of Chinook set aside for the commercial to access to coho. There are large surplus of coho – hatchery and natural both. • Divide the catches of Chinook equally between the recreationals and gillnetters for wild chinook. Since wild coho has been the run of concern for the last several years they will be used as incidentals during chinook and chum fisheries. Impacts to be used when run size is below escapement goal will be divided 60% gillnetters and 40% recreationals. The only exception to this is if the run size is 156% greater than the escapement goal then there could be a directed wild coho fishery divided 60% recreationals and 40% gillnetters. Between 110% and 156% of escapement goal the wild coho will be divided 60% recreational and 40% gillnetters. Hatchery chinook and hatchery coho will be taken during other Humptulips fisheries. • The goals for recreational fishing involving "experience" or "opportunity" are inappropriate. We are already seeing this concept being abusedd in plans for alternative gear elsewhere in the Columbia. OR officials are talking about closing sport fishing during peaks of runs to allow enough mark selective commercial harvest using purse seines! Sports not to worry, you will get extra days during off peak run times. Seines get the harvest, sports get the "experince" of more fishing with less opportunity per day. This is how sports fishing is to be minimized, along with its superior econiomic benefits. The draft guidelines need to be changed to prevent this approach in Region 6. • They should not be fishing more than 3 days / week. They are taking huge sections out of the run. • the commercial gill nets should be in the water one day less than what it was this year. Ive been keeping an eye on the nets in the river because I drive over the Chehalis river bridge in Aberdeen every day and have seen nets in the river, either commercial or native american, 5 days a week. That is unacceptable for recreational fishing because when they take the nets out on Friday, it takes a while for those fish can get through to get up the river to where bank fisherman can have some fun and try and catch some salmon to allay the exorbitant cost for the license. I have no problem paying the license cost but expect the recreational fishery to be given more emphasis. • One good thing is to allow 3 d/wk without nets. Need a change in the current conscious approach. End of year review – compared to what? Need more in the policy. • Support 3 days/week proposal for net free.
• The 3 day proposal for net free; what does that mean? The treaty fishery is already fishing 4 days/week, does this leave the NT fleet sitting on the beach? • The rec option offered 3 days sport and 4 days commercial. The Commercial won’t offer a compromise. Recreation is willing to have days on and days off. • Tribal and commerical netting should only be allowed on a Sun (1200) - Thursday (1200) during the fishery. If the catch goals are not met, extensions or additional netting days can be addressed and granted, but only after escapement data is reviewed. • I want to see the Public more involved in the WAC process before North of Falcon. This process has only involved a fee people invited by WDFW. The Commercial Fleet has dominated this process for many years with WDFW supporting them over Conservation. The Tribes are also part of the Commercial harvest and should be regulated in the same process instead of WDFW letting them do what they want. • Similarly, it was very clear that future, non-treaty salmon harvests should be guided by the greatest benefit to cost ratio - from the data shared this evening it seems that recreational fishing accounts for far greater revenue to Washington state than does the commercial sector. • 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. • The QIN fishery represents more than a meaningful commercial opportunity, and it should be the only one they are obligated to allow. I would like to state for the record that I believe that until you curtail the tribal fishery it will be of little use to keep restricting the non tribal fishers. • Commercial netting should be stopped immediately within Grays Harbor and its tributaries. This is an outdated practice that is not sustainable today in this location due to overharvest and impacts on sensitive species as it does not allow of selective release listed groups of fish. Addtionally there is not the abundance of fish in Grays Harbor that allow this practice to continue. The economic benefit of having a strong sport fishery in Grays harbor and its tributaries far out weigh the small benefit that harvesting the remaining fish by commercial fisherman • The public has repeatedly stated that a tribal net or a non-tribal net is a commercial net under state law. The legislative mandate of the Commission and department states, "The department shall promote orderly fisheries and shall enhance and improve recreational and commercial fishing in this state." (RCW 77.04.012). You will notice the law does not require the Department to provide three commercial fishing opportunities based on tribal affiliation. The attached AGO shows the Attorney General was asked if a non-tribal commercial fisherman who opted to take the buyout could sell the boat back to a tribal fisherman. The AG opined that a tribal fisherman was a commercial fisherman under state law and such could not be done. Since the Chehalis and the Quinault commercial fishing takes approximately 58% of the available harvest in Grays Harbor, the mandate is fulfilled without the Department imposing yet another third commercial fishery. • The inland community does not perceive a difference between the commercials. This ain’t Mobile Alabama 1963 the state needs to get over it, the tribes have the right to take their fish. • Steady decline in the Chehalis. You see that there are two different gillnets, this is one fishery. We are fishing behind all these nets. There should be a focus on one netting season – 60:40 commercial. • Two fishing interests – rec and commercial. Both interests desire the maximum allotted to them. The commercials scoop hundreds, the recs use one hook, and can only keep two. • Economics we important, look at where the money comes from; you are supporting a welfare system for the GH commercial fleet. • Allocation should be developed on science not public opinion. It needs to be understood that nets are not in the water 24hrs / day, the fish get through. Sound fishery science.
Other
Economic value • Commercial value does not account for 1000’s of coho that go un-harvested. • Increasing the sales price of the fish harvested commercially would provide compensation for the reduced harvest volume. WDFW should consider eliminating the would allow the commercial license holders the ability to market the fish caught at retail (i.e.commercially in its seasons in Grays Harbor be sold at wholesale to a licensed fish buyer. This requirement that fish caught “Fresh Tuna” on the dock in Westport, fresh salmon at the farmer’s market in Olympia, etc.). • I'm a sportfishing guide based out of Olympia. I spend the majority of my days fishing in the Chehalis Basin. A dependable season would make my job much easier. I can book trips without fear of in season shutdowns. • I look at things in terms of money. Are you getting your numbers up? That is an investment. If we are not getting fish back then why are we spending the money? • The economic benefit of having a strong sport fishery in Grays harbor and its tributaries far out weigh the small benefit that harvesting the remaining fish by commercial fisherman. • Also, the economic impacts do help the local economy in a big way My clients, for a two person trip pay me around $175 a person for a days fishing. Many people come from out of the area, spending money on motels, dinner, lunch and assorted other items plus licensing. This benefits many in the local area. I also try and buy my supplies locally as well as fuel and my licensing. Thanks for taking this into account when looking at fishings impacts to the local economy. • recreational fishery has more economic value than the commercial fishery (at least that is what your data suggests even though you say that it is not comparable to commercial data), that the commercial gill nets should be in the water one day less than what it was this year. • it was very clear that future, non-treaty salmon harvests should be guided by the greatest benefit to cost ratio - from the data shared this evening it seems that recreational fishing accounts for far greater revenue to Washington state than does the commercial sector • Economics we important, look at where the money comes from; you are supporting a welfare system for the GH commercial fleet. • I am writing to express my interest in the Grays Harbor non treaty gillnet fishery. South Bend Products purchases a large percentage of the harvested fish from Grays Harbor. The fishery produces high quality fish that are marketed throughout the country. Please consider the fact that in addition the income the fishery provides to the fisherman, it provides jobs to on- site buyers and crew, truck drivers, plant workers and office staff. Reduction or elimination of the non-treaty fishery is a reduction of jobs in Gray’s Harbor and Pacific Counties. I would appreciate your consideration of maintaining the non treaty fishing opportunities in Gray’s Harbor. • The GN licenses actively used are about 50% of those sold. You could cut that by 50% again and you might have viable fishery. • late 1970-80’s commercial buyback. The commission mandate in state law is to maintain the viability of the fishing industry. • sport fishery $1.5M, in current dollars is close to $2M.
Hatcheries • We also need to restore the hatchery production that has been lost. • Also you have to fertilize the River you have to put the salmon carcasses back in the River to fertilize the River, most of the rivers are stale and dead now because they have not had the salmon carcasses that the bugs need to feed on. Let's revive the rivers. Then also put as many fish in the River as possible. Then it would make no difference whether it was a hatchery fish are wild spawned fish it would be in the River and you'd have as many fish as you need.
• As for the hatchery's put the hatchery's at full speed raise as many fish as possible get them in the River, it doesn't have to be a year later after they have attached, put them in immediately. • enhancing the Salmon returning to Grays Harbor. I only see maintaining what we have now.
Miscellaneous • Neither current escapement goal methodology nor eelgrass management practices by WDFW take into account the natural carrying capacity of these bays • Region 6 has been content to leave goals low and then seldom meet them. In a region which has been satisfied and enjoyed management job security while missing escapement goals for Gray's Harbor and Willapa Bay 9/10 of the time, a culture change would be needed.
As the fall salmon season grows near many have questions around the issue if they will see positive change and equity for inriver sports fishers. Yes but just how is dependent upon the fish, weather, and the rivers natural processes. ( flows / temperature, ect. ) So we wait and in the not to distant future it will play out. So rather than babble on and confuse many ( most including myself ) as the various directives in the new Grays Harbor Management Plan ( GHMP ) play out we will explain how the guidelines effect Recreational Fishers as the 2014 Fall Salmon season unfolds.
So has the implementation of the Grays Harbor Management Plan ( GHMP ) been a success? From a Non Treaty Commercial Gillnetter perspective I imagine the word terrible comes to mind. From my perspective it has been a tough go but I think yes is the answer. Do issues still exist that need to be addressed? Oh yeah but a good management plan should not only set direction but bring issues forth that need further review.
This exactly what has happened. In my letter to the Commission below I have outlined several issues that for so many years WDF&W simply refused to address and simply ignored them. So now folks we will watch the process unfold as for the first time in decade WDF&W will have to address these issues in public at the Commission level.
It is going to be interesting watch play out to say the least! My thoughts on issues at the moment are outlined in the letter below.
Dear Commissioners,
The months since the Commission adopted the new Grays Harbor Management Plan ( GHMP ) have been interesting, to say the least. While citizen views are diverse as to the success of the GHMP mine are simple, " it has been 100% successful". Why one may ask? The answer is simple enough. A management plan should not just provide a framework for harvest and set standards to be reached but through utilization of management framework identify issues that require further review. This is exactly what has happened in the implementation of the GHMP again this is not a failure Commissioners but rather a success!
In the adoption of the plan it was made clear by the Commissioners to all the citizens and organizations participating that this was going to be difficult journey as the conservation driven GHMP was implemented. I can say with certainty that has been the case.
In addition the Commission committed to review of the plan to address issues arising from the implementation of the new GHMP. With that in mind Commissioners I wish to bring forth three issues that I feel need to be addressed in the review.
ITEM 1: Humptulips Natural Origin Coho ( NOR )
The Humptulips NOR Coho have not made escapement for 23 consecutive years that I have documentation of and several agency staff believe this is the case since the Humptulips Hatchery began operation. To compound the problem the Hatchery Origin Recruits ( HOR ) Coho numbers spawning went as high as four HOR Coho for every one Natural Origin Recruits ( NOR ) Coho spawning. This year before any harvest the Humptulips NOR Coho would not make escapement even without harvest.
We have been told that the Quinault Indian Nation ( QIN ) sees no issue with this as the combination of NOR and HOR spawning in the gravel combined to make escapement is acceptable. One could reject this position rather easily except there is justification for their position and it exist in the East Fork Satsop River. In the 1990's local volunteers assumed operation of a closed WDF&W facility Satsop Springs and developed programs broodstocking to rebuild Chinook & Chum stocks. Brood is taken, spawned & reared an released on site into river. The returning HOR adults spawn with the NOR adults and broodstocking is utilized to minimize any reuse HOR adults in the egg take.
So how is the issue of Humptulips NOR Coho different from EF Satsop NOR Chinook and Chum? Both are integrated stocks, in fact with the Humptulips HOR staying rates so high for so many years I would venture a guess that the Humptulips Coho hatchery Coho are exactly the same genetically as the NOR spawning Coho. If not for the Chum supplementation by HOR adults it is doubtful EF Satsop Chum would make escapement minus supplementation one generation out and most definitely not two life cycles. I believe that Humptulips NOR Coho need to be high on the review list if not the primary issue.
ITEM 2: Dual Management
We have been told that the QIN has the position that US v Washington ( and other court decisions ) gives them the right to 50% of the harvestable salmonids entering Grays Harbor. That the 50% is applicable to total of streams that enter Grays Harbor. WDF&W on the other hand separate the Humptulips and manage it independent of the bay tributaries and Chehalis River. This results in the model many times ( most ) showing over harvest of either a Chehalis or Humptulips stock. Prior to separating the Humptulips from the Chehalis Basins both WDF&W had the same management plan. It can be said that when both had the same plan it seemed that there was less turmoil.
Additionally we have been told that the QIN asked the question "do the proposed 2014 QIN Commercial seasons violate any court agreed to escapement goals?" To which WDF&W staff responded "no". If the QIN position is correct we have a issue that needs resolution. In my mind the harvest rights of the QIN are court mandated and unchallengeable. So what to do? Model Non Treaty fisheries around the QIN seasons? Continue to move forward and hope the QIN recognizes the validity of the GHMP? Simply put Commissioners this is a co mangers issue and one that citizens can not have much influence on. This is dual management not co management, goes hand and hand with item 1, and needs to be reviewed.
ITEM 3: Wynoochee Mitigation:
Myself, Joe XXXX, and Bill XXXX have been working with Jim Scott, Steve Theisfeld and Region 6 staff to develop a plan to fulfill WDF&W's Wynoochee Mitigation obligations by the end of September as the Commission directed. It was our view that after over two decades of failing to move the Wynoochee Mitigation issue forward it would be difficult but doable. Simply put Commissioners yes we still feel it is doable. As to difficult? That is a understatement of the first order. We believe the task can be completed but I would venture a guess that the issues may push our efforts up against the deadline. Hopefully not but both agency staff and ourselves are attempting to meet the Commission's expectations.
Additional Thoughts 4/3:
One item that will unfold in the next few months is the benefit of the GHMP directive of three consecutive days net free ( 4/3 ). In a recent weeks some have lamented that much of the gains from 4/3 will go to the QIN fishers so 4/3 is a failure. This commissioners is just plain wrong. ANYONE who fishes in river above Aberdeen will benefit greatly. Does this means the QIN set net fishers who fish the tide water reach benefit? In a word yes as the returning salmon will not always clear this reach of the river in three days. While the QIN may gain some benefit the Recreational fishers and the fish itself will reap the greatest benefit.
When one considers that for a decade or more Region 6 utilized the preseason run forecast for inriver recreational fisheries rather than what remained after bay recreational, QIN harvest, and Non Treaty Commercial resulting in inriver recreational fishers only getting approximately half of the season they were entitled to. Frankly Commissioners this whining by those who now must face the issue of equitable distribution of harvest and have been the benefactors of the past practices by Region 6 staff.
In closing let me say again I regard the New GHMP introduction as a huge success. That many in Conservation, Sport, or Commercial camps may disagree depending on their perspective is a given. From my perspective the issues outlined in this correspondence have been present and known for many years by few. The GHMP ended that and required that WDF&W Region 6, QIN, citizens, and user groups address these issues. I, for one, sincerely appreciate the Commissions courage and effort to chart direction for managing Grays Harbor fisheries in a manner that guarantees protection of not just the fish but future generations of harvesters.
In the past weeks I have received questions regarding the Grays Harbor Management Plan ( GHMP ) and just what are a citizens' rights if WDF&W violates the policies put forth by the Commission? One has the right to object to WDF&W in writing from the Director down through the layers of staff. You can also write the Commission and attend Commission meetings and address the issue in the " Public Comment " period of a Commission meeting.
Well and good many feel but that really does not require that WDF&W truthfully and completely address a citizens' concerns. Correct to a point and the Washington State Legislature addressed this by passing the RCW below. ANY citizen who feels that WDF&W has violated a Commission Policy can utilize section two of the RCW below. At the absolute least they have to respond in writing minus the usual smoke & mirror routine. The most you can expect? That the policy is put though the legal process and becomes law which is different than " advisory " as the current GHMP passed by the Commission. WDF&W violate the law and a citizen ( or organization ) can seek to have the courts enforce the law. The legal standards are much different than advisory guidelines the Commission adopts.
RCW 34.05.230 Interpretive and policy statements.
(1) An agency is encouraged to advise the public of its current opinions, approaches, and likely courses of action by means of interpretive or policy statements. Current interpretive and policy statements are advisory only. To better inform and involve the public, an agency is encouraged to convert long-standing interpretive and policy statements into rules.
(2) A person may petition an agency requesting the conversion of interpretive and policy statements into rules. Upon submission, the agency shall notify the joint administrative rules review committee of the petition. Within sixty days after submission of a petition, the agency shall either deny the petition in writing, stating its reasons for the denial, or initiate rule-making proceedings in accordance with this chapter.
(3) Each agency shall maintain a roster of interested persons, consisting of persons who have requested in writing to be notified of all interpretive and policy statements issued by that agency. Each agency shall update the roster periodically and eliminate persons who do not indicate a desire to continue on the roster. Whenever an agency issues an interpretive or policy statement, it shall send a copy of the statement to each person listed on the roster. The agency may charge a nominal fee to the interested person for this service.
(4) Whenever an agency issues an interpretive or policy statement, it shall submit to the code reviser for publication in the Washington State Register a statement describing the subject matter of the interpretive or policy statement, and listing the person at the agency from whom a copy of the interpretive or policy statement may be obtained. [2004 c 31 § 3; 2001 c 25 § 1; 1997 c 409 § 202; 1996 c 206 § 12; 1995 c 403 § 702; 1988 c 288 § 203.] Notes: Part headings -- Severability -- 1997 c 409: See notes following RCW 43.22.051. Findings -- 1996 c 206: See note following RCW 43.05.030. Findings -- Short title -- Intent -- 1995 c 403: See note following RCW 34.05.328. Part headings not law -- Severability -- 1995 c 403: See RCW 43.05.903 and 43.05.904.
Well yesterday was interesting! The Director resigned, the first budget proposal was presented and the Thurston County Court just upheld the lower decision in which the Puget Sound Harvesters Association (gillnetters) argued the 2012 commercial season in Puget Sound was illegal as it did not provide gillnets the same opportunity to fish as purse seiners. The court found that the Department's position that the non-selective nature of gillnets that had higher mortality for bycatch than seines was justification for refusing the gillnetter's request for more fishing opportunity when it passed the season regulation. All in all the total of all three made for a really really bad day for commercial salmon harvesters.
If you want a copy of the decision just PM me and I will get it to you. The budget draft is running in another thread so take a look.
So, the court said a non-selective gear can, when selectivity is needed, be given less time and fish. Wonder how that would play in Federal Court since fishing gear used (I believe) is a personal choice and not a genetic requirement.
That's covered in the opinion. The court (it was actually the state court of appeals upholding Thurston County Superior) held that the gillnetters did not have an equal protection claim under the state or federal constitutions.
Well yesterday was interesting! The Director resigned, the first budget proposal was presented and the Thurston County Court just upheld the lower decision in which the Puget Sound Harvesters Association (gillnetters) argued the 2012 commercial season in Puget Sound was illegal as it did not provide gillnets the same opportunity to fish as purse seiners. The court found that the Department's position that the non-selective nature of gillnets that had higher mortality for bycatch than seines was justification for refusing the gillnetter's request for more fishing opportunity when it passed the season regulation. All in all the total of all three made for a really really bad day for commercial salmon harvesters.
If you want a copy of the decision just PM me and I will get it to you. The budget draft is running in another thread so take a look.
Well yesterday was interesting! The Director resigned, the first budget proposal was presented and the Thurston County Court just upheld the lower decision in which the Puget Sound Harvesters Association (gillnetters) argued the 2012 commercial season in Puget Sound was illegal as it did not provide gillnets the same opportunity to fish as purse seiners. The court found that the Department's position that the non-selective nature of gillnets that had higher mortality for bycatch than seines was justification for refusing the gillnetter's request for more fishing opportunity when it passed the season regulation. All in all the total of all three made for a really really bad day for commercial salmon harvesters.
Recently WDF&W provided documents regarding the recent reduction in Natural Origin Recruits ( NOR / Wild ) Chinook for streams entering Grays Harbor approved by PFMC. Boiled down this is for the Humptulips and Chehalis Basins and is for the accumulative total of both. WDF&W's position and Commission directive that separates the Humptulips and Chehalis Basins for harvest has not been recognized by the Quinault Nation so we have a issue that needs resolution. Dry reading to be sure but for those that choose to monitor the scientific rational for decisions that effect the salmon resource in Grays Harbor the documents are informative. One thing about it is that the reduction was not conservation driven but rather established a new Maximum Sustained Yield ( MSY ) for Chinook stocks. As the PFMC document is rather long I cannot post it up so if anyone wants a copy PM me and I will send it on to you.
I received the comments below on the QIN proposal and PFMC reduction for the Grays Harbor Chinook escapement goal. I found the comments to be very interesting and well thought out.
There is so much about this issue, and as it pertains across all species. First, it will be very difficult to directly challenge the analysis. There are established methods and they will be used. Consequently, the answer they get is mathematically defensible. Rather, there is a philosophy that needs to be discussed by WDFW. The following questions need to be dealt with, but ultimately it is a policy choice. And since QIN wants a lower goal.
1. The EDT analysis that CBFTF had done for Grays Harbor identified 12, 692,956 square metres of Fall Chinook spawning area. Giving a pair of Chinook 100 square metres (way more than necessary) gives you 126,930 redds, or 250K+ fish just to use all the habitat. Specifically ask why WDFW does not plan to utilize the available spawning area.
2. If WDFW/QIN choose not to utilize the spawning area (a policy choice) will they identify the non-used areas and direct WDFW-Habitat that HPA's not condition applications for Chinook protection.
3. For Puget Sound chum, WDFW set an escapement goal (purportedly MSY) in the late 1970s. In the 1980s and 90s escapements were significantly higher. In at least one case an order of magnitude. When Ricker curves were run on the wild stocks, in each and every case, the "MSY" goal that was calculated was higher. The goals were left unchanged. The point is that significant increase in escapement can increase MSY.
4. Need to realize that MSY is a somewhat ephemeral concept. Ford Arm coho, in SE AK, is managed at a constant 60% exploitation rate. Because of changes in stream productivity brought about by pink spawners the harvest of fish has ranged from 1,000 to 8,000. At no pinks, the 1,000 catch and approx. 600 spawners was "MSY". At 2 kg per square metre pinks they had 5-8,000 harvest and escapements of 3-5,000 spawners. Again, MSY. So, I would insist that rather than calling whatever they come up with "MSY" that they call it some sort of "sustainable escapement goal".
5. The escapement goal they come up with is only as good as the data. Especially the range of data. If all of the escapements that they look at are (say) under 10,000 then there is no way they will call 250K as MSY. It is terminology and this is a good place to start.
Steve Thiesfeld asked that we spread the word on the opener today.
Good morning everyone,
I’ve heard some rumors that the local paper indicated that marine area 2-2 opened this morning. Just a reminder, the only part of area 2-2 that opened today is the part north of Sand Island towards the Humptulips River. The Chehalis River also opened above Highway 101. All other areas are still closed.
Please help spread the word.
Thanks.
Steve Thiesfeld Washington Department of Fish and Wildlife Region 6 Fish Program Manager 48 Devonshire Road, Montesano, WA 98563 Steven.Thiesfeld@dfw.wa.gov 360-249-1201
The link is to WDF&W Commercial landings for Willapa. The news is 3240 Chinook / 248 Coho which is the best commercial dip in fishery in recent years. Couple that with the screaming that the gillnetters put forth that they were not getting opportunity one must wonder what reality they live in.
Just so all know with out getting myself shot, Willapa is heating up. It appears by Commercial landings that a bunch of fish showed in the last day & a half of the three day dip in fishery. From reports it appears they are still building up but still a lot of Columbia fish in 2T yet and as they peel out the Willapa fish arriving will fill the void. Enjoy guys and it is long overdue!
Well in Grays Harbor no news as to how WDF&W matches up the requirements of the Grays harbor Management Plan and the proposed net seasons. The issue of the Humptulips Wild Coho not making escapement for 23 years is going to come home with a bit of drama somewhere before the Commercial CR 103 is filed. How bad off are we? I do not know as Region 6 has not released the 2014 Harvest Model fully functioning. Yes we have the model but the Summary Tab which allows you to see the impact of all the fisheries has been locked up. ( not useable ) What is known is there is no way no how NOR Humtulips Coho ( wild ) will make escapement before any harvest QIN or Non Treaty. So we have a problem as the GHMP directs that harvest be set with the intent of making escapement.
This guys is a complex issue that with the new GHMP cannot be ignored as WDF&W did for nearly 30 years. The best description I have seen is " WDF&W screwed the pooch so long that there is going to hell to pay". This issue has been right out in the open but most have not taken the time to get their arms around the issue. That the Rec WAC is in place is true but not the Commercial and both can be modified. The Commercial CR 103 is still to come and it is a simple Emergency Rule on the Rec side to change things. So as I have posted before that Grays Harbor has a really big issue and it resides in the Humptulips NOR Coho. ( wild spawners )
This dance is going to be interesting to watch play out as there is not a pain free way out, only varying degrees of pain.
The following is a C&P of a article from the Olympian. Pretty much lays out the issue on culvert repair mandated by the courts. This budget dance for the coming biennium is going to be a dance for the ages!
The Olympian:
Imagine you are driving on the freeway, returning from a long trip, longing with all your heart just to be home. Suddenly you are forced to a complete stop because the freeway is broken and you are facing a 10-foot cliff. There’s no way forward, and as cars pile up behind you, no way back.
That’s pretty close to what a salmon experiences when, returning to its native stream from its long journey out to sea, it confronts an impassable culvert under a highway. Every cell in its body is consumed by the desire to go upstream; that is the life goal of every salmon. If it can’t go upstream to spawn, it can’t perpetuate its species.
According to the Washington Department of Transportation, there are 1,987 barriers to fish passage in the state highway system. As of 2013, 285 fish passage projects have unblocked 971 miles of potential upstream fish habitat. But a U. S. District Court injunction has mandated that 1,014 more be corrected by 2030. Failing to correct culverts that block fish passage violates the treaty rights of tribes whose way of life depends on healthy salmon runs. Treaties are, by definition, the supreme law of the land. We like to think that the days of breaking treaties with Indian tribes are in the past, but the sad fact is we’re stilling doing it – and the result is the same as it has always been: broken treaties threaten the survival of tribal culture and livelihood, as well as the extinction of wild salmon. Culvert repair is part of the state’s transportation budget – or would be, if the legislature could muster the political will to actually pass a transportation budget, which it has repeatedly failed to do. And even if and when a transportation budget is passed, there will be intense pressure to put the transportation needs of people ahead of the needs of fish and treaty rights.
The Washington Department of Transportation estimates the cost of complying with the federal court injunction – which applies only to tribes in Western Washington – at $2.4 billion, or $310 million per biennium. In the current biennium, they will spend $36 million. At this rate, it will take centuries, not decades, to complete this work.
Secretary of WSDOT Lynn Peterson wryly describes the federal court injunction as “Transportation’s McCleary decision,” a reference to the state Supreme Court order for the Legislature to fully fund public education, even if it means taking truly drastic action, such as closing down other state agencies. When a federal court orders the state to do something – in this case, obey treaties – the state surely ought to heed the injunction.
We understand the Legislature’s dilemma. Voters hate taxes. Legislators like to get re-elected. But when both state and federal courts rule that we’re not meeting our obligations to the next generation of children or of salmon, it ought to be a wake up call. Both legislators and voters must recognize that it’s time to move beyond our own self-interest, and to do what’s right for our children, the tribes, and the salmon.
Just to give the Leg some options, maybe the court could tell WA to fix the culverts by 2030, with annual budgets of $310+million or give all anadromous salmonid harvest to the Tribes. Give the Leg a choice. If they choose to take the NI share of salmon as unfixed culverts, development, closed hatcheries, lower taxes then fine.
Would this be a good time to start making the Tribes subject to the same gas, tobacco, and liquor taxes as the rest of us (at the very least off reservation lands)? I don't think that would violate any treaty rights.... They benefit from the same highways blocking fish passage - shouldn't they share in the pain of fixing them? I'll admit this wouldn't come close to bridging the budget gap, but it wouldn't hurt the cause a bit.
Time for strange one of the week. One of the guys spotted a dead fish in the Wynoochee and upon inspection it turned out to be a Chum. Bright showing light stripes it is way early to say the least. In addition others have spotted them with the clear water. So what gives? The run is usually last of October first week of November and they come through the bay regardless of flows. The movement on the tides has been unusual as the fish that showed really did not look like Chinook ( which should be around ) or Coho. So we have the answer but it is a strange one.
Summer chum stray. . They are in hood canal and other PS rivers right now..granted I don't think the GH area has a summer chum run at all or if it ever even did but that's not to say they can't be strays from the wrong side of the mountains
Time for strange one of the week. One of the guys spotted a dead fish in the Wynoochee and upon inspection it turned out to be a Chum. Bright showing light stripes it is way early to say the least. In addition others have spotted them with the clear water. So what gives? The run is usually last of October first week of November and they come through the bay regardless of flows. The movement on the tides has been unusual as the fish that showed really did not look like Chinook ( which should be around ) or Coho. So we have the answer but it is a strange one.
Not unheard of. I caught a chum, colored, in the lower Nooch mid-August several years ago. Could be as simple as a messed up biological clock that told it to enter a month or two early.
Might be a small population of summers. Just because they aren't "officially" recognized doesn't mean they don't exist. And, as noted above, fish stray. Which is how areas get colonized.
Recently some have inquired as to how to make a Public Document Request. ( PDR ) It is rather simple really and then not so simple all at the same time. So here are my guidelines I developed for myself in the past two years.
First: Ask once politely in writing for the information you need. Direct the correspondence to the Regional staffer you feel has the information. Wait two weeks.
Second: Again ask politely in writing for the information you need. Direct the correspondence to the Regional staffer you feel has the information. Wait three weeks.
Third: Write a PDR request for the information and the example below has the contact person and address. Now keep it simple and as direct as possible but one needs to make sure you do not leave a gap ( wiggle room ) or you can bet your sweet bippy they will be misunderstanding or reinterpreting your request. Not the PDO officer below but rather the staff that did not want to respond in the first place. Another issue with WDF&W is the fact that when the state legislature appropriated funding for implementing the PDR process it appears they did the minimum possible ( and I mean minimum ) to comply. This has now created the issue for WDF&W staff to even find the electronic documents requested. Paper documents? The farther back in time your request goes the greater the difficulty as WDF&W did not code or utilize a tracking system for documents.
Now one does not want to throw to wide of a loop as then you will get a paper blizzard. What is a paper blizzard? You get the documents your really after buried among hundreds to thousands of other documents to sort through which is known as " dumpster diving ". The agency your requesting information from does not have to make it easy for you.
My final rule is get somebody to help / look over your work. For years I used my wife, now my brother. Two sets of eyes are better than one and even better if you know a retired agency staffer who will help you out and I have that one three times over.
It is your right as a citizen to require a government entity to make documents available to the public ( the exception being attorney / client documents ) but one should not abuse the right. On the other hand you're not required to accept blindly the utter BS that comes out of agency staffers and lord those folks know how to shovel fertilizer! One final thing is all state documents are Microsoft programs ( a few exceptions like Adobe exist ) so if your a Mac person get ready as the PC v Apple thing is still hanging around! Oh almost forgot. Make sure your complete contact information is provided on the request. ( cell / home phone / email / snail mail )
June 19, 2014
Theresa Gibbs Public Disclosure Officer Washington Department of Fish and Wildlife 600 Capitol Way North, Olympia, WA 98501-1099 1111 Washington Street S.E., Olympia, WA 98504
This is a request for public records. Please forward to me in electronic form any and all communication records of any kind that were created, transmitted or received by the Department, its staff, or the Fish & Wildlife Commission related to the following:
1. Development, adoption or implementation of the new fisheries policy for Grays Harbor that was adopted by the WDF&W Commission (POL-C3621) that were transmitted or received from the date of adoption (February 8, 2014) to July 19, 2014;
2. The creation, drafting, filing, or processing of the 2014 Grays Harbor fall commercial fishing season that were transmitted or received from March 6, 2013 to July 19, 2014.
3. Co-management in Grays Harbor with the Quinault Indian Nation (QIN) of fishing harvest including, but not limited to, any tribal or non-tribal seasons proposed or considered by either the Department or the QIN that were transmitted or received between January 1, 2013 to July 19, 2014.
“Communication records” includes, but are not limited to, any voice mails, text messaging, emails, letters, meeting minutes, conversation notes, created, transmitted, received, or acquired.
Feel free to contact me if you have a need for any clarification.
A reminder for all. Tomorrow at 1:00 to 3:00 at the Region 6 offices in Montesano is the hearing for the Grays Harbor CR 102 Commercial Season WAC. This is the last time one has a opportunity to put your comments into the legal record regarding the Grays Harbor gillnet season.
A public hearing will take place on August 26, 2014, at 1:00 p.m. to 3:00 p.m. Region 6 Fish and Wildlife Office, Conference Room 48 Devonshire Rd., Montesano, WA 98563
The Commission will have a conference call meeting Thursday and for many item B regarding the 2015 budget is important. So here is the press release.
Washington Department of Fish and Wildlife
Fish and Wildlife Commission SPECIAL MEETING ANNOUNCEMENT MEETING via CONFERENCE CALL Agenda
WHEN: Thursday, September 4, 2014 – 8:30 A.M.
WHAT: A. Advisory Committee to the Commission for Persons with Disabilities Member Selection for Open Positions – Decision The Commission will consider candidates for open positions on the Advisory Committee for Persons with Disabilities. Panel members will present the results of candidate interviews and make recommendations for final selection.
B. 2015 Operating Budget Request - Decision Department staff will brief the Commission and request approval for the agency’s operating budget proposals.
C. 2015 Legislative Proposals – Decision Department staff will brief the Commission and request approval for the agency’s 2015 legislative proposals.
D. Meeting Minute Approval – Decision The Commission will consider approval of meeting minutes. • August 15, 2014 – conference call
E. Wolf Management Update – Briefing Department staff will brief the Commission on recent wolf management activities.
F. General Discussion The Commissioners and Director will discuss recent activities and items of interest.
*WHERE: This meeting will take place by telephone conference call. The public may listen to the discussion on speakerphone by coming to the Commission Office at the Department of Fish and Wildlife headquarters, Natural Resources Building, 5th Floor, 1111 Washington Street SE, Olympia or one of the Regional Offices. If you plan to come to one of the offices to listen to the conference call please contact Commission staff at (360) 902- 2267 so we can ensure adequate space is available.
The information below was provided by Brandon and he is working to get funding to upgrade the South Monte boat launch. The attachments I can send anyone if they would like to have them just send a PM to me or Brandon. I have not reviewed the information completely yet but at first look it appears to be a worthy effort.
I have attached the proposed improvements we would like to make to South Montesano. I have also attached a "rough draft" of a presentation just to give you a better idea of what the proposed project looks like and what the RCO Grant panel will be scoring. The main features that we are revamping is a brand new double boat ramp that is protected by a concrete articulated mat known as "armor flex." The new style ramps that we want to install are a vast improvement in design, longevity, and durability compared to the current ramps. Also, another main feature of the site redevelopment is the installation of a new CXT vault toilet. As you will see in the pdf attachment of the rco presentation, there are hardly any words on the slides. That is how RCO wants the slides to look and my job is to "present" the slides so all wording is by mouth rather than written. I will give you a breakdown of what is happening in each slide. I hope this provides you with the information you're seeking.
Slide #1- Title #2- Map #3- Current ramp condition is very poor, especially during low tides #4- Another view of the current ramps #5- A shot of the busted culvert that we will replace to improve drainage of the parking lot #6- A graph showing visitor use (before fishing season. These numbers will sky rocket soon.) Also, the current toilet #7- An arial view of the site and its close proximity to the amenities provided by the town of Montesano #8- The existing site as it stands today #9- The proposed site plan with an example of the new toilet and new ramp #10- Cost benefit of making these improvements (again, this is a rough draft) #11- How the improvements will improve overall boating experience ( the grant category is "Boating Facilities Program," so the goal is to prove that the project will increase the boating experience and attract more boaters, which in return, creates more revenue for future projects.) #12- A timeline to show we are ready to take on this project
Again, thank you for your interest in this project. If I can do anything else for you, please let me know. Respectfully, Brandon Troyer
As the dance over the fall salmon season continues the following comments were submitted. I will look around for some commercial input but I think that will have to wait until the Concise Explanatory Statement is released addressing comments from citizens regarding the Non Treaty Commercial CR 102. The one thing that is clear at the minute is Grays Harbor has a new conservation driven management plan and the QIN view that they have court directed to access to 50% of hatchery plus wild for the total of Grays Harbor combined and do not recognize the separation of the Humptulips and Chehalis Basins. Two trains traveling at high speed on the same tracks in opposite directions. Going to be one hell of a collision someplace some how, soon.
Dear Mr. Thiesfeld:
RE: Revised comments to GH Commercial Proposal
The Twin Harbors Fish & Wildlife Advocacy offers the following as a supplement to the comments filed earlier related to the Department’s proposed commercial gillnet season in Grays Harbor. We provide additional comments, revise an option, and add an additional recommendation for consideration while maintaining our position the proposal is contrary to legislative mandates and the new policy passed recently by the Commission.
The new policy for Grays Harbor adopted by the Commission states any season set by the Department must intend on reaching escapement goals for natural spawning and hatchery Chinook in the Chehalis after consideration of the impacts of both, tribal and non-tribal seasons. Therefore, the maximum impacts of the season cannot rise beyond a level where the fish available for harvest drops below zero as a minus number of fish remaining reflects the number expected to be short of the escapement goal.
In its previous presentation on the proposed NT net season for Grays Harbor, the Advocacy raised the issue that the harvest model showed the combined harvest of all users resulted in only 184 natural spawning Chinook and -120 hatchery fish remaining for harvest for a combined number of 63 left above the escapement goal. Since the Commission policy states the season has to intend on reaching escapement goals for hatchery and wild Chinook, the minus number of hatchery fish found in the harvest model shows the season proposed by the Department is not intended to reach escapement goals and the Department is fully aware of that fact. Additionally, the Advocacy felt that the use of an assumed 90% compliance rate for selective fishing and an assumed catch by the Chehalis Tribe tied to the court set formula of its treaty rights was flawed and held great potential to underestimate the harvest impacts far beyond the 63 fish remaining. If corrected, the Advocacy believes the harvest model would likely show a minus figure for both natural spawners and hatchery and the season was not expected to reach escapement goals.
On the Friday before the hearing set for Tuesday, August 26, 2014, the Department provided the public with a revised season model with changes to the summary tab. While the Department improved its presentation by listing the changes it had made, the email cover for delivery did not provide any rationale for the changes or disclose the effects of said changes. The Advocacy has not had the time or information available to confirm the rationale or effect of the changes.
However, in our attempt to do a review of the changes we have located what Advocacy believes at
this point are flaws or errors in the model that if confirmed, likely further underestimate the impact of the commercial season proposed on Chehalis Chinook. The problem could exceed the 63 fish number by a significant amount on its own. This new concern, in combination with the 2 concerns listed previously reinforces the Advocacy's believe that the commercial season proposed does not rise to the standard of the new policy that requires the season adopted have an intention of meeting escapement goals.
The problem with these assumptions and potential modeling errors are truly significant. As an example, consider the results if the Department inserted the Chehalis Tribal assumption in a similar manner for the QIN. If the Department "assumed" the Quinault season would only result in impacts tied to the formula in U.S. v- Washington (Boldt) of 50% of the available harvest across the bar, the harvest model would reduce the expected QIN impacts on Chehalis Chinook for this proposed commercial season by 4,270 fish. The 63 fish in the model would grow to 4,333 remaining above the escapement goal. Add the modeling error and Chehalis tribal assumption and that number could grow significantly further. The problem is simply underestimating commercial nets seasons only serves to create "paper fish" in the model and while the model is “tricked” into accepting the season proposed, paper fish cannot spawn in the gravel.
In the Advocacy’s earlier presentation, Option 2 stated “The only other means available to convert the season into a proposal we could support is to remove the fishing in either week 40 or 44. This would lower the number of impacts on natural spawning Chinook to provide a buffer against harvest undermining the escapement goal for the Chehalis.” Now that the Advocacy has been provided the revised summary tab in the planning model, we amend this option to say, “….into a proposal we could support is to remove the fishing in both week 40 and 44.
If adopted, the proposed season will likely create controversy and distrust between the public and either the Commission or tribal co-management
The Advocacy has steadfastly tried to avoid the annual allocation battle between the nets and the poles. However, a primary goal of the Advocacy is to encourage all the citizens to manage and share natural resources for the benefit of future generations. The proposed season sets the stage for a controversy that will have lasting impacts on the public image of the Department and Commission. It will also likely further complicate the troubled relationship between non-tribal fishers and the co- managers representing the interests of the tribes. As a result, the Advocacy has no choice but to comment on the Department’s proposed allocation, which comes in the form of the proposed non- treaty net season.
The proposed season by the Department creates an overwhelming share of the harvest to the commercial sector. While federal courts have mandated the Department honor tribal fishing rights, the non-treaty commercial fisheries holds no such right to fish. The Department’s legislative mandate states, “In a manner consistent with this goal, the department shall seek to maintain the economic well-being and stability of the fishing industry in the state1.”
Since the tribal fishers are also citizens of the state and large segment of the fishing industry, the economic well-being and stability of the industry is assured by the tribal commercial seasons without
the installation of yet a third gillnet season into the same river. The recreational sector has repeatedly pointed out a net is a net regardless of a tribal affiliation or not. More importantly, the tributaries of Grays Harbor simply don’t have enough fish available this year to fill those non-treaty nets without undermining the effort all have engaged in trying to find season that meets escapement goals.
The Department’s proposed season fails to recognize the effect of the Boldt decision and tries to once again “shoe-horn” a non-treaty gillnet season into the already crowded calendar. In doing so, similar to the experience in nearby Willapa where no tribal nets are in play, the Department is in essence promoting an allocation between nets and poles that is extremely lopsided in favor of commercial nets. Combined, the harvest model provided by WDFW shows the Department is promoting a season that will result in the three net seasons taking 79.4% of the Chinook, 76.8% of the Coho and 97% of the Chum in Grays Harbor and its tributaries.
