What we have here are my final comments on the Willapa Management Policy draft. ( WMP ) Myself and others worked with the Advocacy to address most issues in the WMP draft which was posted previously.

So take a look and see what you all think. The critical thing for all is the 14% harvest rate for Chinook in the entire Willapa Estuary. Without that all the miles running around to meetings will have been a total waste of time. Also several side bar issues remain with Coho & Chum which I commented on.

Regardless of your views I urge all to submit your final comments on the WMP to the Commission. commission@dfw.wa.gov I would also urge all to CC the Director director@dfw.wa.gov . It really is your last shot as a citizen to put forth your thoughts for consideration.





Commissioners,

Myself and many others that participated in the Willapa Management Policy ( WMP ) process have worked to develop comments on the final draft of the WMP with the Advocacy for your consideration. Difficult as it is to get the views of all captured in a workable document I do believe the modifications suggested are well thought out and doable. I urge the Commissioners to adopt the modified option E and other changes suggested by the citizens working with the Advocacy.

As the WMP process evolved it was a difficult journey for all. Deep divisions were apparent between user groups and to be honest agency staff did not help with the manner issues were addressed. That said what the agency did do well was the AHA model. The intense effort to proof the AHA model by staff and the contractors was apparent with excellent results. Despite considerable opposition from both Recreational and Commercial fishers staff stayed the course and got it right.

So why do we have a problem? AHA model identified that a harvest rate of 14% for the entire Willapa Estuary ( both North & South regions ) was needed for recovery. It is not that the AHA model failed but rather staff and many others did not like the answer it provided. At a Commission meeting early in the process Commissioner Mahnken told all that the WMP effort to comply with HSRG was going to be difficult and painful which it has been, is at the present, and will be in the future. Because HSRG standards may be difficult to achieve is not a reason to stand down HSRG standards but rather should be viewed as the catalyst to motivate agency staff, Commercial & Recreational fishers, and Conservationist interest to change how we do business. For Recreational fishers it will mean changes in what areas we fish. Conservation driven advocates will need to accept something less than perfection. Commercial fishers will need to move to alternate harvest methods rather than the traditional gillnet. For the agency the effort to redefine how the Willapa Estuary Hatchery Complex production is produced will be very difficult. The AHA model dictates a 14% harvest rate for recovery and must be maintained in the future. Frankly as difficult as it will be it is the only hope to recover and redefine conservation driven harvest in the Willapa Estuary in the future. I urge you to continue the recovery process in the Willapa Estuary and adopt a maximum of a 14% harvest rate for both the Northern and Southern streams in the Willapa Estuary.

Additionally I would like to comment on two other issues. Throughout the WMP process staff has constantly altered and moved stream designations ( primary/ contributing/stabilizing ) to enable different levels of hatchery production. HSRG stream designations have definite definitions / requirements and are not intended to be multiple choice to stand down HSRG standards. While this is clearly an attempt to skirt HSRG requirements in the case of the Naselle Coho it is driven by the inability to stop hatchery origin Coho adults from straying. Dependant on flows the Naselle weir is removed around October 15th which simply means straying of hatchery origin Coho above acceptable HSRG levels is guaranteed. Staffs response in the draft WMP is to designate Naselle River as a stabilizing stream for Coho to allow much higher straying rate but bring the hatchery broodstock to contributing requirements. Again Commissioners this is a failure to meet HSRG requirements on straying and an attempt to skirt HSRG requirements. As one of the two largest streams in the Willapa Estuary the Naselle River is at the least a contributing stream or primary for Coho and those standards should be applied.

So what to do is the question. Regardless of what the Commission chooses to do the simple fact is that for the first four years of the WMP the agency and users will be in a transition from the current production to that required by HSRG. I urge the Commission to consider a alternate approach for the Naselle River Natural Coho and hatchery Coho production.

A. Designate Naselle as contributing Coho stream for Natural Origin Coho Recruits ( NOR ) which is compliant with HSRG.

B. Allow the agency to utilize the first four years as a transition period for the Naselle Hatchery to allow staff to develop a solution and seek funding required for what is necessary to comply with HSRG.

C: If after four years the agency fails to obtain funding to modify the Naselle Hatchery or develop a HSRG compliant alternate solution for hatchery straying then all the requirements of a contributing stream be immediately applied with no exceptions.

Throughout the WMP process users, ( both commercial & recreational ) elected officials, and special interest have put forth a wide range of ideas. Some were doable, many were not but nearly all have a price tag in dollars. So this is the challenge for all. To meet HSRG requirements the Naselle hatchery needs weir modification, replacement, or a alternate solution compliant with HSRG. It falls not on the agency alone to attempt to obtain funding for this but ALL mentioned previously. In simple terms on this issue it is time for all users and their supporters to work with staff and our elected officials to seek funding for a solution. If we fail to do so, so be it and implement all HSRG requirements for a contributing stream, no exceptions.

Again it will be difficult but this can be done Commissioners. Whatever the Commission's solution to the Naselle Hatchery Coho issue what should not be done under any circumstances is to stand down HSRG requirements as has been the agencies response to this issue.

The other issue that I wish to address and formally object to revolves around Chum escapement goals. During the WMP process three times the lowering of the Chum escapement goal was discussed between staff and Commercial fishers. In fact when pressed by a Commercial fisher staff identified the new escapement goal looked to be around 17,000 & change. Two things come to mind. First it is highly inappropriate for staff to have conversations with only the Commercial interest on a issue such as this without the public being aware or provided the same opportunity and information. Secondly Commissioners the Willapa Estuary was the premier natural Chum producer in the state for most of the last century. That Willapa Estuary Chum are struggling is a given but the cause other than overharvest has not been identified or put out for review by the scientific community. In fact many believe the cause is not entirely the streams and overharvest but the bay itself and human activities such as spraying chemicals. The failure by Region 6 District 17 staff to clearly define the cause of declining Chum numbers should not be accepted by simply lowering the Chum escapement goal.

I urge the Commission to require any changes to any Salmon stock escapement goals ( of greatest importance being Chum ) be brought to the Commission for review and the supporting documentation made public for a full scientific review by third parties before implementation of any reduction in escapement goals. Frankly Commissioners I think my neighbors comments about capture the issue. " They ( the agency ) make a mess out of things and rather than find out what went wrong WDF&W wants to lower escapement goals. Why don't they find out what went wrong and fix it? When does it stop? At zero? " I think John's questions captures the issue.

Sincerely