Here are my comments to the Commissioners. Frankly I doubt if the Commissioners truly know the depth of the hole Willapa is in and frankly the probable outcomes from staffs actions. My view of things.



Commissioners:

The recent review of the Willapa Policy ( WP ) and the many issues surrounding it have been discussed, primarily around harvest issues for 2018. While important I feel all are failing to grasp the true nature of the impact of the Willapa Policy when the policy is fully implemented in 2020.

Prior to the WP the entire Willapa Harbor was managed for what can best be described as a kill zone fishery area with the Commercial fishers being the prime beneficiary. The WP has many elements and verbiage to direct both harvesters and the agency toward conservation driven harvest opportunities. What most miss is not what the words say and mean but rather what they do.

To truly understand the WP and its effect on Willapa Bay it is best to look at Willapa Bay as two areas with the North area comprising the Willapa River, North River, and Smith Creek. The second area is simply the South Channel and the streams that empty into it which include the Naselle and Nemah rivers. If one is not familiar with the Willapa Bay and the harvest sectors WDF&W has a map on its website.

It is critical that one understand the interaction between four terms in the WP to fully understand the probable outcome.
1. NOS: Natural origin spawners in the gravel.
2. HOS: Hatchery origin spawners in the gravel.
3. Ratio: This is the mix of NOS & HOS in any given fishery.
4: Encounter Ratio: When harvesting the NOS & HOS mix determines how many NOS encounters which lead to mortalities from NOS encounters when releasing NOS adults.

I will outline what the WP dictates for Chinook in the Willapa River, which is the location of the Forks Creek Hatchery. The hatchery Chinook production was drastically reduced to 350K to comply with the Prime stream designation as it relates to straying. This action will fully implemented in 2020 when the first returns from the reduced releases return. In 2020 the Chinook ratio could drop to nearly 1 to 1for fishers in areas T, U, and inriver, it just depends on what the run forecast is for any given year. What is certain is with the ratio being what it will be starting 2020 areas T & U going forward will be difficult to maintain even the sport fishery. The NOS population is a small one under escaped resulting in the sport catch and release ( C&R ) hooking mortality possibly being more than can be maintained and reach spawner objectives. There will be zero commercial opportunity as even a tangle net mortality is far greater than the NOS returns can tolerate. This will happen regardless of any action WDF&W takes.

To complicate matters two very real unknown factors will also be at play. First the Willapa NOS population has been supported by substantial influence by the HOS staying for years. In 2020 this ends and the Willapa Chinook NOS will be a standalone population and how well it will perform is not known. It is not about just making a redd but rather how successful the NOS spawners will be in reproducing offspring. This cause and effect is dictated by the simple fact that multi generational hatchery fish do not reproduce as well as wild NOS when returning to the gravel. Genetically the Willapa hatchery Chinook are the same as NOS as the massive staying of hatchery resulted in a NOS that is in reality a HOS adult spawning in the gravel just unmarked with a fin. Again this is a real unknown and likely to very difficult for staff to quantify until 2024 to 2028. One certainty is the beginning returns will not be greater than at present, In fact we will be lucky if the first generation returns from 2020 to 2024 are the same. The most probable outcome is a reduction in numbers from four to eight years, two generations, and then the stock if managed properly slowly begin the 20 plus year recovery period envisioned in AHA modeling.

The second issue all about what the fish do when they return in 2020. Prior to 2020 T & U areas were the destination of returning Willapa River HOS fish so the ratio of HOS & NOS was favorable toward harvest. 2020 this is not so resulting in the vast majority of HOS Chinook will be returning to the South Channel. This leaves one with a real unknown. Will the Chinook track in close to the mouth of the bay and swing through T or track West and more or less track straight down the South Channel? The fact is the more adults that enter in the Tokeland side of T as they go South will greatly help the ratio of HOS & NOS reducing encounter ratio of NOS thus reducing the number of NOS mortalities from release. What is known is that between 0% and 100% of the South bound Chinook will do something in or around T and the North bay but to what degree to favorably effect the HOS / NOS ratio will not be fully known until several years of fishing which would be 2023 or 2024.

To add to the difficulty is the fact that staff will have little data to utilize. What the WP did when the Chinook hatchery production was moved South is create totally new parameters resulting in a much different hatchery complex for Chinook. The fact that Mr. Herring, District 16 staffer, has done a lot of work on the numbers and has a real feel for what the true relationship is between numbers and the fish is a plus as this is going nearly impossible to sort out while maintaining harvest.

In 2020 the South Bay fisheries will also be drastically altered. The added Chinook hatchery production from the Southern hatcheries will be available with a favorable ratio of HOS & NOS. The downside is that the NOS population is rather small and is going to be very vulnerable to over fishing. Commercial fishers will have a substantial number of fish available for harvest but to access them the fleet will need to utilize tangle nets or the most selective gear that can be developed to be utilized. Every NOS mortality that the fleet can avoid allows it to access thousands more Chinook and Coho for harvest. From the start of the WP implementation the Commercial fleet has resisted utilizing selective gear with a few exceptions. If this course of action continues the Commercial fisher will force itself off the water as Chinook NOS population will not rebound but rather resume to decline in NOS spawners. This will result in limiting the Commercial fleets access to Coho also to a far greater degree than at the present time.

The issue surrounding the Willapa Chum population are steeped in history and environmental changes that have been experienced acerbated by over harvest. The Chum issue needs to given a complete review separate from this discussion in my view. I say this because my best guess is WDF&W will seek to lower the escapement goal rather than address past failings. It is easier to ignore a problem rather than take action to repair the damage done in the past.

Additionally the sport fishers that have traditionally fished T & U will be restricted by the loss of the Forks Creek production and small numbers of NOS & HOS impacts available for harvest. It is a fact that all fishers, be it sport or commercial, fish where the fish are. It should be expected that the sport fishers in the South Channel will increase dramatically in the first years after 2020 and this in itself will create ever greater conflict between sport and commercial fishers. Again the South Bay NOS Chinook population is a small one which will now have both Commercial and sport competing for the same limited number of NOS impacts as presently exist. Another way to look at the issue is that the vast majority of Chinook Willapa Bay hatchery production will only have half the NOR adults supporting harvest it enjoyed prior to 2020 with the conservation directives in the Willapa River.

The other reality is that the Commercial fleet is in reality two groups of fishers. The North end fishers from Tokeland, which are who the Commissioners usually see at meetings, and the Southern fishers. All are territorial, do not take intrusion by another fisher lightly, and only have the catching of a fish in common. The dislocation of the Northern Commercial fishers to the South Channel will be a issue as will migration of the majority of the sport fleet to the South Channel.

So here we are in 2018 arguing over the definition of terms and intent of the WP. Commissioners I urge you to do nothing. Intent or not the years prior to 2020 are, for lack of a better description, our training period. It is the time that staff, fishers and yes the Commission must develop the discipline to properly conduct harvest under very unfavorable conditions. Frankly Commissioners we are failing miserably and there will harsh consequences unless this changes. The agency knows this is coming and the lack of candor on this issue is appalling.

So again Commissioners I urge you to do nothing. we have two years to get our act together and any action by the commission will only make things worse. It is time for WDF&W staff to do their job and lead because in 2020 it will be a new world and as a citizen fisher I feel it would be of substantial benefit if we were actually prepared to face the coming challenges.

Sincerely,