Done. Thanks for the reminder.

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.

Sent my email yesterday, actually received email from reg 6 inviting me to comment.

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!

Must applaud Team Hamilton for spearheading this valiant effort.

A decade of involvement doing it the WDFW way has left me and at least four other rec advisors extremely frustrated at the lack of basic conservation.

It's harvest harvest harvest at all cost.

Perhaps FTC.net will give the agency cause to pause to consider its mission in these proceedings in the future.

The advisors and especially eye FISH have worked tirelessly for years to make the NOF process fair to recreational anglers.

What Tim is claiming is that both the WDFW science and the NOF process are intentionally rigged games. The next 30 days will be interesting for sure.

Hopefully this effort helps eyeFish and the rest with their efforts in the future.

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

why ?? cant they figure it out????

thought they already had the rules out???

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.

I hope the end result of all of this is Ron Warren losing his job.

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.

I understand this meeting was concerning GH but will the Willapa gillnet season also be decided in the time frame you just described?

If so, then we should expect news for each area, correct?

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.

It will be an interesting next 5 days to say the least

Here is the link to rules on Emergency Rule making and we are idiots and totally messed things up is not one of the justifications.

http://apps.leg.wa.gov/rcw/default.aspx?cite=34.05.350

Intersting read about "emergency" rules.

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.

http://apps.leg.wa.gov/rcw/default.aspx?cite=34.05.325

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.