I was asked to post up the proposed REC seasons for Grays Harbor so here you are. Biggest changes are the return of the early summer fishery on the Chehalis, two rod endorsement for the Chehalis but only above the 101 bridge to the South Elma Bridge, and a two bag limit in 2C and a overall expanded season. The two rod bit will primarily help those fishing from boats but also the plunkers. 2C has limited ( & poor ) access. It works for those who want to dodge the crowds and put up with the inconvenience. Keep in mind this is only proposed at the minute and could change.


2015 Grays Harbor Fall Non-Treaty Terminal Area Planning Model
2015 schedule proposals, Cheh July Jack, Hump 2 Adults Chin Nov 15, Rec 2C Aug1-Sept15, comm 2A/D 4days 9 hr WK 43 and 45, 1 day 5hr and 1 day 4hr WK 42 , 2C 2 days 9 hr Wk 44 add H CHK Hump.
Model Run Description Preseason planning 03/05/2015
PFMC Option #
FRAM Run # 1408

Fishery Description
Sport Dates Bag Limit
Marine 2.2 Area 2D only Sept 16 - Nov 30 3 adult, release Chinook.
Area 2C only Aug 1 - Sept 15 2 adults, release wild Coho.

Chehalis River FW
Mouth upstream to South Elma Bridge May 1 - Jun 30 1 adult bag: 1 Chinook
July 1 - Nov 30 3 Adult bag: release adult Chinook, two pole endorcement July 1 -Nov 31.
Dec. 1 - Jan. 31 3 Adult bag: 2 wild Coho, release Chinook and Chum

South Elma Bridge to Black River May 1 - Jun 30 1 adult bag: 1 Chinook
Sept 16 - Nov 30 3 Adult bag: release adult Chinook
Dec. 1 - Jan. 31 2 Adult bag: 1 wild Coho, release Chinook and Chum

Black River to Hwy 6 May 1 - Jun 30 1 adult bag: 1 Chinook
Sept 16 - Nov 30 3 Adult bag: release adult Chinook and Chum
Dec. 1 - Jan. 31 2 Adult bag: 1 wild Coho, release Chinook and Chum

Hwy 6 to high bridge Oct 1 - Nov 30 3 Adult bag: release adult Chinook and Chum
Dec. 1 - Jan. 31 2 Adult bag: 1 wild Coho, release Chinook and Chum

Hoquiam Oct 1 - Nov 30 2 Adult bag: release Chinook
Dec 1 - Dec 30 1 Adult bag: release Chinook

Wishkah Sept. 16 - Nov 30 3 Adult bag: 2 wild Coho, release Chinook
Dec. 1 - Jan. 31 2 Adult bag: 1 wild Coho, release Chinook

Wynoochee Sept. 16 - Nov 30 2 Adult bag: release Chinook; mouth to White Bridge
Dec. 1 - Jan. 31 2 Adult bag: 1 wild Coho, release Chinook , mouth to White Bridge

Satsop Sept. 16 - Nov 30 3 Adult bag: release wild Chinook
Dec. 1 - Jan. 31 2 Adult bag: 1 wild Coho, release Chinook

Black River Oct 1 - Jan 31 2 Adult bag: release Chinook and Chum (After Nov 30, only 1 wild Coho)

Skookumchuck Oct. 16 - Nov 30 3 Adult bag: release Chinook and Chum
Dec. 1 - Feb 28 2 Adult bag: 1 wild Coho, release Chinook and Chum

Newaukum Oct. 16 - Nov 30 3 Adult bag: release Chinook and Chum
Dec. 1 - Feb 28 2 Adult bag: 1 wild Coho, release Chinook and Chum

Elk and Johns Oct 1 - Nov 30 1 Adult bag: release Chinook
Humptulips River FW Sept. 1-Sept 30 2 Adult bag: of which 1 may be a Wild Chinook, release wild Coho
Oct 1 - Nov 15 2 Adult bag: of which 1 may be a Chinook, release wild Coho
Nov 16-Jan 31 2 Adult bag: release Chinook, wild Coho, and Chum

Do you know if these were proposed in the spirit of 4/3?

It didn't make sense to me. 4days 9 hr wk 43 and 45? How much time in the water does that mean?

looks like it says .. 4 days in weeks 43 and 45 for 9hrs a day = 36hrs a week

Correct... as literally stated, it adheres to the 4/3 principle.

However, commercial advisors recommended a schedule that reverses the 4/3 to 3/4 in week 45.

4/3 vs 3/4... BFD? Who cares? There's still 3 days of escapement, right?

WELL.... not so fast.

It wouldn't be such a big deal... EXCEPT that the QIN is going 5/2 in stat week 46.

So for the two stat weeks 45 (3 off/4 on) and 46 (5 on/2 off), you get a combined schedule that looks like 3/9/2.... with the 9 consecutive gillnet days falling on Nov 4 thru 12.

That WILL be devastating to the inriver guys thinking they're poised for prime-time coho action.

There is the verbiage from the plan. Does it violate the spirit of the plan was the question back a bit. Yup but that is WDFW. Staff has fought implementing the plan from the beginning as they just can not turn loose of the NT Nets. One should keep in mind that the Rec season was taken out of one proposal ( as staff said no changes to Rec they are satisfied with what they have ) and three more commercial net season proposals have been directed to staff.

Below are my comments on the last Commercial proposal and many questions that swirled around the others are addressed in it.

To: Steve Theisfeld
Jim Scott

After reviewing of the Commercial Proposals submitted on 5/1/15 several issues are present. In looking at the modeling of the proposed seasons by the Commercial sector, revised by WDF&W, I propose the changes outlined below. I also have attached a modified copy of the WDF&W spread sheet reflecting the changes.

It appears that the model failure of not reflecting harvest impacts of prior harvest be it Recreational or NT Commercial prior to the QIN fisheries is still present. I should not be able to place NT Commercials in seven days a week with the QIN fishing 4 days and show zero impacts to the QIN fishery. This was corrected for the Recreational fishery last year but it appears staff failed to do so for the QIN fisheries.

Also the model does not provide ex-vessel value for the NT Commercial harvest. This is a serious failure by staff to provide all the information necessary to evaluate any NT Commercial season proposal. This should be addressed immediately and added to the model as was done in the revised Willapa Harvest Model.

Recommended Changes To the 5/1 Commercial Season Proposal:
Week 42:
On October 11th the proposal places the NT Nets directly in front of the QIN scheduled fishery on October 11th. This is inappropriate and appears to be intended to strike out at the QIN & GHMP. This is inappropriate and should be removed from any further consideration.

On October 14th the proposal has the Non Treaty fishers going in directly as the QIN fishers are pulling their nets completing fishing for the week. With limited boat ramp availability and the combined number of QIN, NT, and Recreational boats intermixed in such a small area the potential for safety issues and conflict exist. I suggest a minimum of a 1:30 PM start for NT fishers to allow the QIN and Recreational fishers who choose to do so to get their catch and boats off the water safely without unnecessary conflict.

Week 43:
The proposed season is utilizing the aggregate for Humptulips and Chehalis Chum but taking the vast majority on the Chehalis side. This is inappropriate and vastly increases the probability of serious damage to the Chehalis Chum stocks should the runsize forecast meet predictions and guarantees substantial damage to Chehalis origin Chum if run does not exceed preseason expectations. This differs greatly with the QIN proposed seasons with harvest projections of a Chum harvest of 2916 Chehalis origin and 1275 Humptulips origin which seek to maintain somewhat of a balanced harvest. The proposal also places the NT Commercial fleet in the river at 2A & D at Aberdeen thus removing the weekend fishery for the family Mom & Pop recreational fishery. This particularly egregious as 2A is the primary bank fishing area for handicapped Recreational fishers This is totally unnecessary as it can be avoided by simply utilizing other days of the week. To address this issue and the imbalance between the harvest of Chehalis and Humptulips Chum in the aggregate I propose a reduction to two NT Commercial days on October 21 & October 22 in week 43.

Regardless of what days of a week WDF&W staff choose to install the NT Commercial fisheries in 2A & D Saturday or Sunday should not be utilized for Commercial days to avoid the Recreational and Commercial gear conflicts which was a goal of the GHMP.

Week 45:
The proposal in week 43 results in gear conflict between Recreational & NT Commercials as the proposal places the NT Commercial fleet in the river at Aberdeen in 2A & D thus removing the weekend family Mom & Pop and handicapped recreational fishery. This is totally unnecessary as this can be avoided by utilizing other days of the week. To accomplish this a week 45 fishery of November 1 through November 4 is necessary with a start time of 1:30 PM on November 1st to avoid conflict with recreational fishers is required. This allows for four days of NT Commercial harvest.

Additionally the schedule outlined previously for week 45 allows for three days between the NT Commercials and QIN which allows for limited impact to the quality of the QIN and Recreational fisheries.

The final issue I wish to address as a GH Adviser is the failure to record or take formal minutes of the May 1st Adviser meeting create a record of the meeting which is also inappropriate. It was my understanding that this issue had been resolved some time back and WDF&W would create the required permanent record of Adviser meetings. If staff has changed or altered the manner it creates a permanent record I would appreciate you provide me the revised procedures.

I thought I would add Steve's E mail about the dust up over how the NT Commercial is going. If you want the two model runs that came with this e mail just PM me your e mail address and I will get them to you.

FROM Region 6:

Hi Everyone,

I want to bring folks up to speed on Grays Harbor. First I want to clear up any misconception about the model we sent out last Thursday. That model was not a proposal from WDFW. It was the juxtaposition of the two schedules (treaty and non-treaty) to help folks see where we had issues, especially with the 4/3. The purpose of Friday’s meeting was to hear ideas for resolving the issues.

Second, there have been a couple of requests for copies of the model the advisors worked on at Friday’s meeting. I have attached 2 models for everyone. These are not WDFW proposals. One is the commercial sector’s schedule request for meeting the issues identified in the previous paragraph. The second one is that same request with some trimming to meet Chum escapement. Please note that we have not gone over these with a fine tooth comb looking for problems, so there might still be an issue that we have missed.

Thank you.

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 latest draft of the Willapa Management Plan is out for comment & the link is below. It is a bit to get your arms around though.

WDFW NEWS RELEASE
Washington Department of Fish and Wildlife
600 Capitol Way North, Olympia, WA 98501-1091
http://wdfw.wa.gov/
May 15, 2015
Contact: Steve Thiesfeld, (360) 249-1201

WDFW seeks comments on Willapa Bay salmon policy
OLYMPIA - The Washington Department of Fish and Wildlife (WDFW) is seeking public comments through June 3 on a new draft policy to improve salmon management in Willapa Bay.

State fishery managers have been working since last October with a citizen committee and the public to develop draft options for a new policy for Willapa Bay salmon fisheries. The revised policy includes provisions to conserve wild salmon, clarify catch allocation, and reduce conflicts between sport and commercial fishers in the bay.

The policy is available at http://wdfw.wa.gov/conservation/fisheries/willapa_bay_salmon/. Written comments may be submitted via email to willapabay@dfw.wa.gov or by mail to Steve Thiesfeld, Washington Department of Fish and Wildlife, 600 Capitol Way N., Olympia, WA 98501-1091.

At its April meeting, the Washington Fish and Wildlife Commission, a citizen panel appointed by the governor to set policy for WDFW, asked the department to provide options that immediately accelerate the recovery of natural-origin chinook salmon. These options would reduce the incidental catch of wild fish while encouraging the harvest of hatchery chinook.
WDFW has developed two new options, bringing the total of alternatives for consideration to five.

WDFW staff members will provide a briefing on the options to the commission at its June meeting. The commission is tentatively scheduled to hold a public hearing on the policy and is expected to take action at the meeting Saturday, June 13, in Olympia.
Information about upcoming commission meetings can be found online at http://wdfw.wa.gov/commission/ .

Gonna start a list of my objections here... edit and add to it as I go. Anyone can feel free to copy/paste for their own public comments that they wish to submit.

Page 3, item 8) That nasty word "aggregated" was suck in there. Needs to be stricken.

Page 4 and 7 and 11, in reference to impact cap of 20%.... must be limited to 14% in ANY of the alternatives A/B/C. The commission has already seen the pitfall of adopting 20%.... it simply CANNOT fulfill the intended conservation objective of the policy. The commission understands 20% is a recipe for certain failure... so much that they planted a 14% rate in the interim policy for 2015. Adopting 20% can only be seen as a step backward in moving the conservation agenda forward.

...

OK ... holy krap! Two more alternatives (D/E) since the last draft. Alternatives A/B/C should just be taken off the table since they all propose an irresponsible 20% harvest rate. D/E have no transition period and jump straight to the 14% rate in the first year.

Will review D/E side by side against the rest of the A/B/C options.

....

OK, I put A and D up side by side in two windows, same size/font, and they are identical EXCEPT for the elimination of the 20% transitional phase-in during the first 4 years. Willapa Primary and Naselle undesignated with a 'pie in the sky' ramp up to 3.3 million chinook production.

FYI Alternative E is basically a synopsis of the essential policy elements endorsed by the Twin Harbors Advocacy as well as the WB Advisory Members representing the recreational and conservation sectors.

...

The principal difference between D and E is that Alternative E seeks a Contributing stock designation for Naselle chinook without the 'pie in the sky' ramp up to 3.3 million hatchery production. Instead a much more realistic and sustainable hatchery production goal od 0.8 million is proposed.

You pegged the "aggregate" Doc but they stuck it in for all three species. That lets them create a "kill zone " fishery in the South Bay.
Not good.

Some had questions on why the GH & Willapa Rec seasons were not in the NOF so below is Steve's response to the question.


With the delay on Willapa, we had to do them separately. Hopefully she will be getting out soon.

Steve

Sent from my iPhone



Hey,

I am being bombarded by folks wanting to know why GH & Willapa Rec seasons worked out in the local NOF are not in the CR 102 Ashbook sent out for comment below. Could you enlighten me so I can let folks know?

Dave

From: Ashbrook, Charmane E (DFW) [mailto:Charmane.Ashbrook@dfw.wa.gov]
Sent: Friday, May 15, 2015 3:24 PM
To: Ashbrook, Charmane E (DFW)
Subject: Recreational Salmon Fishing Rule Process: Public hearing, CR-102 Filing, & How to receive future information

Good Afternoon,

The Washington Department of Fish and Wildlife is proposing rule changes for recreational salmon fishing. The agency developed these changes through a pre-season planning process known as “North of Falcon” that includes a series of public meetings with federal, state, tribal and industry representatives and other concerned citizens. Rules based on the North of Falcon planning process change from year to year to reflect resource availability and achieve conservation goals.

The CR-102 and proposed WAC can be viewed and downloaded at: http://wdfw.wa.gov/about/regulations/development.html.

In accordance with RCW 34.05.320, a public hearing will be held on Wednesday, June 9, 2015, at 9:00 a.m., at the Natural Resources Building, Room 682, 1111 Washington St., SE, Olympia, WA, 98504.

Please also be aware that to reduce paper and associated costs, from now on this information will be provided through email and public news release. To continue receiving this information, please sign up at this website, http://wdfw.wa.gov/lists/, and select “WDFW Regulation Updates.” The public news release will continue to provide contact information for those that need a hard copy.

In case you are unable to or do not wish to attend the public hearing, you may submit written comments to me, Charmane Ashbrook, as shown below. WDFW must receive comments by June 9, 2015. For an electronic or printed copy of the proposed rules, please email me at Charmane.Ashbrook@dfw.wa.gov or call me at 360-586-0734.

Charmane Ashbrook
600 Capitol Way N.
Olympia, WA 98501-1091
via e-mail at Charmane.Ashbrook@dfw.wa.gov
via fax at (360) 902-2183.

Attached and below are comments on the final draft of the WMP put together by the Advocacy. I think that about 18 of us signed on to the letter which is a bit of a shock as getting on the same page was similar to herding cats! Key things?

• A 14% harvest rate for both the North & South portions of the bay.
Modified
• 2.Modified Option E is the only way to go.
• Also staff is playing games with a couple things identified.

So take a look and see what you think. I have some additional thoughts I will get out in the next couple of days but we are getting close to closing time.





WB Request For Adoption Of An Interim Policy For Willapa Bay Fisheries



May 26, 2015 Via Email

The Honorable Members
Washington Fish and Wildlife Commission 600 Capitol Way N.
Olympia, WA 98501-1091

RE: WB Salmon Management Policy Recommendations

Dear Commissioners:

The 17 individuals who have served on the Ad Hoc Committee or regularly attended the public meetings in Raymond that are shown as endorsees below have reviewed the latest draft for a new salmon management policy for Willapa Bay. We respectfully reject Alternatives A-D and endorse Alternative E. Further, we offer several suggestions for improvements to Alternative E that we believe would prove helpful to restoring natural spawning stocks and increase the likelihood that recovery can be attained within the next two decades.

Our suggestions to Alternative E have been incorporated into the latest draft produced by the Department and attached in a PDF file format. The attachment shows deletions in red strikethrough and our additional language or changes in blue (see Strikethrough_Option E with improvements.pdf).

We offer the following comments and recommendations to the members of the Commission regarding the numerous alternatives for Chinook management.

Alternatives A-D All of these Alternatives are fatally flawed for the following reasons:

1. The AHA modeling during the ad hoc process found a maximum harvest rate of 14% on both the south and north tributaries would be required in order for natural spawning to recover within 16-21 years. The harvest rate of 20% or 14% on only a single river (Willapa) with no limitation on others will delay recover further into the future and creates a scenario where recovery is likely to never be achieved in the majority of tributaries throughout the rest of the bay. Last season, the harvest rate was capped at 20% in the Naselle only. The end result was a harvest at 38.8% in the Naselle and significantly higher in the Willapa. Having a single stream harvest rate has led to the Department setting seasons that dramatically increase the harvest against the other streams that are provided little if any protection from over-harvesting. The harvest occurring on the non- index streams during seasons installed by the Department has exceeded the harvest rate maximum for the index stream by a factor of 3-4. Use of a single stream as a harvest index will effectively delay if not block entirely, the restoration of natural spawning on the other less fortunate streams.

2. The use of "aggregates" creates similar problems for in season adjustments and managing for escapement goals. In essence, all the stocks in all the different tributaries are combined for harvest management or spawning escapement into a single Chinook, Coho, and Chum for the entire bay. While the Department's harvest model and the AHA model separates the different river runs for harvest rates and escapement goals, Alternatives A-D basically allow the Department to ignore over-harvest occurring on Chinook in one or more streams by linking in season adjustments to an aggregate number for the entire bay. The same linkage is installed for escapement goals for Coho and Chum. The use of aggregate thresholds allows the Department to regularly fail to reach its goals for harvest or escapement as long as it can get a portion of the Bay to compensate for the other. One example would be having Chinook restoration occurring in the northern tributaries where recreational priority has been limited while over-harvesting with the commercial sector on all the southern tributaries is preventing escapement from occurring. A reverse example would be having Coho in the south coming out of the Naselle with its problem weir cover for a decline in Coho occurring in the Willapa or North River. Hatchery Reform should apply to the entire bay, not just a single stream.

3. The Chinook hatchery production in the future will drop dramatically out of Forks Creek in the Willapa River. Restoration of the natural spawning production quickly as possible is of critical importance if one wishes to have any meaningful harvest opportunity once the past hatchery releases have cleared. It is therefore imperative that hatchery runs returning to the Willapa River over the next 4 years be allowed to jump start natural spawning (adverse impacts to current natural spawners is not expected as the stray rate has been historically high as 4-1 hatchery fish over the last decade). The Chinook "stage up" in the lower stretches close to the mouth of the Willapa in late August and early September in the lower reaches of the Willapa River waiting to spawn. These staging areas are included in marine Area 2U and open to commercial harvest approximately 5 miles up from the mouth of the river to the 101 bridge in Raymond. Alternatives A-D install the commercial fleet in 2U after Labor Day in the first four years and then not prior to September 16 in the second phase. While filling nets with the last of the large hatchery releases will be financially rewarding to the commercial sector over the first 4 years, it will leave the Willapa River effectively "clear-cut", delay recovery, and at the same time, provide little meaningful harvest opportunity in the future for others once the nets are cleared back.

4. Hatchery Reform seems to the public to be a procedure for operating hatcheries in a manner that is compatible with the native spawning populations. The creative use of stream designations contained in Alternatives A-D that move streams with existing hatcheries down to the lowest ranking of stabilizing effectively negates the implementation of Hatchery Reform. As an example, the Naselle has one of the better Coho natural production spawning capacities that warrants recognition as either a prime or at least a contributing but also has a hatchery with a weir problem that allows excessive hatchery straying into the spawning grounds. The most obvious simple solution would be to cure the problem with the weir. The solution contained in Alternatives A-D is to creatively insert a stream designation of "stabilizing" to the Naselle for Coho effectively making an "end run" around HSRG standards for straying. To label hatchery streams like the Naselle as stabilizing effectively stands down hatchery reform except in those areas where no hatchery exists.

Alternatives E The general language of the full policy and the hatchery production levels create problems for many in the public sector. Such is especially the case for those who recreational fish for Chinook in the north who will see Chinook production in Forks Creek decline dramatically due to the lack of a weir in the mainstream of the Willapa
River. Alternative E is the only alternative that rises to the challenge of installing hatchery reform and seeks to achieve restoration of natural origin populations during most of our lifetimes. Simply put, AHA modeling shows that it is unlikely to achieve restoration within the next 27 years unless a maximum harvest rate of 14% is installed for both, the Willapa and the Naselle. Having a harvest cap for both provides necessary protection from seasons being set that over-harvest in either end of the bay. Without a cap on both, one end of the bay or the other is not likely to ever see natural spawning populations recover. Therefore, Alternative E is the only alternative that provides a potential for successfully recovering natural spawning Chinook in Willapa Bay.

We offer several suggested changes to Alternative E that we believe would greatly enhance the policy in fulfilling its purposes and reaching the goals. The changes are relatively easy to install and are included in the draft language markup that is attached. The changes are as follows:

1. (Addressing the aggregate problem) Under the "Guiding Principals" section, add a new subsection as follows:

12) When managing fisheries using an “aggregate”, the Department shall utilize an aggregate of streams flowing into the north of Willapa Bay (Areas 2T, 2U, 2K) and an aggregate of streams flowing into the south of Willapa Bay (Areas 2N, 2M, 2R, 2P).

2. (Addressing the need to let the next four years of Chinook hatchery returns accelerate the restoration of natural spawners in the Willapa River) In Alternative E, delete the early start time of commercial seasons in the north set forth in Phase 1 and use the start times found in Phase 2
for years five and beyond. The effect of this change would be to move the commercial start time back from “after Labor Day” as set in the current draft for Phase 1 until September 7th in the south and September 15 in the North as set forth under Phase 2.

3. (Addressing the two options for Chum harvest) Under Section 3) of the Chum Salmon heading, select Option B for harvest impact limitations which is based on the language contained in the GH Policy.

Again, the individuals listed below that have served on the ad hoc committee and attended the public workshops in Raymond for all these months are requesting that the members of the Commission incorporate Alternative E into the new policy. Further, while the suggested changes shown above might seem relatively minor to some, the recommended improvements to Alternative E listed above will greatly improve the chances of success for the new
policy. Therefore, we strongly encourage the members of the Commission to consider our suggested improvements to Alternative E for incorporation as well.

Sincerely-

The following are comments from a AD HOC member of the Willapa Management Policy Advisers. I think his comments mirror what many others are saying. It is time for all to get their thoughts on the WMP into the Commission. For all whatever your thoughts the 14% harvest rate for the ENTIRE Willapa Estuary is critical.




Sent: Wednesday, May 27, 2015 11:36 PM
To: 'director@dfw.wa.gov'; 'commission@dfw.wa.gov'
Subject: Willapa Bay Policy.

Dear Commissioners and Director,

I am writing to provide feedback on the ongoing Willapa Bay salmon policy development process.

I was recruited as an ad-hoc member last year and have been following the process closely, including attendance at several of the town hall meetings, advisory meeting, and commission meetings. As a recreational angler for salmon, I view the process through the prism of angler opportunity and have advocated for a policy that maximizes economic benefits while achieving the commissions stated conservation goals.

In particular the chinook policy options under consideration fail to maximize economic benefits relative to natural origin chinook spawners, and only one (option E) has any hope of achieving the stated conservation goals 20 years from now. As the policy process has evolved, it has become increasingly clear that WDFW staff are pursuing an agenda independent of public input that maximizes gillnet harvest at the expense of both conservation goals and other user groups. If this is really the intent of the policy, it should be clearly stated as such, and I will accept this. As it stands, the policy suggests that commercial harvest and recreational opportunity are balanced priorities secondary to achieving conservation goals.

The actual situation deviates considerably from the stated policy. At the outset of the policy development process, the commission articulated a vision for a recreational priority for chinook management giving some hope that the very least a balanced approach to allocation issues might at last be achievable. From that initial guidance, WDFW staff have somehow arrived at a policy where 4 out of 5 options will clearly increase gear conflicts between the commercial and recreational sectors and all options allocate the vast majority of impacts to the commercial fleet.

Equally important, all policy options are predicated on a more than 10-fold reduction in hatchery chinook production at Forks Creek (from 3,200,000 to 300,000) which supports the majority of marine recreational chinook opportunity and over a third of the Willapa bay tributary freshwater opportunity for chinook. Please see attached information. Both these changes will dramatically reduce recreational chinook catch and meaningful opportunity. I fear that once fully implemented the policy will essentially eliminate meaningful marine recreational chinook opportunity in Willapa bay.

To conclude, it is difficult to imagine how I could be more dissatisfied with my involvement in the policy adoption process. It has become crystal clear that the entire process is governed by political considerations rather than science/conservation or public involvement. It is equally clear that all of my input to WDFW, based on a good faith analysis of existing data provided by WDFW staff, has been disregarded in the decision making process. Likewise, the process itself has been tarnished by the unprofessional behavior of several members of the advisory committee.

Taken together, my experience with the Willapa Bay advisory group and the general outcomes at NOF over the past several seasons suggest that WDFW is doing a poor job of managing the state’s salmon resources; management decisions are clearly focused on the desires of select special interest groups rather than the needs of the majority. If this downward trend continues, my family will spend its time on the water, license fees, and recreational fishing dollars outside the state of Washington as our neighbors to both the north and south do still seem to value recreational salmon fishing for its considerable economic impacts.

Sincerely,

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

I thought I would post this paper sent to the Commission on the Willapa Estuary & its condition by a local advocate. I think he captures the issue.


Executive Summary

The ecological status of Willapa Bay, Washington, has changed rapidly in the last fifteen years, and not for the better. All of its iconic wild species of animals and plants are in a deteriorated state. These changes are impacted by action of state agencies, recently at an accellerated pace. While the bay suffers from long term neglect of salmon management standards and habitat protection statutes, recent actions are piling on losses at a more alarming rate. Where goals exist, they are not being met. " No net loss of ecological function" is the law of the state. Unmonitored net loss, or monitored with no effective corrective action, has been the practice in Willapa Bay.

Analysis

A major invasion of the plant spartina proceeded over several decades. It was displacing eelgrass and needed to be removed. Suddenly, about year 2000, excess caution was replaced with no caution and a massive spray campaign ensued. As a result, spartina was largely removed, and by 2008 large, collateral damage resulted. Chum salmon and waterfowl immediately declined. During the bulk of spartina removal, eelgrass net loss was not monitored, in keeping with tradition. Only one aerial survey of eelgrass can be found, published in 2007. Even this late survey shows Zostera marina where it is now absent and has never returned. None have been published since. Waterfowl surveys were suspended during the entire spartina campaign. The larger eelgrass, Zostera marina, and the smaller eelgrass, Zostera japonica, which we call "duckgrass" suffered major collateral damage. Pacific Brant, which rely on marina, have never recovered, nor has marina. Duck grass recovered more rapidly in the more suitable areas, as did the ducks that depend on it. Waterfowl surveys, reinstituted in 2012, showed good numbers for two years, followed by a crash in 2014 with the onset of a spray campaign directed at eelgrass. Chum and Chinook salmon escapement of Natural Origin Spawners (NOS) failed to meet WDFW goals starting one spawning cycle after the spartina program did, and have never recovered. The NOS Chinook do not show up in acceptable numbers, and those that do are genetically, statistically, overwhelmed on the spawning beds by by more numerous hatchery fish that are less reliant on bay habitat to survive the juvenile portion of their life cycles. This is now true for every major river in the Willapa Drainage. In the North River they are essentially gone. This is one of the two rivers earmarked for NOS Chinook recovery several years ago, when there were many more present. Poorly situated overharvest finished the job on North River. Endangered Green Sturgeon and white sturgeon are gone fron Willapa Bay. We have new leadership in WDFW. It is concentrating on harvest. We have hope. Still, WDFW seems to have little to say about habitat, the other root cause. This must follow.


Historically both species of eelgrass were protected by a state " no net loss" requirement. Their restoration was required, and this was not monitored or enforced. In 2011, WDFW removed duckgrass from protected habitat status. This was the enabler for a chain of events involving multiple state agencies which ended in early 2014 with issuance of a Department of Ecology NPDES permit to chemically remove duckgrass, along with marina on the bed being treated. In keeping with tradition, this permit requires no monitoring on net loss of marina, and no restoration. It is backed by an Environental Impact Statement that assumes waterfowl forage requirements one thousand times less than truth. The major math "error" that caused this has been pointed out, and remains uncorrected. At the request of the state Departent of Ecology, an appeal of this permit has been delayed until October 2015, allowing another year of wide open spraying. In 2014, waterfowl numbers crashed again in Willapa Bay. Along the Long Beach peninsula, where there are normally several thousand ducks at peak, there were 32 widgeon and zero pintail observed. The bay wide peak average of 85,000 over the previous two years dropped to 22,000 in 2014. Such a drop has not been counted in thirty years. In 2014 flyway numbers were above average, but not in Willapa Bay. In Puget Sound eelgrass is being restored, while it is being removed in Willapa Bay. Both species are protected in Puget Sound, although Ecology has now asked them not to.

To the casual observer, it must seem shocking that things can happen so fast, with spraying that "should" be diluted by tides and carried out to sea. This was the claim of the state permit's impact statement. Actually, bad things can happen fast because Willapa Bay has a peculiar circulation pattern which moves seawater and pollutants with a net inflow on the west side. It goes south of a dispersion or low flushing zone and stays there for many weeks. The average age of water south of Nahcotta and Bay Center is 45 to 60 days. Eventually this water and contents are carried back out on the east side to the North. When a certain seasoned oceanographer pointed this out, the state attorney general labelled him unqualified to speak. Back in the day, such estuarine types were called Vertical Boundary Estuaries. Today a more recent UW paper on Willapa Bay has different labels, but has shown exactly the circulation of such an estuary. It contains exquisite detail, makes the same points about flushing and circulation, and receives the same state consideration, i.e. none. Apparently DOE has repealed density gradients and Coriolis Force, along with fish biology and waterfowl carrying capacity math. Chemicals that, in minute concentrations, can retard plant growth without killing or deforming, are circulated and retained in a situation that should be alarming. The ducks knew the condition of their food, ate what little was there, and left. Salmon and sturgeon are stuck in this cycle. With any overharvesting, they just disappear.

After ten years of " no targeted harvest", chum salmon, which used to fill a bay with a carrying capacity of 80,000 to 200,000 now cannot make an escapement goal of 35,000 fish. Chinook have made their escapement goal once in fifteen years. Brant are almost gone. Ducks are at a 30 year low. Sturgeon are gone, with zero retention allowed. Green sturgeon are endangered. After a few decades of removal of their favorite forage, burrowing shrimp, it is over for them. We now can see that carrying capacity, in addition to harvest control, is the key to all of the above and the bay has lost much carrying capacity for our iconic species. They all depend directly or indirectly on eelgrass. This key habitat is being removed under state permits and negligence of our own standards.

The waters of Willapa Bay were put here by the world's great flood. Under the waters are the eelgrasses. Under the grass are their words. How long will these words haunt us?

I thought I would get this Letter To The Editor out that was published in the Chinook Observer May 27th. It is a interesting read and I think relevant to the Willapa Management Policy that is soon to be adopted. So read on and a big hand to Marlisa Williams Dugan for speaking out!



Sport fishing great in bay in 2015

Past commercial over-harvesting of our naturally spawning Chinook has placed natural-origin spawners at critically low levels. Protecting this population today is urgent to avoid possible Endangered Species Act (ESA) listing in the not so distant future. Our best science tells us that even with a reduced 14 percent commercial impact on Chinook we can only hope to make our projected escapement goals in 16 to 21 years. Good grief, some of us might not live long enough to see that happen.

We can’t control global warming and changing ocean temperatures, which will likely contribute to a decline in future salmon returns. But we can begin to control how many Chinook salmon get to the spawning grounds. It’s high time we began managing for a self-sustaining wild population in meaningful numbers along side the abundant hatchery productions we all need to have a decent fishing day.

ADHOC committee members like myself strongly advocate for more recreational fishing opportunity. The gillnetters have been consuming around 93 percent of the returning salmon population, with the recreational fishing community getting approximately 3 percent. It’s like running a handicapped race, with no legs.

1. Selective fishing gear is required for recreational users: barbless hooks, no nets, release all wild Chinook, fish the bay after the commercial fleet has cleaned it out, and freshwater opportunity is the trickle down left over theory.

2. The commercial fleet has been allowed to use a non-selective gillnet and kill nearly the entire projected run of the wild Chinook population in 2014. They’ve had inadequate monitoring by the Department of Fisheries and have never fished within the projected impacts given. If the Willapa gets ESA listed it will be the fault of every gillnetter and Fisheries Department personnel who assisted in creating the commercial gillnet seasons on Chinook.

I want to believe there are good administrators within Department of Fish and Wildlife and the Fish and Wildlife Commission today who are willing to make a stand with conservation and to allocate our salmon evenly between the user groups — 50 percent of the returning Chinook salmon should belong to the commercial fleet and 50 percent should belong to the marine and freshwater fishers. The commercial fleet should be held to fishing within the impacts allowed on troubled species, end of story, no dispute!

The quicker we can jumpstart these declining Chinook and chum populations, the quicker commercial impacts will increase to more acceptable numbers. Alternative, selective commercial fishing methods are needed to allow targeting the abundant hatchery Chinook populations.

Sadly, throughout the advisory meeting process only one single gillnetter continued to attend the meetings and work the process, discussing the dreaded tangle net, and that was Allan Hollingsworth. Through adversity and disappointment he conducted himself like a gentleman. The political fallout from being on the opposing side of this struggle between the commercial gillnetters and the conservation supporters has recreational fishers and conservation supporters being attacked by gillnet propaganda.

First, let me state my support of Miranda Wecker from Naselle. Miranda has conducted herself with political decorum we can all learn from. The citizens of the state of Washington are fortunate to have an individual of this caliber appointed to the commission. Amidst underhanded political maneuvering to remove her from her influential position as the chairperson on the Fish and Wildlife committee she stands tall and resolute, trying to do the right thing for your fishing future. She has seen the scientific data and listened to the information presented by biologists, the Department of Fisheries and the ADHOC committee members. She understands the importance of taking preservational steps today, the importance of getting our head out of the sand and beginning the process of rebuilding our naturally spawning Chinook salmon before we get ESA listed on Willapa Bay Chinook.

For the record, I support commercial fishing to feed those who don’t fish for themselves. Commercial ocean fishing and inland bay commercial fisheries are facing changing times. Willapa Bay had more Coho than the commercial fleet could catch in 2014, fishing seven days a week, 24 hours a day. Good for them! I’m glad for these extravagant returns and hopefully a silver lining in their pocket books. As long as they can fish on a targeted species without deprecating another, have at it. There is room to share our salmon populations with more equal distribution among conservation, commercial and recreation.

The Department of Fish and Wildlife Commission, after much resistance, has been able to implement an interim policy for 2015 that guides the Washington Department of Fisheries to manage the wild Chinook fisheries with greater conservation. This policy opens the door for the selective sports fisherman to scoop up thousands of abundant hatchery fish this year:

1. No commercial fishing until after Labor Day in 2015.

2. The commercial fleet is reduced to a 14 percent impact on wild Chinook. This means once they have killed 14 percent of the naturally spawning Chinook they cannot fish again until the Chinook run is out of the bay. This new policy has re-directed the commercial fishermen to using their impacts after Labor Day, focusing on the Coho season in September — placing the commercial focus on Coho.

3. Recreational marine bag limits will be six fish, four adults, release all wild Chinook.

Willapa Bay is considered a build up fishery. The Chinook start migrating into the bay in late July and early August in meaningful numbers. They begin staging for the different rivers moving into separate areas of the bay as the season progresses. The Coho and the Chinook start to be a mixed bag in mid-August. In 2015, the bay should be piled with abundant hatchery Chinook and Coho with the absence of all commercial fishing until Sept. 8 this year

Freshwater fishing promises to be excellent also, with a four adult bag limit — all freshwater areas — release all wild Chinook at the start of the fishing season.
Recreational advisors have been advocating the re-opening of closed freshwater areas on the Naselle, Nemah and Willapa for 2015 to increase recreational opportunity … legal issues are being addressed regarding the ability of the Department of Fisheries to keep rivers closed where and when no conservation limitations apply. All Willapa tributaries should see Chinook entering the rivers in larger numbers prior to Sept. 8 this year due to gill net restrictions. The next four years promise a freshwater recreational opportunity on Chinook prior to Labor Day on the Willapa and the Nemah unlike anything we’ve seen. Abundant hatchery Chinook could flood these rivers with a little rain at the right time. It’s time to dust off the fishing gear and pursue your share.

Please remember to respect private property. Property owners who post their land expect you to stay off. Scoping out permission in advance this year could give you an advantage. Ask permission prior to entering or get guidance to publicly available areas. Trespassing violations can be prosecuted. Williams Park on the North Nemah is stepping up to provide additional recreational opportunity by sponsoring a day of fishing in August for the Wounded Warrior Program — disabled veterans can make contact at fishthenemah@comcast.net for details. I am coordinating the event. A non-disabled companion must accompany each disabled fisherman. Day parking and restrooms are available. Golf carts can assist with transportation to and from the river for those that need it. The event honors our wounded military men and women.

If I were the South Bend Chamber of Commerce I would be busy facilitating extended parking for the Ron Craig Boat Launch. Some type of overflow parking and shuttle service will be needed or boaters will go elsewhere. Unparalleled Chinook and Coho fishing opportunities will continue in 2015 through 2019 regardless of budget cuts or hatchery productions to come in the future. These salmon are already out there, growing and on their way back to the Willapa. This, combined with the ESA listing of Puget Sound Chinook, has thousands of boaters looking for somewhere else to fish. The protected water of Willapa Bay offers an attractive alternative for those unwilling to brave ocean fishing or the Columbia. South Bend and Raymond are woefully unequipped to facilitate camping and housing to keep these recreational dollars from escaping. Picturesque South Bend could become the new Tillamook of the west coast if they can keep the salmon supply steady. Opportunity is knocking, it will be interesting to see if the business community can rise to the bait.

I would love to see South Bend and Raymond overflow with a fishing tourist trade this summer … someone should address the boat parking issue.

Marlisa Williams Dugan

WDFW has dropped the CR-102 for the 2015 WB commercial season and the public hearing is set for Tues June 9 2015 9:00 AM at the NRB.

I see that the entire August "dip in" has been eliminated.

First comm opener is delayed until Sunday Sept 13 in areas south of the usual/customary rec fishing zones.

2T opens Monday Sept 14 AFTER the weekend rec fishery is done.

These are GOOD things that have happened due to the diligent work of non-commercial advisors and the Twin Harbors Fish/Wildlife Advocacy. Give them a BIG round opt applause!

I suspect the commercial sector may show up in force to object to the proposed season in the CR-102.

If you are unable to attend the hearing, written comments in support of the CR-102 can be submitted to:

Charmane Ashbrook
600 Capitol Way N.
Olympia, WA 98501-1091
via e-mail at Charmane.Ashbrook@dfw.wa.gov
via fax at (360) 902-2183.

At a first look both Grays Harbor & Willapa appear to comply with the management policies for both. In GH the putting the NT nets in on Sunday is a bit problematic as it takes away the Lakeside ( above the 101 bridge ) and Port reach's for the weekend fishers. ( it is a mom & pop type fishery ) As they have a unique way of calculating partial days one does not want to drop in days for impacts without the numbers so I have requested the models so one can see the projected impacts by species.

As to fresh water ( inriver ) those changes are not in the Rec NOF CR102 that was filed. I assume that staff will use a emergency rule to update those. Assume is the key word here.