Smalma,

While I appreciate your posts and your insights on most every topic you choose to participate in, this one is not one of them.

Without directly addressing your last post head on, I'll do it via questions:

1. What is the stock status of the Methow River fish compared to the weakest stocks of the LCR listed fish?

2. Compare/contrast the expected encounter and mortality rates of a Methow River sport fishery and a LCR gillnet fishery (encounters and mortality rates on listed fish).

3. What is the allowable ESA impact on the listed fish in each fishery, and how are each fisheries doing relative to that impact?

4. What would happen to a Methow River sport fishery if it either:
a. Encountered many more times the amount of listed fish as was previously expected, and
b. had a mortality rate as high as the LCR gillnet fishery?

5. Related to number 4, in order of likelihood, which actions would managers take if the Methow River fishery enounted, say, 700% of the expected encounter rate, and had a nearly 50% mortality rate?
a. nothing and allow it to go on
b. close the fishery
c. search for some sort of fishery that would dramatically lower either the encounter rate or mortality rate
d. ask NOAA to triple the allowable impacts so that the fishery could go on as is.

Before you put in your answers, I'll give them a general shot without the benefit of having the numbers in front of me.

Both runs of fish are listed. The Methow fish are doing fairly well, existing above replacement level consistently. The Methow River fishery is being prosecuted over a sinble run of fish.

The LCR net fishery is being prosecuted over dozens of individual runs of fish, some of which are in dire straits.

The Toutle River stock, among others, in the LCR are barely at replacement level, and any increase in impacts is likely to result in their extinction (per WDFW and ODFW biologists).

The encounter rate for the Methow is somewhere in the neighborhood of 1/100 or 1/1000 of that of the LCR gillnet fishery.

The mortality rate for fish encountered on the Methow is probably around 2% (barbless single hooks, no bait, cold water)...the mortality rate for the "gillnet and release" fish is, what?, around 50%?

If the Methow fishery could somehow magnify its impacts a hundredfold, or a thousandfold, it would be closed. Period.

The actions that regulators would take, in order of likelihood, would be as follows:

1. Close it (100% chance)
2. Modify it (0% chance)
3. Seek to change allowable impacts, lower the bar as it were, to make the fishery all of a sudden "successful" (0% chance)
4. Do nothing (0% chance)

So, we have a sport fishery that has a measurable, but extremely low, encounter and mortality rate, that would be closed at the drop of a hat if there was any hint of overfishing...this on a run that is existing well over replacement level.

Next, we have a "gillnet and release" fishery that has an encounter rate that is astronomical...nearly 70% of the catch is non-target, ESA listed fish, and the mortality rate is through the roof.

Components of the LCR ESU are existing right around replacement level (a bit above, at, or a bit below), and both states' bios have stated that some of those components will go extinct if the impacts are increased.

The mangers' response when faced with this scenario?

They ask to raise the allowable impacts 300% so that they can legally kill many more ESA listed steelhead and spring chinook while harvesting hatchery chinook.

This argument, while compelling enough as it is, doesn't even bring in the economics of the situation, which is so astronomically in favor of NOT having that net fishery at all, much less with the triple impacts.

Attempting to characterize outrage at this situation as being hypocritical is not only trying to draw comparisons between apples and oranges, it's drawing comparisons between grains of dust and the plantet Jupiter.

Am I that far off base here?

Fish on...

Todd

How do the fisheries people know how many steelhead are killed in gillnets each year? Do they check the commercial netters on each trip out to pull in there catch? How can you selectively change the percentage from 2 percent to 6 percent mortality? It seems like the only way to kill more steelhead would be to leave the nets in longer. Are they going to allow for a longer commercial season?

Luke,

There are various ways to make use of the increased impacts...

The season length could be increased, soak times could be increased, and geographical areas open to netting could be increased...likely it would be a combination of two or three of the above, if the increase is granted by NOAA-F and the State Commissions allow it to go forward.

Fish on...

Todd

Todd -

Status of the Methow wild steelhead - ESA listed as endangered - that is likely to go extinct.

Status of the lower Columbia River wild steelhead - ESA listed as threatened - that is likley to become endangered.

Just to check my facts I quickly referred to WSC's draft steelhead white on steelhead status and the authors confirmed my recollection of the status of the two populations. So in short the status of the Methow fish is in worst shape than the LCR populations.

As I recall the sport fishery on the Methow was a selective fishery targeting the hatchery fish returning to the river and it was to last until the number of wild fish encounters times a hooking mortality yielded an impact on the wild population of 1.8% (I may have a detail or two wrong as I don't following things on that side of the state too closely).

The commerical impact on the lower Columbia Fishery was to be capped at 6%. Given the Status of tne Methow fish (ENDANGERED) versus the status of the LCR fish (THREATENED) I have at least as great of concern about the 1.8% impacts on the Methow population as I do about the 6% impacts the LCR population. You of course are free to feel differently.

Again I feel strongly that if one is to lobby for the fish we need to do so consistently across all fisheries if we are to maintain our creditability. Given that belief I will continue to point out what I consider to inconsistent positions as my primary concern is the fish - sorry if that offends you.

As always I'm more than willing to explain and/or defend my position or to supply information so that others may make their own informed decsisions.

Happy Holidays and my the New Year bring you tight lines
S malma

Smalma,

Thanks for the quick response...

The private world, just like the public, is not blessed with unlimited resources, including manpower, money, or time.

Battles have to be chosen based on several different factors, including immediate necessity, ability to affect the outcome, and costs/benefits of acting or not.

On the Columbia River gillnet-n-release issue, there are tens of thousands of wild steelhead to be affected, there is a blatant sell-off of sportsman driven recovery efforts for small commercial fishery gain, there is a total disregard for components of the ESU's steelhead runs, the economic emphasis is grossly overbalanced against the fishery at all, much less one with tripled impacts...and it can all be avoided by those who wish to benefit from the increased impacts.

It is a dangerous example to set that if the fishery is woefully inadequate at providing any fruitful economic returns and woefully inadequate at being prosecuted anywhere near acceptable impact levels, that rather than require that the netters (and their friends at Reg. 5 and the Director's Office) be proactive in creating a fishery that has less impact and more economic returns, that they pursue instead a lowering of the bar, a significant lowering of the bar, to re-define "success" as what they are already doing, rather than change what they are doing to achieve "success".

The equivalent would be sportfishermen wanting to harvest wild steelhead on the Skykomish, and rather than support recovery efforts, and when the fish are sufficiently recover, fish in appropriate times, places, and manners to have harvest and assure preponderance of the runs, they lobby instead to just lower the escapment goals by 60%.

If the escapement goals were lowered by 60%, all of a sudden the Skykomish recovery efforts are an overnight success...the river is over escapement, and we can fish with impunity.

This is by redefining success, rather than actually achieving it.

Perhaps it would be more appropriate if we were perpetually stuck in the year "1984"...which, thankfully, we are not.

Would you have supported such an action on the Snohomish system in 2002 if the sportsmen pushed for it? Would you have gone to bat for them to get it done?

I'm guessing not...but it's what the managers at Reg. 5 are asking NOAA-F to do, and next month they'll be asking the Commision to sign off on it, and fishermen and advocates are not going to take it sitting down, nor are they going to feel bad about doing it because there is a sport season on the Methow.

In my last post to you I was not asking the legal status of the Methow and LCR stocks...I was asking the biological status, the r/s ratios, the replacement levels. There are certainly fish with "legal status" who are doing well, and some (PS Steelhead, for example) with no legal status who are doing very, very poorly.

If your point has been to show disdain for effort in one area while other areas are going unaddressed (regardless of magnitude of the issues), then your point has been made.

What then do you think about the merits of the Columbia River Gillnet-n-Release fishery, its biological and economic impacts, and the reasons for and against tripling the allowable impacts?

Thanks, as usual, for your time...I appreciate your points and responses very much.

Fish on...

Todd

P.S. I do not view this as an allocation issue...arguments for and against who gets to kill the most or the last fish will all be hashed out, too...but in this case, there is no allocation issue.

There is no allocation issue because the entire increase in the impact will go directly to the commercial fleet...and the issue is how biologically sound that is (or is not).

If sportsmen were going to see some of that increase, and they and the netters were arguing over who gets what percentage of it, then that would be an allocation issue.

This is about should the increase even exist at all...which I believe, it should not.

I am so pleased that I totally agree with Ramon for a change. Thanks for the insightful response that I think is right on target.

Smalma

I think Todd is correct in that we pick our fights as sports fishers. As a group we have not done all there is to do by any means but we have done more than other user groups towards cutting back our efforts to save fish. You can go down that all of nothing road if you want but this is a specific fight with some real ramifications for many other issues to come. This is a lopsided proposal to try to benefit a very small and not economically viable group. This is the same group of netters who refused to allow observers on board last season.

The bottom line is that there is just no logical justification for more netting when ESA listed or even threatened stocks are swimming in the same column of water as the target fish. Netting is too final, too all inclusive.

This proposal is nothing more than a changing of the rules to benefit a user group that cannot limit their impacts. Once the expanded fishery is allowed and the impacts even exceed the new 6% limit they can just say. Oh Well we did the best we could. Then the damage is done and the sports fishery gets to close to make up for yet another excess by the commercial fleet.

Sorry Smalma but I think your criticisms are too narrowly focused.

Must be the holiday season...

...Grandpa, Ramon, and Todd all agreeing on the same thing?

Ramon, didn't see your note to give you a call until now...sorry. I'll PM you with my cell number, or I can call your store over the weekend if you will be there.

Fish on...

Todd

Here's mine:

I am deeply disturbed by the Commission’s attempts to triple the allowable mortality rates on endangered wild winter steelhead “incidentally” caught in the Lower Columbia River tangle/gillnet fishery targeting hatchery spring chinook.

The entire sportfishing and conservation community is outraged by this irresponsible proposal. The conservation efforts and sacrifices we have made are paying off in healthier steelhead stocks. From leading the charge for selective fisheries, changing hatchery practices, promoting habitat restoration, to insisting on more responsible hydro-power practices, we sportfishers have fought hard to protect wild steelhead. We did not make these investments to restore wild steelhead only to have them die as bycatch in tangle/gillnets.

Indeed, many of the stocks are still too fragile to even consider raising impacts against wild steelhead. For example, WDFW biologists believe that tripling the netting impact would probably drive the Toutle River wild winter steelhead run to extinction. Furthermore, ocean conditions right now are extremely beneficial to wild steelhead returns. If we want the most “bang for our buck” to help endangered steelhead, now is the time to invest in additional estuarine and riverine restoration efforts, not in increased netting mortalities.

To their credit, WDFW has been testing the efficacy of small-mesh tangle nets over standard large-mesh gillnets to improve release mortalities for endangered wild spring chinook. But the unexpected results are irrefutable; while tangle nets help to reduce wild chinook mortalities, they are extremely efficient at killing non-target steelhead. Clearly, there are other methods of commercial harvest that allow the unharmed release of wild steelhead, yet they are not implemented or even considered. Instead of insisting that the commercial fishery improve the selectivity of its methods in targeting hatchery spring chinook, WDFW irresponsibly opted to request an increase in allowable bycatch mortalities. It’s not much different than asking a school system to lower its testing standards instead of re-tooling the curriculum to achieve better performance from its students. This is just plain wrong!

I believe your primary concern should be shaping policy to rebuild wild salmon and steelhead stocks. But there are important socio-economic issues as well. Because it will result in predictable cuts in future sportfishing seasons, this proposed action affects tens of thousands of sport fishermen and millions of Washington residents. This translates to reduced recreational fishing expenditures that fuel the southwest Washington economy as well as WDFW coffers. This proposal benefits a handful of commercial netters who profit at the expense of all other citizens. Listen to the collective will of the people and consider the plight of endangered salmon and steelhead stocks, then let your conscience be your guide. Do not allow this preposterous plan to be implemented.

TTT

Very nice letter, Doc!

This is from a post I put on another site...

********************
Ladies and Gentlemen,

Preliminary information is that the ODFW Commission will be having a public hearing on this issue in the first couple weeks of January, and that the WDFW Commission will follow suit about the same time, perhaps a little after.

It will be very important, besides writing letters to both Commissions and both Governor's offices, to go to those meetings, sign up to testify, and testify.

We really need to pack the places with people against this increased impact, and remind them that no matter what NOAA-F rules about the increase, that they alone are responsible for protecting wild fish runs and fishing in their respective states, and to not let parts of the LCR ESU go extinct, and to let decades of sportfishing restrictions, hydropower, and habitat work result in a short term economic benefit to very few people.

Biologically, economically, and culturally this proposal has very little, if any, merit.

At the meeting, after a few people testify, they will generally ask, due to time constraints, that if more people are going to come up and testify to the same thing as previous testifiers, to agree to not testify.

Don't take the offer.

If they have to stay for eight hours to allow each and every person to go up and have their say, then demand that they do just that.

Unlike the LCR managers from both states, who have been, and really are here, going to bat for the commercial guys, I think that the Commissions would like to do the right thing, and it would really help them out to give them a crutch to lean on, namely that overwhelming public sentiment has forced them to NOT authorize fisheries that will take advantage of any increases allowed by NOAA-F.

This also is not a "home state" issue...anyone from Washington, as I am, that can make it needs to go down to Portland and testify at the ODFW meeting...after all, they are making decisions that affect "your" rivers and fish...same with the Oregon folks, as many of you who can need to drive up to Olympia and protect "your" rivers and fish, too.

The last few years, and especially the last few months, make it very clear that we in the PNW are not going to get any help from the powers that be in D.C. in protecting our culture and our fish...we need to make it clear that we expect our State Commissions to do it.

Fish on...

Todd Ripley
VP Political Affars
Wild Steelhead Coalition
http://www.wildsteelheadcoalition.com
c_n_r_nates@hotmail.com

Nice work on this issue, Todd.

But seriously, time to get off your keyboard now and go out and catch a steelhead.

Doctor's orders!

BTW I'm headed out the door now to do the same.

Doc,

This time of year I have the opportunity to fish once or twice a week...and I can pick my days, depending on my schedule.

If I can pick my days...Saturdays aren't them!

Unless, of course, someone wants to take me in their boat...then Saturdays are looking a little better!

Fish on...

Todd

P.S. Got to fish on Monday and Wednesday...four steelhead hooked, three landed, two bonked, one already eaten!

Many silvers and chums released...they seem to just keep on comin' !

hey todd.... nice to meet you briefly last night at the christmas party.... if you get a day off for a drift sometime soon drop me a line

lupo,

Our gracious hosts last night made me the same invitation...hopefully soon we can all get out there together and knock a few 'heads!

Fish on...

Todd

This is just to throw a little fuel on this fire…

Last January I attended an ODFW meeting the was convened to discuss this proposal. In this meeting Steve King of ODFW let it slip that the original proposal by WDFW much higher… I emailed him after the meeting in an effort to get this info in writing… this is how it went

Question:
“at what part of the Biological Assessment did the State of Washington put forth their 17% incidental take proposal? What part of the chronology did it occur? Was it at the beginning of the 10 month process – just before your 11/07/03 testimony to the Commission – or after 11/07/03 but before 01/02/04 completion of this Draft Biological Assessment. When did both parties finalize the 5% to 7% incidental impact number?”

Answer from Steve King:
“The 17% consideration for wild winter steelhead impacts was only a
verbal discussion amongst ODFW and WDFW on a manager to manager basis.
It never went beyond that. The discussion occurred in December”

So in December of last year WDFW staff was proposing a 17% impact…
anyone here want to defend that?

Doesn't surprise me one bit. I think these "managers" have all lost touch with their humbler roots when they were real biologists.

I don't care who's trying to justify those numbers, they are completely indefensible from a biologic standpoint.

I think the commercial fishing interests convinced their lobbyists at Region 5 WDFW that they could not meet the guidelines and still net the springers in the CR. Their performance that first time out with those stupid tangle nets when they caught some 25,000 incidental steelhead was proof. After that they had no choice but to put forward a recommendation that "fit" with the reality of gill netting. Remember that their goal is to provide that "viable" commercial fishery that state statutes mention. That is always the fallback battle cry of WDFW and the commission any time they are questioned about doing something radical to help commercial fishing. That same state law mentions "quality" sport fishing.

Viable means that it can support itself and can survive without outside help. Quality sports fishing is open to real interpretation. I think the RCW needs to be changed to get rid of that viable language and focus on policy that takes into account the benefit of sports fishing and the tremendous economic benefit to the state it brings with it. The RCW should also take into account the "maximum sustainable survival of our fish" and toss out the "maximum sustainable yield" philosophy that helps these outlaw staff members of WDFW support their outmoded policies that blatantly support commercial fishing at all costs.
Just my humble opinion

Todd -
You asked me to expanded my take on this issue.

Bascially I see it as an issue with 3 broad components: 1)Management/process, 2) biological/data, and 3) allocation. I'll try to disucss each briefly.

1) The management paradigm used to manage this fisheries and most others in this era of ESA listings. Basically it allows at some fishing on non-listed stocks with limited impacts on the listed stocks. these allowable impacts are established so that the stock of conern is not unduely jeopardized. This paradigm encourages slective fisheries and without it there would be virtually no fishing for any species anywhere in Washington on the marine or anadromous waters.

There are large segments of the State's population that believe that there should not be any fishing that impacts the listed stocks - essentially shifting more of the conservation burden to the fishers and away from the habitat H. It is the potential shift from that paradigm that concerns me as it puts all fishing at risk. The trick of course is the development of allowable imapcts that don't significantly impede recovery efforts while keeping some fishing.

It is in this context that I made my comments earlier in the discussions.

2) the biological/data piece has 2 pieces -
Is the limits on the fishing impact appropriate for the stock(s) of concern? This assessment should include the impacts from all users in all fishing areas. In this case determination of the adequancy of the allowable impacts needs to include the sport impacts (main stem Columbia and the tribs) and commerical imapcts. If I recall correctally last year the model was a 2% sport fishing impact (mostly in the tribs) and a 2% in the commerical fishery. So what the proposal appears to doing is doubling the impacts from 4 to 8%. Is that appropriate? Don't know in that I have looked closely at the supporting information. presumably that will be a factor in NOAA's evaluation.

The second piece is whether the estimates of the impacts are creditable and supported by the available science. Again I have not looked closely the available information so am not really to make an assessment.

3) the allocation piece should be asking the question of what is the best or wise use of the allowable fishing in impact? First are those impacts being used to meet legal requirements and secondly are the decision makers address the scio-economic impacts in the process appropriately (fairly/wisely).

I would encourage you each to address the later aspects in your comments as you each feel is warranted. Those issues are appropriately addressed at the lcoal fishing level. If you support continuing to allow fishing under this paradigm then that aspect of this issue is probably best left for other discussions. Of course if one feels that this management paradigm is not a responsible approach then questioning it in this context and attempt to establish a precedence to aid in re-shaping management in other areas may be a workable strategy.

Hope the above is what you were asking for. I felt that addressing your Snohomish questions was unnecessary.

Happy Holidays and may the New Year bring you tight lines
S malma