I would add that i the late 80s an accounting model was being developed for PS. It would have clearly included net dropout and I think pinniped predation. Was going to have more stocks, better estimates of timing, etc. Don't know what happened to it.

I hate that word " Harvesting" when it comes to fish.

Change of pace for a minute. I received this twice now so I thought some would find it helpful. Simply put WDFW is trying to get it website functioning better.

From: WDFW Web Project (DFW)
Sent: Tuesday, November 28, 2017 11:20 AM
To: DFW DL WDFW Staff <DFWDLWDFWSTAFF@dfw.wa.gov>
Subject: Help us distribute a website study by Dec. 5

To all staff:

We are conducting a follow up study this week to test the preliminary organization of our new website. We did a similar study earlier this month, and we appreciate everyone who encouraged others to participate. After making changes based on results from the first round of testing, we are doing this second online study to help validate the effectiveness of the site structure.

Using a simplified set of website topics and subtopics, study participants will identify where they think specific information would be located. We want to ensure the new site structure makes sense for current website users as well as first-time visitors.

Please help us distribute this revised study to anyone interested in Washington's outdoors. We are specifically looking for responses from people who aren't avid hunters or anglers. Please forward the study link to friends, family, external colleagues, outdoor organizations, and educators, and encourage them to take the study by Tuesday, December 5.

Please refrain from taking the study yourself as we expect to have other ways for staff to provide feedback in the near future.

Link to the study: https://anthrotech.optimalworkshop.com/treejack/wdfw2

If you have questions or would like more information, please contact me at james.blum@dfw.wa.gov<mailto:james.blum@dfw.wa.gov> or 360-902-2232. Website redesign project information is also available on the SharePoint project page<https://shared.sp.wa.gov/sites/dfw/DO/StaffComm/External_Site_Design/SitePages/Home.aspx>.

Sincerely,

Jim Blum
Website Redesign Project Manager

Do you know where to find the location of the harvest (meaning ak or be or elsewhere)?

Thought I would post this up for folks watching Willapa. Tim, Ron & Art have pretty much stayed right on the Willapa policy as the agency has a rather short memory as to what words mean let alone what a paragraph was intended to portray.




January 2, 2018

Twin Harbors Fish & Wildlife Advocacy
PO Box 179
McCleary, WA 9855 thfwa@comcast.net


To: The Members of the WDFW Commission via: email in PDF format Re: Response to Department Presentation and Comments on Willapa Bay
The Twin Harbors Fish & Wildlife Advocacy and members of the public have invested thousands of hours and tens of thousands of dollars into the development of the Willapa Bay Salmon Management Policy (C-3622). We offer the following comments regarding the presentation provided the Commission by Region 6 Fish Program Manager Annette Hoffman during the regular meeting on Saturday, Decem- ber 9, 2017.

First, the presentation was smoothly delivered and contained numerous tables, charts and graphs. How- ever, unless a person was very familiar with the data and history in Willapa Bay, we believe the public could come away from the presentation under false or inaccurate impressions.

The Willapa Bay Policy states:

Purpose
The objective of this policy is to achieve the conservation and restoration of wild salmon in Willapa Bay and avoid ESA designation of any salmon species.

The presentation by the Department was vague at best about conservation, restoration of wild salmon, or our progress in avoiding ESA. Conservation over harvest does not appear to be a Department priority when one viewed the presentation.

In the week following the presentation to the Commission, Ms. Hoffman offered the first conference call of the season with the Willapa Bay Advisors. The outcome was the Advisors were told the Department would likely fail to reach escapement goals on natural spawning Chinook, Coho, and Chum in Willapa Bay in 2017. The Department either did or, should have known, this fact at the time of the presentatio Many in the public had come to that conclusion over a month earlier. Zero for three on reaching natural spawning escapement deserved prominent notice in the presentation.

To further understand the conservation problems in Willapa Bay, turn to hatchery egg take which is the lowest performance bar one could establish. The Department missed hatchery egg take for Chinook.
Then, Chum too if not for efforts to “mine the gravel” as Chum were snagged or dip netted in the spawn- ing grounds of other streams and transported back to the hatcheries. Now comes an emergency rule cutting rec bag limits down to the minimum (1 clipped Coho) on January 1st. The reason provided was
a fear the Department would not make hatchery egg take on Coho either. Without mining for Chum, the Department seems to be approaching zero for six on reaching escapement goals. Is it possible to get any worse than that?

How could such a result not be included in the presentation? Advisors in the conference call asked this very question of Ms. Hoffman and were told the data was all in there, you just have to add up the dif- ferent numbers. The response was “Do you think it is appropriate to expect the members of the Com-

mission to figure out how to do that (paraphrasing)? Since the priority is conservation first and harvest second, zero for six should have made it into the presentation. The fact the Department failed to point out the failure to reach escapement goals in it’s annual review in a clear and precise fashion is telling on its own. Neither members of the public or members of the Commission should be required to retain a forensic accountant to figure out success and failure in reaching escapement goals in Willapa Bay.

Perhaps the most alarming factor to many viewing the presentation to the Commission was some of the comments offered by Ms. Hoffman. It seemed to many present that she was somehow trying to claim the only major problem facing us in 2018 was “Allocation of Available Impacts” (See Slide #21). Then, her comments left many with the belief she was promoting the notion that the recreational sector had exceeded the share of the catch the Commission intended when passing the policy. Recognizing Ms.
Hoffman was stationed in Region 4 and not present during the passage of the policy, we can not find a source for this claim on the public record and the Advocacy members attended every Ad Hoc Meeting and Commission meeting wherein the policy was discussed.

Regardless, the facts are again telling. When one compares the impacts (fish killed) by the recs and nets bay wide the impression recs were somehow exceeding the commission expectation by a factor of two is clearly debunked. Using the data in the Dept’s Excel spreadsheet filed with passage of the commercial

Willapa Chinook NOR Impacts (Bay Wide)
Year Nets Recs Net % Recs %
2014 2,553 205 92.6% 0.074
2015 606 243 71.4% 0.286
2016 385 149 72.1% 0.279
Total #s Average % 3,544 596 78.7% 21.3%

season in WB in 2017, the Advocacy found the last three years wherein data is available for both sectors (2017 rec data is not available at this time). The impacts on Chinook natural origin spawners (NORs) provided the commercial nets averaged 78.7% of the total bay wide terminal impacts and the rec sec- tor averaged 21.3%. It is noteworthy that the policy establishes a rec priority for Chinook and the same for the nets on Coho and Chum. The one with the priority gets to use all the available impacts and any remainder goes to the other. How does the recs historically taking only 21% of the impacts align with Ms. Hoffman’s comments that they somehow were using twice the impacts as intended by the Commis- sion when the policy was passed?

In fact, Ms. Hoffman’s comments are contrary to the actual language of the policy which states:

4. Fishery Management Objectives. The fishery management objectives for fall Chinook salmon, in priority order, are to:

a) Achieve spawner goals for the North, Naselle, and Willapa stocks of natural-origin Chinook and hatchery reform broodstock objectives through the two phase rebuilding program described above.

b) Provide for an enhanced recreational fishing season. The impact rate of the recreational fishery is anticipated to be ~3.2% during the initial years of the policy, but may increase in subsequent years to provide for an enhanced recreational season as described below:

c) Manage Chinook salmon for an enhanced recreational fishing season to increase participation and/ or catch including consideration of increased daily limits, earlier openings, multiple rods, and other measures.

d) Conservation actions, as necessary, shall be shared equally between marine and freshwater fisheries.

e) Provide opportunities for commercial fisheries within the remaining available fishery impacts.

As for increasing the rec impacts in the future, clearly the Commission not only recognized but encour- age this to happen. While the increase occurred faster than some thought would the case, it is important to note that the declining rec opportunities statewide and the Departments fishing reports, etc. led to an increased pressure as WB was promoted as the best opportunity for recreational license holders. The result was the local community shared with the rest of the state the resource which encourages license sales by the Department. It is time to insert the old saying “No good deed ever goes unpunished”?

Prior calculations used the actual impacts and the percentage of the impacts between sectors. The Harvest Rate is a percentage of the fish killed compared to the runsize. Reviewing the Department’s presentation, slide #10 shows the harvest rate of the recs on the Willapa Bay (marine)@ 9.6%, Willapa River @ 14.9%, and Naselle River @6.1%. The font for the Willapa River is set in red as if to point out this is a problem (rec sector taking more than anticipated?).

Returning to the spreadsheet utilized by the Department to set the seasons in 2017, the data does not sup- port the impression recs in the north have somehow overpowered commercial fishing. From 2014-2016 the nets took an annual average of 1,181 Chinook impacts (bay wide) and the recs in the marine and freshwater up north took 150. Would a transfer of impacts from the northern rec sector provide an eco- nomic surge for the nets? Hardly, unless one terminated rec fishing in the north nearly entirely. One can now see why those who understood the implications of Ms. Hoffman’s comments immediately became alarmed over the future of recreational fishing in WB, especially in the north.

What would be the purpose of the Department seeking to convince the Commission to shift impacts from the rec sector to the commercial sector? The most logical answer the Advocacy could develop is the Department is seeking to transfer rec pole impacts to the commercial sector to allow use of non- selective gillnets during Coho run time. The use of gillnets over the more-selective tangle net would
increase the mortality on the late portion of the Chinook NORs mixed in with the Coho requiring extra Chinook impacts from somewhere. Where does the Department look for them? In the north where most of recreational fishing occurs seems to be the direction the Department is headed.

The Advocacy tries to avoid allocation battles and maintains the belief that a dead fish is a dead fish re- gardless of the gear type used to kill it. However, moving the impacts from the most selective (pole) to the least selective gear (gillnet) is punishing those who have adopted selective fishing. Certainly not an effort to improve conservation performance and ironically, would likely prove be the equivalent of “put- ting a Band-Aid on an open chest wound” for the commercials. Further, it is contrary to the language of the Policy which directs the Department to: “Pursue implementation of additional mark-selective com- mercial fishing gear to enhance conservation and provide harvest opportunities”. The Policy does not contain a provision calling for transfering rec impacts to the commercial sector so the Deptartment can provided additional harvest opportunities for non-selective gears.

The economic reality of commercial fishing is not based on who gets the larger portion of the impacts as

Page 4, Commission Presentation by Dept
shown on a computer model (effect of moving impacts). That just gets them a few extra days of the season or increasing the use of non-selective gillnets over tangle nets during season adoption in NOF. Rather, it is primarily the run-size coming back into the Bay that puts fish in the boat and makes both sectors “winners or losers”.

As we pointed out in our comments to the commission following the presentation, the commer- cial sector caught 198 less Chinook this year than landed the previous year. The Coho crash in 2017 resulted in a drop of 14,729 from the previous year. Clearly, it wasn’t Chinook that broke the bank this year and neither was it using more selective tangle nets. Rather, it was the simple fact that Coho were in such small numbers the commercials stayed home many of the days when they were able to fish.

Are the smaller runs the result of passage of the policy? No. The small run sizes in 2017 are the results of “sins of days passed” under the management schemes used prior to the passage of the policy wherein the gillnet dominated the Bay. As a result, we’ve failed to make escapement goals 7 years in a row. For Coho, which were thought to be in the best shape, we’ve missed escapement goals 2 out the last 3 years. Then in a Bay which historically had huge runs of Chum which were the backbone of commercial fishing, we’ve failed to reach escapement goals 11 out of the last 13 years. It is important to note that the Advocacy and many who have studied WB fear the runsizes have yet to bottom out. Runs will likely decline even further due to low ocean productivity, warmer climates, and the continuing failure to meet escapement goals.

Recently, the Court soundly rejected the assertion by the Willapa Bay Gillnetters Association that a gillnet license holder’s profit margins are on an equal par with the state’s duty to manage for conservation. At this point, one wonders if the Department listened to its own successful argu- ments in that case. Regardless, it’s time for the Department Senior management to realize it can not provide harvesters with fish that are not in the water. Rather than continuing to open up old allocation wounds, the Department needs to address the conservation problems and take mea- sures that restore the run sizes.

In closing, the Advocacy sincerely hopes that the Commission will allow the public time to digest the content and comment on presentations from the Department related to the Willapa Bay Salmon Policy before reaching mindsets or adopting positions on requested actions. As one Commissioner noted last meeting, it is very difficult to respond quickly in 3 minutes at the mike. The Commission Members have similar challenges. We would point to that old saying on the radio of “Now.......for the rest of the story.”

Respectfully,

May as well add my Willapa Policy comments, too...

.
.
.


Commissioners:

I am deeply concerned about the way WDFW Fish Program and the Region 6 staff are implementing YOUR Willapa Bay Policy and the intellectually dishonest manner in which they attempt to hide their management failures from you…. THEIR BOSS!

A bit of historical context helps to set the stage.


Let’s start with the most fundamental conservation tenet of the Policy…. rebuilding a wild chinook population that historically has been ravaged by a century of harvest and hatchery abuses. Let’s be CLEAR that the primary impetus for crafting this Policy is recovering a healthy self-sustaining population of natural origin chinook in the basin. WDFW’s best scientific models predict that recovery to the agency’s natural origin escapement goal is possible within 16-21 years ONLY if harvest becomes more hatchery-selective AND releases of hatchery chinook are sufficiently tempered in order to markedly reduce pHOS (the proportion of hatchery strays on the spawning gravel)…. while concurrently curtailing the in-basin exploitation of natural origin chinook to an impact cap or harvest rate of 14%. This is the level of harvest restraint necessary to rebuild the stock in 16-21 years. Exploitation at any rate exceeding 14% would only serve to flatten the rebuilding trajectory, delaying or perhaps extinguishing any possibility of recovery…. EVER!


The commercial advisors balked at a 14% impact objective right out of the gate, arguing that a significant cohort of hatchery chinook from prior large releases were still grazing the ocean pasture. These fish needed to be caught as they returned to Willapa Bay to keep them off the gravel, so gillnetters argued that a 20% impact cap would not only soften the blow to their fleet, but also help them to remove more hatchery fish to improve the glaring pHOS problem on the spawning grounds.

The Commission went along with this compromise to phase in the 14% impact cap by allowing a “transition” of 4 years to allow a 20% harvest rate. Incentives are built into the policy to ramp up the implementation of selective gears during the transition with a goal of at least 6% allocated to alternative gear. The Policy requires an annual review of fishery impacts and includes an insurance provision or “payback clause” to maintain the rebuilding trajectory if the harvest rate is exceeded in any given year.

So how are we doing on natural origin chinook recovery? Are we hitting the conservation benchmarks spelled out in the policy? How well is Region 6 / Fish Program fulfilling the deliverables spelled out on the Policy?

To put it bluntly, staff is failing the Policy and you the Commission… MISERABLY!

But how would the Commission even realize this when staff refuses to include a PowerPoint slide/graph showing the historic escapements relative to the natural origin spawner goal. Upon identifying the oversight in the PowerPoint prior to the staff presentation, I personally asked that the slide be included. This advisor request was REJECTED by staff, citing that achievement of the natural escapement goal is NOT a staff objective during the transition, but rather one reserved for 16-21 years out. The objective metric during the transition is a 20% harvest rate, so that’s what they would present to the Commission.

But they didn’t even do that. The truth is they are batting a thousand on exceeding the 20% harvest rate, but were too cowardly to tell you outright. Instead they cleverly parsed up the exploitation by each sector…. commercial, marine recreational, and freshwater recreational… to intentionally muddy the waters to disguise yet another year of over-harvest.

When I confronted Annette Hoffman about the glaring error of omission, her response was simply. “It was all there, all you had to do was just add it up.”

<< Are you fooking kidding me >> (and no I didn't send that part... READ ON)

So I ask you, how many commissioners were familiar enough with the spreadsheets to “just add it up” on the fly from two spreadsheets presented FIVE SLIDES APART during the last Commission meeting? Prior to my testimony in the public hearing, how many of you were honestly left with the impression that the rate had been exceeded yet again? Hmmmm… I wonder why.

Not once since the Policy took effect has staff delivered on the already lenient 20% impact cap. It has been EXCEEDED every year. What’s worse is that they couldn’t muster the intellectual honesty to tell you straight up. This inexcusable pattern of staff-sanctioned over-exploitation under the leadership of Annette Hoffman mirrors exactly that of pre-Policy management under the leadership of Ron Warren. When the Policy says to shoot for 20%, they deliver 25-27% instead. When it was 30% pre-Policy, they consistently delivered 36-38%. Regardless of what goal you set before them, Region 6 staff is still habitually overexploiting the Willapa harvest objectives by a margin of 25-30%.... NOTHING HAS CHANGED ! ! !

And what about the payback clause? Not once has staff considered invoking it to pay for past sins. Instead they look for weasel words in black and white to justify why the clause does NOT apply. Once again, where is the intellectual honesty? Are they serious about recovery within the 16-21 year time frame? And will they hold themselves accountable to maintaining the rebuilding trajectory?

This is exactly like an undisciplined fat kid whose doctor/dietician has laid out a perfect plan to slowly get him back to a healthy weight over the next 16-21 months. The first 4 months, the doctor gives Fat Albert a break by allowing him 2000 calories a day to lessen the shock from his typically obscene 3600-3800 caloric intake. Eventually Albert’s got to whittle down to 1400 calories a day for this health plan to work. But he just can’t help himself. He’s just got to snarf down that extra 500-700 calories. Besides, he’s thinking who’s really gonna know… and who’s even gonna care?

So I ask you, will Fat Albert ever reach his goal in 16-21 months if he’s habitually sneaking an extra 25-30% in calories without telling his doctor? If he can’t hold himself accountable to the plan, then who will?

And look... I'm not here to demonize the commercial fishermen. They're just hard-working folks trying to earn an honest living the way they've been accustomed... it's culture, it's tradition. OK yeah... I get it.

They will fish in EXACTLY the most efficient, least labor-intensive, and most cost-effective manner permitted under the law.

The guys making and implementing the rules shoulder the responsibility to the resource.

The rule makers (Commissioners) have made their wishes known... it's the Policy. The problem is a rogue agency (WDFW) that cannot discipline itself to implement the policy as written. Instead WDFW willfully breeches the policy guidance and breaks the rules regardless.

Time for the Commission step up to the plate... demand a payback in 2018 and 2019. Defiant/incompetent heads MUST roll!

Something interesting in your letter, Doc. If WDFW believes that the escapement goals don't become "real" until 16-21 years out then what folks are essentially saying is that the whole thing is none of their concern. None of them will be around when it comes time to pay the piper. The staffers then may just be starting High School now, probably in Kansas or Iowa or some such so they will have not clue or history in the situation.

But, in seriousness, what should be of concern is the kick the can down the road mentality. Somebody else, later, will fix it. Must have learned that from the Legislature.

Your concern is EXACTLY what former Commissioner Miranda Wecker spoke to when we finished writing and adopting this Policy. She really wanted to make sure this thing got done before her departure. Her parting words paralleled your last post to a TEE....

That we MUST stay committed to the course and maintain the modeled rebuilding trajectory to achieve the intended recovery in that 16-21 year timeline, even though she would perhaps not even live long enough (nor many in the room) to actually see it come to fruition.

Region 6 is off to one helluva crappy start to that 16-21 year journey.

WOW, do I ever agree with the "kick the can, down the road" bit....

Now 25 years of Wynoochee Mitigation.......new personnel, every few years, lets start over again......new items added, some items change......bottom ?ucking line, "can gets kicked down the road"......grrrrr

It's more than just kicking the can down the road. Those fish were my responsibility. It was not just a job. For whatever reason, we now seem to, as a society, separate the job from the results. The run didn't make escapement. Too bad. The patient died. Well, that happens. The kids didn't learn. Hey, I taught them. The list goes on.

Not much sleep so I will try to update after a little nap ( old guy thing ) but at first read some say all out assault on Willapa policy others not so. I tend to lean toward the agency minions are at it again trying to chip away at the Rec fisheries.

WDFW NEWS RELEASE
Washington Department of Fish and Wildlife
600 Capitol Way North, Olympia, WA 98501-1091
http://wdfw.wa.gov/

January 16, 2018

Contact: Annette Hoffmann, 360-249-1201

WDFW seeks public comments
on Willapa Bay salmon priorities

OLYMPIA &#150; State fishery managers will hold a public workshop Jan. 23 in Raymond to solicit public comments on priorities for upcoming sport and commercial salmon-fishing seasons in Willapa Bay.

The workshop, sponsored by the Washington Department of Fish and Wildlife (WDFW), is scheduled from 6-8 p.m. at the Raymond Elks Club on 326 Third St.

Annette Hoffmann, regional WDFW fish manager, said the department is currently seeking guidance on how to reconcile priorities for salmon-fishing opportunities established in the state's Willapa Bay Salmon Management Policy.

That policy, approved by the Washington Fish and Wildlife Commission in 2015, gives recreational fisheries priority in the Willapa Bay chinook harvest, while designating commercial fisheries as the priority for coho fisheries in the bay.

To meet conservation objectives, WDFW requires both fisheries to release any wild chinook salmon they encounter and manages fishing seasons to hold mortality rates for those fish within a prescribed limit.

Hoffmann said the department has asked the commission to provide greater clarity on ways to achieve those priorities, and wants to involve participants in Willapa Bay's recreational and commercial fisheries in the discussion.

"The commission makes the policy, but we also want to hear from those directly involved in these fisheries," she said.

Hoffmann said state fishery managers will convey comments heard at the workshop to the commission during a public meeting scheduled Feb. 9-10 in Olympia. The department will then look to the commission to provide guidance in setting fishing seasons for Willapa Bay in 2018 and future years.

Persons with disabilities who need to receive this information in an alternative format or who need reasonable accommodations to participate in WDFW-sponsored public meetings or other activities may contact Dolores Noyes by phone (360-902-2349), TTY (360-902-2207), or email (dolores.noyes@dfw.wa.gov). For more information, see http://wdfw.wa.gov/accessibility/reasonable_request.html.

This message has been sent to the WDFW News Releases & Weekender mailing list.
Visit the WDFW News Release Archive at: http://wdfw.wa.gov/news/
To UNSUBSCRIBE from this mailing list: http://wdfw.wa.gov/lists/unsubscribe.html

For those who do not know here is the NOF schdule for NOF Willapa & GH.

2018 North of Falcon public meeting schedule
Figlar-Barnes, Kim P (DFW)
11:23 AM
To Allan Hollingsworth, Andy Mitby and 12 others
Quick reply allReplyForwardDeleteActions
Welcome to the 2018 North of Falcon public meeting schedule for setting the 2018-19 Salmon Fishing Seasons. Please refer to the below list for meeting schedules:





Meeting Date Time Location



Grays Harbor & 2-26-18 6-8 pm Montesano City Hall

Willapa Bay Forecast



Statewide Forecast 2-27-18 9 am – 3 pm Lacey Community Center, 6729 Pacific Ave., SE Lacey



PFMC 3-9 to 3-14 See PFMC Double Tree by Hilton Sonoma, One Doubletree Drive,

Agenda Links Rohnert Park, CA



Grays Harbor Advisory 3-19-18 6-8 pm Region 6 Montesano Office





NOF # 1 3-20-18 9 am – 3 pm DSHS - Office Building 2 Auditorium, 1115 Washington St SE, Olympia



PFMC Public Hearing Ocean 3-26-18 7-9 pm Chateau Westport Beach Rm, 710 W Hancock, Westport



Grays Harbor NOF 3-27-18 6-8 pm Montesano City Hall

Public Discussion



NOF # 2 4-3-18 0930 am – 5 pm Lynwood Embassy Suites, 20610 44th Ave. W, Lynnwood



Final PFMC 4-6 to 4-11 See PFMC Sheraton Portland Airport, 8235 NE Airport Way, Portland OR

Agenda Links




For those who do not know here is the NOF schdule for Willapa & GH


Grays Harbor Advisory 4-17-18 6-8 pm Region 6 Montesano Office







All 2018 NOF meeting schedules are located on WDFW webpage at: https://wdfw.wa.gov/fishing/northfalcon/

Please refer to WDFW webpage as meeting dates and locations are tentative and could change.

The following is a letter that I attempted to address the current status of the Willapa Policy. I would urge all to pay attention to this issue as current WDF&W staff are attempting to circumvent the intent of the policy. It is not a small thing and as always remember, next time they come for you!


Dear Commissioners,

I am writing to express my concerns regarding the recent actions taken by Region 6 ( R6) staff and the Willapa Bay Policy ( WBP ). I recently attended a public meeting in Raymond on this issue, that simply put was a " dog and pony show. " Ms Hoffman and Mr. Philips provided a copy of the policy and a one sided sheet of issues that lacked depth and context, did not provide a in depth summary on the pros & cons but rather limited that discussion and only allowed participants to put forth suggestions. What information was provided was biased to lead one to draw conclusion the staff desired. Honestly Commissioners this process was more about creating confusion in peoples mind rather than educate. This is the definition of a " dog and pony show " by almost any standard that I am aware of. Staff did express confusion as to what the Willapa Policy intended to accomplish as to allocation of available impacts between sport and commercial fishers. I might add that staff stated they were going to have a whole series of these meetings to what end no idea as we all were left wondering why?

This brings me to the purpose of this letter. There cannot be any confusion on this issue with staff as it simply is not possible. Why one may ask? Ms Hoffman could at any time as Region 6 harvest managed simply asked Chad Herring who is the R6 District 16 number cruncher and was very involved with the process of creating the WBP. If that was not adequate she could have turned to the head of her division Mr. Ron Warren, who also was very engaged in the process. If that was not adequate again either Ms Hoffman and Mr. Philips could have picked up the phone and called senior WDF&W staffer Mr. Jim Scott who was the primary author of the WBP for clarification. It is not possible for a WDF&W staffer to stand in front of a room full of citizens and express any confusion as to what the WBP was intended to accomplish or the manner it is to accomplish the goals of it. Perhaps they could be confused if not fully informed by senior WDF&W staff but as Ron Warren once told a group on this issue who questioned a statement as to his view or the agencies in the meeting and he stated forcefully he was the agency in the meeting. So at the recent meeting Mr. Philips and Ms Hoffman were the agency and it is not possible for the agency to be confused on this issue.

Commissioners a large number of citizens participated in the WBP process. We drove long distances to many meetings, endured verbal abuse and threats of violence from opponents of HSRG and the WBP to get this task accomplished in a partnership with WDF&W. For staff to now attempt to undermine that joint effort by so many citizens is appalling and frankly a affront to those citizens.

A number of challenges faced staff with the implementation of the WBP. Frankly were simply ignored and brought us to this place with the WBP. The driver of this is the fact that Willapa Bay has a rather small Natural Origin Recruits ( NOR ) and a large Hatchery Origin Recruits ( HOR ) which means selective or alternate methods of fishing by any harvester would be required for any recovery of NOR Chinook stocks. This was discussed many times, resisted by the commercial fishers as they refused to recognize HSRG and the need to manage for natural production in any manner and was accepted by the sport fishers. There cannot be any confusion with staff as it was the primary driver in the discussions many times. It was known that selective or alternate harvest methods would have to fully implemented rather quickly for the commercial fisher and this was a fundamental objective of the WBP.

To assure that the NOR Chinook trended up to recovery several mechanisms were in the WBP. A payback clause to more less refund fish the next year by the harvester who over fished their allocation is present but never complied with by staff as it relates to commercial fishers. The harvest rate impacts would go from 20% to 14% after the first implementation years to again insure that the Chinook stocks continued to trend up to escapement goals. Additionally the sport fisher was given Chinook priority and commercial Coho and Chum.

After mostly failing rather miserably at compiling with the previously mentioned WBP objectives staff simply ignored goals of the WBP and created what could best be described as a train wreck. Additionally to comply with HSRG in the creation of the WBP a reduction of Chinook production at Forks Creek Hatchery to 350K was required. This action resulted in a very simple fact that four years from implementation of the WBP that the mix of NOR and HOR Chinook in the North end of Willapa Bay and the Willapa River would be drastically changed from the vast majority of the Chinook being HOR fish to nearly one on one NOR / HOR. This is not a small detail. With the future being as I described even if the commercial fisher used a tangle net to reduce mortality the number of NOR's encountered and released mortalities in any Willapa River ( Forks Creek production ) would nearly dictate a very large reduction of fishing time by commercials in the South end of the bay during their Coho fishery. Again Commissioners that was why the use of selective gear or alternate harvest methods was a priority. I would also point out that it was WDF&W that insisted on the aggregate of all streams in Willapa Bay for each species rather than separate the bay into two sections ( North & South ) as I and others urged to simplify harvest allocation impacts.

The fact is Commissioners with the WBP after four years and the Forks Creek Chinook production reduction it will be very difficult just to keep the sport fisher a full seasons in Area's T & U. (North Willapa Bay ) At that time the majority of returning Chinook will be returning to the South end of the bay to Naselle & Nemah giving access to the commercial fisher. This will be a majority of the HOR Chinook to be sure but the Commercial fishers gear will need to be selective or alternate types ( traps / other ) to access these fish due to small number of NOR Chinook. This outcome was what the WBP dictated and was the desired outcome. Not to remove commercial fisheries from Willapa Harbor but to direct them toward a method of harvest that was sustainable. The majority of commercials fishers refused to change gear types which leaves one with the outcome we have now which is the one the commercial fleet chose.

Finally Commissioners one last issue. In the nearly 40 years I have been around the agency or working with it one thing has been present but never to the degree it is now. The thing? WDF&W staff believe it is proper and acceptable to with hold facts or information that would lead one to draw a conclusion different than they would if fully informed. Now I know what my mother told me that was prior to my car and myself grounded for six months when I utilized this method but you can choose your definition. I can tell what it is not. It is not forthright, honest, or ethical. In fact I see that a bill was dropped addressing this issue in the legislature as this seems to be a problem that WDF&W is the poster child for.

From my seat in the stands you folks have some work to do internally before you start making decisions be it the WBP or any other policy. If staff provided information I seriously doubt the validity or accuracy of it let alone anything that is not biased toward the outcome that senior staff in Olympia desire. It is my understanding that the Advocacy will be making a presentation on Willapa soon and I urge the Commissioners to listen to them. It will be unvarnished truth to be sure but after the smoke and mirrors of staff presentations you might find a forthright honest presentation refreshing.

Sincerely

Here is the link to the WDF&W Commission meeting agenda for February 8-9-10 and both Grays Harbor and Willapa are on the agenda but different days. Links are provided to view WDF&W presentations and one should be concerned.

I am told that the Willapa has a error as who & what and is to be corrected.

https://wdfw.wa.gov/commission/meetings/2018/02/agenda_feb0818.html

Turning a BLIND eye to conservation, once again....

ZERO payback for the past 2-3 years of OVER-harvesting the policy's impact cap. Just more concessions to the gillnet fleet. Gee, what's new?

https://wdfw.wa.gov/commission/meetings/2018/02/feb_1618_b_wb_guidance.pdf

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



Commissioners:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Sincerely,

RG, I am a little dazed and confused too. In your letter, you lay out all the complications and difficulties that emerged from the WP process that created the current WP. These were the result of difficult decisions regarding the mix of conservation, hatchery production, and logistics and management of the sport and commercial fisheries within WP. This produced the current WP, warts and all. You recommend the Commission "do nothing". The current WP has some language in it that is open to interpretation. Apparently, there is a difference of opinion as to whether WDFW is following the wording of the WP. If the Commission does nothing, what will change in the next two years to meet the challenges? Without some more direction/clarification from the Commission won't the meandering continue and won't the evaluation of how well the management actions met the WP by 2020 be in the fog too?

I think yes to fog. That said staff did not do the Commission any favors by not clearly identifying the difficulties and when they did is was only for the present. The lack of candor around what will exist in 2020 and what conservation means for the future. Believe me you will not like 2020 and 2024 to 2028 running off the natural spawn productivity ( not redds ) has the potential of being a disaster if we do not address it now, which we will not.

By 2020 the NORs will be effectively "gone". Can't find them. So, there can be fishing on the HORs. Since the situation being created will be "impossible" to manage per the plan, we just toss the plan and fish.