Salmon and steelhead hatcheries sure aren't delivering the benefits they were originally intended to. One would think that WDFW would re-evaluate and adjust. But that would be contrary to the axiom of bureaucracy.

After receiving the latest model showing Chehalis Chinook NOT making escapement I felt compelled to object to the Director, Commission, and staff.


Morning,

After reviewing the model it is clear that when I asked at the last ZOOM NOF Grays Harbor with all out effort to cram more NT Commercial time would we make Chinook escapement staff replied yes. Adding both wild and hatchery numbers it is clear you have an problem. The escapement goal is 9754 for wild Chinook an adding in the expected hatchery escapement the model shows 9066 Chinook to the gravel. In other words you were not truthful and I will stick with untruthful but others may choose other words. Director Susewind this thing with the Quinault Nation has been going on for a long time. Many times I have been present when agency employees refer to the non-treaty gillnetters as “our commercials”. Director Susewind we have three commercial net seasons in this basin. They are Chehalis Tribal non treaty, treaty Quinault Nation, and the state non treaty commercial fishers and frankly most folks could careless about the race or ethnicity which WDFW keeps inserting into the conversation simply by their actions. This needs to end!

In the last two years Region 6 staff have literally violated the GH Policy on harvest sharing in about every way possible, attacked the inriver fisher for using catch and release for Chinook which is legal, and shut down huge portions of the Rec fishers for conservation under premise of low flows stacking the fish up ( I provided a video showing this was untrue ) which by the manner you did so placed the so called conservation burden on the bank fishery who are usually folks who cannot afford a boat or are simply poor. The bias in Region 6 toward the inriver Rec fisher is simply appalling. The continuing whatever between the Quinault Nation and WDFW staff needs to end as the fish and the Chehalis communities cannot afford it any longer.

Director and Commissioners I urge you to find a third party to bring both the Quinault Nation and WDFW staff together to moderate a discussion to put and end to this ongoing issue between the two parties as it is clear they lack the will, desire, or ability to do so on their own.



From: Grays Harbor (DFW) <graysharbor@dfw.wa.gov>
Sent: Thursday, April 13, 2023 3:34 PM
Subject: Updated 2023 Grays Harbor planning model B

To all interested Grays Harbor parties,

Please see the attached updated 2023 Grays Harbor planning model B. The model you received on Tuesday, March 11th has been updated to reflect the changes in the commercial schedule that were discussed at yesterday evenings meeting. This change was made after the commercial sector reviewed the model and asked staff to reduce the fishery by one day in week 43 and allow for the use of 6.5” mesh net. Also, the attached Word file includes the tables from the “2023 Summary Table” tab in the attached planning model.

Please let staff know if you have any questions.

and then there is the Absolutely Stupid regs this year for Snohomish/skykomish summer chinook with an estimated return of 7,500 fish but WDFW will only allow 3 days in may and 2-3 days per week. When the Wallace gets 5,000 hatchery fish back each and every year easily.
Sport fishing is being driven out from this state as fast as they can push it.

The Tribes certainly and the State probably prefer that salmon fishing by NI occurs in the Ocean and Straits. In a push, Puget Sound would be ok. Ideally, nothing in bays or rivers; that's Indian Country.

I and several others put together our thoughts and objections to the 2023 NOF process and seasons. Few folks participated in the ZOOM portion or rather should I say spoke out. Bay fishers were more than happy to toss the inriver Rec under the bus for C&R bait fishing while praising the bay fishery which is the LARGEST C&R Chinook on the coast. Few Recs spoke and even less the inland inriver fishers but to be honest I am not sure it would have made a difference. WDFW has gone old school we are WDFW you are peons!


April 15, 2023

WDFW Commission
Director Susewind

Commissioners my name is Dave Hamilton and I wish to object to the manner WDFW Region 6 conducted the Grays Harbor NOF in 2023. When my 30 years as an WDFW enhancement volunteer ended at the request of others I turned my attention to harvest issues and I was shocked by Region 6’s conduct. WDFW Region 6 staff kept the public from Adviser meetings, refused to release the harvest models and meeting minutes or provide basic documentation. After several Public Document Requests failed I took legal action to get WDFW documents and the issue was settled out of court. WDFW then reformed the Grays Harbor NOF process and at Mr. Warren’s request I agreed to become a Grays Harbor Advisor, meetings became open to the public, harvest models made available to all, and soon after WDFW reformed Grays Harbor NOF the process to be more inclusive and the WDFW Commission adopted the Grays Harbor Policy (GHP).

Fast forward to 2023 and oh how things change. WDFW ended the use of Grays Harbor Advisors, public participation in the harvest NOF process is at an all-time low, and NOF negotiations between the Quinault Nation (QIN) and WDFW are dysfunctional from the general public’s perspective. The ZOOM process that Region 6 implemented due to the recent concerns over the virus and public health has had a chilling effect on public participation to the point where few make any effort to participate.

2023 NOF public meeting seemed to start off well as did the first ZOOM NOF and then staff went to California to finalize the 2023 commercial seasons with QIN due to scheduling issues with the QIN. Imagine our surprise when staff returned and stated that due to the QIN aggressive harvest for the 2023 season that WDFW was going to stand down the GHP because Region 6 staff felt the 2023 QIN seasons did not allow for a reasonable state nontreaty commercial fishery resulting in the loss of two fishing days when compared to the 2022 season.

When I asked at the last ZOOM NOF Grays Harbor that with the all-out effort to create more NT Commercial time would we make Chinook escapement staff replied yes and as the final model showing the changes were not provided to the public until after the last NOF ZOOM the explanation was accepted. After receiving the model it was clear something was not right. Adding both wild and hatchery escapement numbers it is clear we have a problem. The escapement goal is 9754 for wild Chinook and adding in the expected hatchery escapement the model shows 9066 Chinook to the gravel. In other words staff were not truthful and I will stick with not truthful but others may choose different words. Director Susewind this thing with the Quinault Nation has been going on for a long time. I have been present when agency employees refer to the non-treaty gillnetters as “our commercials”. Commissioners we have three commercial net seasons in the Chehalis Basin. They are Chehalis Tribal nontreaty state, treaty Quinault Nation, and the state nontreaty commercial fishers and frankly most folks could care less about the race or ethnicity which WDFW keeps inserting into the conversation simply by their actions. This needs to end as for the fish and inland communities a gillnet is a gillnet and it matters little who owns it! The overarching goal of the co-managers to achieve conservation goals is simply ignored.

In the last two years Region 6 staff have violated the GH Policy on non-treaty harvest sharing in about every way possible, attacked the inriver fisher for using catch and release for Chinook which is legal and used in nearly all WDFW managed fisheries, and shut down huge portions of the Rec fishers for conservation under premise of low flows stacking the fish up. I then provided a video of salmon movement to staff showing this was untrue. The manner WDFW implemented the restricted recreational season placed the conservation burden on the bank fishery who are usually folks who cannot afford a boat or are simply poor. The bias in Region 6 toward the inriver Rec fisher of limited means is not acceptable.

Commissioners I realize the present Commission were not part of the process that created the GHP but simply put it is a conservation-based policy that provides guidance to WDFW staff and defines how non-treaty harvest is to be shared. It does not address and is not binding for tribal fisheries dictated by past court decisions for either the non-treaty Chehalis Tribal or treaty QIN fisheries. It has many provisions but for the inland communities it is what is known as 4/3 provision that is critical. This requires that at least three days in a calendar week be net free if possible which is not always possible if the QIN fish more than four days in a calendar week such as this year. That said the state nontreaty commercials seasons are not supposed to violate the 4/3 clause or the designated 0.8 nontreaty commercial exploitation rate simply to get more commercial harvest which Region 6 did in 2022 and 2023. The GHP does have an adaptive management clause to allow for modifications to harvest guidelines but when this was discussed during the process creating the GHP and staff assured all that this clause would only be used for issues of “extraordinary circumstance.” The GHP has a clause that limits harvest known as 3/5 that limits nontreaty impacts if a salmon species has not made escapement 3 out of 5 years. For 2022 this clause was in play for Coho when the preseason forecast showed substantial numbers of harvestable Coho. 3/5 was stood down and seasons set minus the 3/5 requirement limiting nontreaty harvest. I thought this was an appropriate use adaptive management and “extraordinary circumstance” but the expansion of the nontreaty commercial above the .8 Chinook exploitation rate in 2022 was not! To make things worse for 2023 staff utilized the loss of two days in the modeled 2023 nontreaty gillnet season from the 2022 NT commercial season which was only created by violating the GHP in 2022.

The 4/3 clause was included in the GHP because prior to the GHP WDFW managed harvest in the Chehalis River, which is the second longest watershed in the state, for commercial fishing at Aberdeen at the mouth of the river limiting the inland recreational fisheries and Chehalis Tribal fisheries. It took years of effort by local advocates for the inland communities to get reasonable salmon seasons for recreational fisheries. Additionally as a former commissioner said 4/3 had the unexpected benefit of providing a safety net for wild salmon escapement, primarily Chinook and Coho, which have failed make escapement even after the Chehalis Chinook escapement goal was reduced a few years back.

The continuing whatever between the Quinault Nation and WDFW staff needs to end as the fish and the Chehalis communities cannot afford it any longer. This thing where post Boldt decision WDFW has continued resent the imposition of co-management needs to end! If the QIN are harvesting more than the court mandated share then WDFW needs to forcefully address it but standing down conservation guidelines of the GHP for the states share is not the appropriate remedy.

Commissioners I urge you to find a third party to bring both the Quinault Nation and WDFW staff together to moderate a discussion to put an end to this ongoing issue between the two parties as it is clear they lack the will, desire, or ability to do so on their own.

If any have questions feel free to contact me and the final 2023 Harvest Model, GHP are attached.

Sincerely

Dave

Waiting anxiously to read the reply (or replies) but expect them to be spinning faster than a high-speed top.

Yup but unlike last time where we let the word smithing go by this time several people helped me and we will tear it down line by line. R-6 does not get any more free passes.

It is way past time when we held WDFW, and all agencies, to actual concrete performance and not platitudes.

As if that will actually happen here in Washington. What you see now, is what you got...

What we see now is what we allow ourselves to see.

It will be interesting to see if there is any kind of serious reply, usually these are ignored or fall on deaf ears. I personally don't understand how R6 can get away with the smoke and mirrors corruption for as long as they have. No oversight or accountability to higher ups, or the corruption goes farther up.

Since the people in R6 are appointed by the folks in HQ, they (HQ) must support what they are doing, right? I mean, they can't be that dumb. Can they?

Could not figure out where to post this so just put it up here. https://wdfw.wa.gov/about/commission/comanager-hatchery-policy is the link to the WDFW website info. Frankly considering the situation in R^ and the QIN I imagine it will go in the dust bin like the rest of WDFW's plans.


May 1, 2023
Contact: Ken Warheit, 360-902-2595
Media contact: Ben Anderson, 360-902-0045
WDFW seeks public input on environmental analysis of co-manager hatchery policy

OLYMPIA – The Washington Department of Fish and Wildlife (WDFW) is asking for public comment on an environmental analysis of a draft policy to guide management of hatcheries in cooperation with tribal co-managers.

In April 2021, the Washington Fish and Wildlife Commission adopted an updated Anadromous Salmon and Steelhead Hatchery Policy, and instructed WDFW "to begin development of a joint policy agreement on salmon and steelhead hatchery programs with tribal co-managers," which would supplement and supersede the existing Commission policy when appropriate.

After more than a year of collaborative work with technical staff under the direction of a subset of commissioners and tribal policymakers, a final draft policy was developed in November 2022. Following presentations to the full Commission, the draft policy was released for general public comment in February 2023. Results of that public comment opportunity were presented to the Commission in April.

The draft co-manager hatchery policy is now undergoing a State Environmental Policy Act (SEPA) public comment period; the SEPA determination, draft policy, and supporting documents are available on WDFW's website. Members of the public can submit comments on the SEPA determination online, by email, or by mail to:

Lisa Wood, SEPA/NEPA Coordinator
WDFW Habitat Program, Protection Division
P.O. Box 43200
Olympia, WA, 98504
Comments, including mailed comments, must be received by 11:59 p.m. on May 26, 2023.

The draft policy includes commitments to work as co-managers to develop and implement hatchery management plans on a regional or watershed-specific basis, while conserving natural-spawning populations of fish and mitigating the effects of habitat loss and other environmental impacts. The draft policy outlines six guiding principles to support these values.

The Washington Department of Fish and Wildlife works to preserve, protect, and perpetuate fish, wildlife and ecosystems while providing sustainable fish, wildlife, and recreational and commercial opportunities.

This draft "policy" has so many wiggle words in it, it really should not be considered any kind of policy. Lots of suggestions for actions, worded "should be considered" (or similar) rather than any commitment to actions, other than saying that habitat conditions require on-going hatchery mitigation. Since the statement about mitigation is without any additional qualifiers, I can only assume that it means everywhere.

I read nothing in the "policy" committing the co-managers to conserving natural spawning populations of fish. In fact that term is not used at all in the policy (that I could find). When there is a reference to natural spawning populations (several bullets under Principle #4), the terms "should consider" or "should strive" are always used. That's an easy one to get around as in "we considered it, but decided not to do it," or "we strove for it, but just couldn't accomplish it." This appears to be the perfect policy to accomplish nothing new in regard to hatchery programs, so I guess the perfect hatchery policy.

Good summary OncyT. Looks like the "new" co-manager hatchery policy is "We'll ad hoc it just like we've always done," and call it new.

It's too bad Salmo g. The WDFW staff was given instructions "to begin development of a joint policy agreement on salmon and steelhead hatchery programs with Tribal Co-Managers that has similar development and joint commitment provisions to those in “The Salmonid Disease Control Policy of the Fisheries Co-Managers of Washington State.” The disease control policy is very well thought out having very specific standards for 1) surveillance of pathogens; 2) fish health monitoring; 3) hatchery sanitation; 4) transfer of gametes and eggs, fish, carcasses, and water; and 5) site specific pathogen containment plans. These are specific to three levels of risk, i.e. transfers within watersheds, within fish health management zones, and across fish health management zones. These include almost 20 pages of technical specifications that have to be followed EVERYWHERE to protect fish health. You don't just get to decide what you want to do in any one particular watershed. If this template, which was suggested as an example of a successful co-management policy, was followed (suggested by Jim Anderson, past Executive Director of the Northwest Indian Fisheries Commission), they might have actually developed something useful.

Funny you should mention the Co-Managers Disease Policy. Back when I worked in WDFW hatcheries there were parts of the agency working against the policy; their Program had apparently never heard of it.

Frankly I wouldn't be surprised if there were parts of WDFW's hatchery program working against the policy. It put limitations on some things that could be done, and it required additional effort to do other things. Plus, any affected co-manager could object to a proposed transfer that wasn't going to be consistent with the policy. Can you image? Needing to be careful to prevent fish diseases from being spread around the state!!!...

I was talking about programs outside Hatcheries fighting the agreement. Inside was a whole other story.

Some pf the folks didn't care about disease, especially if it clobbered the hatchery, so long as wild fish were "helped".

Just my personal view is that there needs to be a whole lot more cooperation on what we do with our resources, inside and outside individual agencies.

Were you around when the late 80s VHSV hit? That was Goat Roping 101.

I understood what you were saying about programs outside the hatcheries. And these people didn't think that spreading diseases around would ultimately effect wild populations? They must have never heard of horizontal virus transmission. What I was suggesting is that the new policy put some limits on what the ops managers could do. They always liked doing exactly what they wanted.

Yeah, I was around during the VHS stuff. People "knew" it came from importing Atlantic salmon. We also "knew" that all fish on the hatchery sites had to be destroyed, that is until VHS was discovered at one of WDFW's hatcheries. Then they just had to be quarantined. (Just an observation from someone that was outside of WDFW .)