Without ranting I will put this out to chew on. The QIN asked R-6 Fish Program if their proposed 2014 seasons violated any court agreed to escapement goals" & the answer was NOPE. The court mandated escapement goals are for Grays Harbor and all the streams empting into it and do not break them down by tributary streams. So the QIN manages itself ( no co management here ) for 50% harvestable across the bar FOR THE ENTIRE WATERSHED COMBINED. Now the state separated the Humptulips and Chehalis years bck but the tribe did not agree to amend their court rights and frankly appear unwilling to consider doing it either. So you have two different views on how things are managed. When all streams are combined in that manner then the total of escapement has been met or is close in recent years. This results in the final total looking OK but tributaries some down ( about 1/3 of the Chehalis watershed crashing with Chum & Humptulips Wild Coho never making escapement ) and some way up depending on the year & all three species run size.

Well, well, well....

WDFW changed how Region 6, Chehalis/Humptulips, was managed......change was done for a few reasons, major was to benefit the growing sports marine fishery.

QIN stayed with the "time honored way" of management.

WDFW needs to change back to the management style, that seemed to keep peace, with all the parties concerned.......IMO

Time for WDFW needs to understand that a gill net is a gill net. QIN and Chehalis tribe can meet commercial fishery, from GH, for the salmon eating public.

NOF process could be made a lot easier, less costly and State coffers, enlarged with a more active sports fishery in the Chehalis basin.....again, IMO

[quote Fawn Sharp]“As co-managers, the Quinault Nation and State should be working collaboratively and cooperatively to conserve Grays Harbor salmon.
[/quote]

Yes they should Fawn, so why don't start working on that?

Sometimes in the ongoing conflict between the Rec & Commercial fishers we forget that the discussion ( sounded better than brawl ) has a very human element. The following two letters one addressing Grays Harbor and the other Willapa, obtained in a PDR, capture that rather well. It is rather easy to blind one's self to the human cost to REC families and traditional Commercial fisheries but it is very real.

A Commercial perspective:
To the Members of the Washington State Salmon Commission,

I am the wife of a 4th generation gillnetter out of Grays Harbor. Adolf Bold, our great grandfather, made and fished his gillnets by hand as he worked as a German immigrant coming to the United States in hope of a better life. This year my son was the 5th generation from our family to step on a grays harbor gillnet boat. This fishery is very much a part of our family's history and heritage. We value commercial fishing, specifically gillnetting as it has supported our family for over a century .

I am saddened to learn that commission is favoring sport fishing over commercial fishing. I am also disappointed to see that many other avenues of conservation have not been explored. It seems that all accounts of fishery depletion are being pinned on the gillnet fleet. Commercial gillnetters are following the guidelines clearly set out by WDFW, and yet they are being "punished" for following the rules.
While I understand that Chinook salmon runs are low and concerns are high, I do not believe that allocating more fish to the sportsmen will do anything to further conservation efforts. With the introduction of live boxes and net changes, gillnetters have adapted and have seen decreased mortality. We would like to see similar efforts made on the part of the sportsmen whether it be isolation of spawning grounds, regulations on jet boats, decreased catch limit, or limited entry, there must be concessions made on both sides- not continually on the part of the commercial gillnetters alone.

Please keep in mind that these fishermen are family driven people, they work very hard to make a living and are dependent on the resources that they harvest. There is continual accusation of the moral character of the fleet, the honesty of their catch and the professionalism of their endeavors. While sportsmen continue to advocate for increased observation and supervision among the gillnet fleet, we would like to see increased observation among the sport fishery. The assumption that an individual has better intentions, better moral character, and stronger inclination to follow the rules simply because of fishing for sport vs. fishing for income is ridiculous. Assume the best of these men, their work ethic alone speaks volumes on the strength and endurance of their character.

While we all recognize that changes must be made, I certainly hope the commission will consider the impacts of the continual cut back of the non-tribal gillnet fleet. These impacts certainly will have an immediate impact on our income, and the incomes of those in the fishing community, but in the long­ term they will impact the legacy of family's like ours. Please do end our way of life in order to silence the present demands of those who are unwilling to compromise.

Commercial fishing is our heritage; it is our history and our future.


And a Recreational Fisher Perspective:
Westport/Grayland Chamber of Commerce

I am contacting you on behalf of recreational fishers in Willapa Bay and Grays Harbor. Business owners should be able to support both commercial and sport fishing. They should not be bullied into making a choice. Most of the gill netters in this area are fine people. There is a very small fraction that want the sport fishers out by any means. There has been name calling and harassment on the Tokeland docks. Here is an example, a man was walking down the dock to his boat in the morning. He passed by a few gill netters standing by one of their boats. He said nothing to them but after he walked by one of them shouted "we gotta get these ---- suckers outa here". They threaten business people with the loss of their dollars if they support us in any way. My wife and I stayed a month per year in Tokeland for 18 years and spent a considerable amount of money from South Bend to Westport. We don't fish there anymore because of what I have encountered. I won't elaborate on what I have been called.

In past years, we had to struggle but both sides got a decent season at the annual salmon meetings. In 2010 the WDFW made no pretense of fairness. The sport fishing representatives that attended thought it was not a legitimate negotiation. They held private meetings with the gill netters before each of the last two meetings. Towards the end of the last meeting, one of the commercial fishers said something like, "we've wasted enough time, isn't it time to tell them how it's going to be?" Soon after his statement the DFW did just that. In recent years the gill net fishing started around mid September in Willapa Bay. In 2010 They received a so called "test fishery" with not many boats but quite a few dates. They got two full fleet openers in August just when the recreational season is beginning. They started their regular season about four days earlier than the recent average.

The DFW also required us to release all unmarked Chinook and coho. This is very frustrating, many anglers reported a 50% release rate. With Chinook, the naturally spawning and hatchery salmon are all the same stock. The native silvers that are scarce don't come in until nearly a month after the marine sport fishery is basically over. They required the gill netters to release the unmarked salmon also. Catch and release gill netting makes no sense. At the mortality rate they are assessed at, they wasted 940 kings and 9,544 silvers, then add the sport fishing mortality. This is an awful waste of food and I was told it was a disgusting sight, the dead salmon drifting down with the tide.

Westport spends a lot of money attracting us to this area. The DFW and the gill netters appear to be trying to get rid of us. The Department totally ignored the letter the Chamber sent last year. If this doesn't change there will be a constant decline in recreational fishing. I was told the South Bend launch was down about 50% last year, Tokeland was down too. Some members of the Legislature seem to have some leverage on the DFW. You probably know a lot more about that than I do. We do not want to take over, we just want what is fair for us and for the business community. I am sending a copy to the 19th District Legislators.

On the subject of South Grays Harbor, as you know a great Chinook sport fishery has been lost. It was good for us and for you. The DFW still allows a non tribal gill net Chinook mortality and they have allowed a sport fishing Chinook mortality with a coho fishery. With Tribal fishing, I wondered if you had tried talking directly to them. This could be of interest to sport and commercial fishers also. There is also the habitat destruction in the Chehalis headwaters. I really hope we can make some progress on all these problems.

From WDF&W Willapa Commercial Season

July 28, 2014


To Interested Parties:

This letter is to inform you of commercial salmon gillnet fishery regulations in Willapa Bay during 2014.

Please be aware that not all commercial fishing areas are open during each opener and that the area around the North River (see summary of schedule for a specific description of closed area) in area 2T is closed to fishing prior to 6:00 p.m. on September 30, 2014. Retention of sturgeon and steelhead is strictly prohibited. Encounters of sturgeon with tags of any sort should be reported. DO NOT REMOVE tags; carefully obtain and submit information from tags to the Washington Department of Fish and Wildlife, 48 Devonshire Rd., Montesano, WA 98563.

During all commercial fishing for salmon in Willapa Bay:
- Commercial fishers MUST:
o Have in their possession a WDFW-issued “fish Friendly” certification card.
o Carry an on-board observer when requested by Washington Department of Fish and Wildlife (WDFW) to do so.
o Report encounters of green sturgeon through the Quick Report system or to a dealer for reporting. Direct reporting by fishers shall include name of the fisher and vessel #, date, catch area, and number of green sturgeon encountered.

- Wholesale dealers and fishers retailing their fish MUST
o Report purchases of salmon including all “take home” to WDFW by 10:00 A.M. of the day following the commercial landing. The quick reporting requirement does not preclude the obligation of buyers to report catches on fish tickets. A copy of the “Statewide Quick Reporting Summary Sheet” can be downloaded on our website at: http://wdfw.wa.gov/fishing/commercial/. Dealers should use the “buyer only” portion of the fish ticket to list the number of green sturgeon encountered with any landing and in the pounds/price columns label as ‘encountered’.

These regulations are subject to change based on in-season information. You are advised to verify schedules and regulations on the WDFW hotline at (360) 902-2500 or (360) 249-4628 before fishing. You may obtain a copy of the Washington Administrative Code (WAC) for this fishery at http://wdfw.wa.gov/about/regulations/2014/wsr_14-15-052.pdf .

This letter and other relevant information regarding this fishery are available on the WDFW website at http://wdfw.wa.gov/fishing/commercial/salmon/netting_schedules.html. For additional information or questions, please contact Barbara McClellan at (360) 249-1213 at the Region 6 Montesano office.


Summer Fishery (openers occurring between July 22 and August 15 annually):
6:00 a.m. August 12, 2014 through 6:00 p.m. August 15, 2014; Areas 2N, 2T (excluding North River closure area), and 2U ONLY. Retention of any species other than coho, Chinook, and chum is prohibited; 9-inch maximum mesh size.

Fall Fishery (openers occurring between August 16 and November 30 annually):
Gear restrictions:
- Openers occurring prior to 7:00 a.m. September 8 the maximum mesh size is 9 inches.
- Openers occurring between 12:01 p.m. September 8 and November 30 the maximum mesh size is 6 ½ -inches.
Area restrictions:
- No openers will occur in areas 2K and 2P during 2014.
- During the fall season no openers are scheduled in Areas 2M, 2R, and 2T until 6:00 p.m. September 15.
- Area 2T north of a line from Toke Point channel marker 3 easterly through Willapa Harbor channel marker 13 (green), then northeasterly to the power transmission pole located at 46°43.1907'N; 123°50.83134'W), is closed to fishing prior to 6:00 p.m. September 30.
- Each week from September 15 through October 3 Areas 2M, 2N, 2R, and 2T close at 6:00 p.m. Friday evening; each of these weeks 2U closes one day prior at 6:00 p.m. Thursday evening each week (September 18, September 25 and October 2).

Mark selective fishery and recovery box requirements:
- From 12:01 p.m. September 8 through 12:00 p.m. (noon) September 22, 2014.
o Soak time is limited to 45 minutes during any set.
o Recovery boxes are required and must be operated when gear is being retrieved and when a wild (unmarked) Chinook or steelhead is being held to recover.
o All wild (unmarked) Chinook and all steelhead MUST be placed in an operating recovery box and remain until they are not lethargic and not bleeding; ALL wild (unmarked) Chinook are required to be released.
o Regulation Compliance Incentive Day, please be aware that an opening noon September 21 - noon September 22 may occur provided that compliance as accessed during previous days fishery openings exceeds 90%, this day will be implemented by e-rule.

Atlantic Salmon
Wholesale dealers and fishers are asked to contact the Washington Department of Fish and Wildlife should Atlantic salmon be taken during any fishery in Washington waters. Please notify the appropriate WDFW staff member of when and where the fish was encountered or contact Fish Program in Olympia at (360) 902-2700.


2014 Summary of Willapa Bay Summer and Fall Commercial Gillnet Fisheries
This summary sheet is provided as a courtesy for use as a quick reference and does not fully describe 2014 rules. For additional information or questions, contact Barbara McClellan at #360-249-1213 or Mike Scharpf at #360-249-1205.

The following are in effect for ALL commercial openers in Willapa Bay:

• Retention of STURGEON is PROHIBITED. ALL encounters MUST be reported to Wholesale Buyer or Quick Reporting
• For QUICK REPORTING (by 10am the day following landing), NOTICE OF INTENT, and reporting GREEN STURGEON ENCOUNTERS: Fax 360-249-1229; telephone 1-866-791-1280; email harborfishtickets@dfw.wa.gov
• Notice of Intent to fish any opener during 2014 is REQUIRED by August 5, 2014.
• All participants MUST have attended a "Fish Friendly" best fishing practices workshop and have their department-issued certification card in their immediate possession.
•
Date and Time Area Mesh size stretched Requirements and gear restrictions:
6:00 AM, Aug. 12 through 6 PM, Aug. 15, 2014 2N, 2T (except those waters north of a line from Toke Point channel marker 3 easterly through Willapa Harbor channel marker 13 (green) then northeasterly to the power transmission pole located at 46° 43.1907’ N, 123° 50.83134’ W), and 2U 9-inch maximum



RELEASE STURGEON


7:00 PM, Aug. 25 through 7:00 AM, Aug. 26, 2014,
7:00 PM, Sept. 1 through 7:00 AM, Sept. 2, 2014,
AND
7:00 PM, Sept. 7 through 7:00 AM, Sept. 8, 2014.
2N and 2U 9-inch maximum
7:00 PM, Sept. 8 through 7:00 AM, Sept. 9, 2014,
7:00 PM, Sept. 9 through 7:00 AM, Sept. 10, 2014,
7:00 PM, Sept. 10 through 7:00 AM, Sept. 11, 2014,
AND
7:00 PM, Sept. 14 through 7:00 AM, Sept. 15, 2014. 2N and 2U 6 ½ -inch maximum RELEASE ALL WILD (UNMARKED) CHINOOK AND STURGEON

Live boxes are REQUIRED to be used on-board

Soak times are limited to 45 minutes (from gear entering the water until fully removed)
Continued on next page

Date and Time Area Mesh size stretched Requirements and gear restrictions:
6:00 PM, Sept. 15 through 6:00 PM, Sept. 19, 2014,
2M, 2N, 2R, and 2T (except those waters north of a line from Toke Point channel marker 3 easterly through Willapa Harbor channel marker 13 (green) then northeasterly to the power transmission pole located at 46° 43.1907’ N, 123° 50.83134’ W) 6 ½ -inch maximum RELEASE ALL WILD (UNMARKED) CHINOOK AND STURGEON

Live boxes are REQUIRED to be used on-board

Soak times are limited to 45 minutes (from gear entering the water until fully removed)
6:00 PM, Sept. 15 through 6:00 PM, Sept. 18, 2014,
2U 6 ½ -inch maximum
6:00 PM, Sept. 22 through 6:00 PM, Sept. 26, 2014,
AND
6:00 PM, Sept. 28 through 6:00 PM, Sept. 30, 2014
2M, 2N, 2R, and 2T (except those waters north of a line from Toke Point channel marker 3 easterly through Willapa Harbor channel marker 13 (green) then northeasterly to the power transmission pole located at 46° 43.1907’ N, 123° 50.83134’ W) 6 ½ -inch maximum

RELEASE STURGEON
6:00 PM, Sept. 22 through 6:00 PM, Sept. 25, 2014,
AND
6:00 PM, Sept. 28 through 6:00 PM, Oct. 2, 2014

2U 6 ½ -inch maximum




RELEASE STURGEON


6:00 PM, Sept. 30 through 6:00 PM, Oct. 3, 2014,
2M, 2N, 2R, and 2T 6 ½ -inch maximum
6:00 PM, Oct. 4 through 6:00 PM, Oct. 7, 2014,

12 AM, Midnight, Nov. 2 through 11:59 PM, Nov. 7, 2014,
12 AM, Midnight, Nov. 10 through 11:59 PM, Nov. 14, 2014
AND
12 AM, Midnight, Nov. 17 through 11:59 PM, Nov. 19, 2014. 2M, 2N, 2R, 2T, and 2U 6 ½ -inch maximum

This issue is a very interesting. For many the thought that Director Anderson gives a preference to Commercial fishers is rather dominate. From the Commercial side I bet that view is not shared, to say the least. For my part I will take you back to the final North of Falcon at Olympia a couple years back. Region 6 District 17 utilized nearly 3 1/2 hours putting forth just what was possible and what was simply unattainable. Then Director Anderson came down from his office and set in a bit until we broke for lunch. Coming back into the meeting following lunch we were witness to staff pounding away on the lap top keyboard utilized to display the model and options on the wall. What happened next was a bit mind boggling as now what was not possible was possible and what was possible ( for the Recs ) was now not! This prompted one attendee to state in a rather load voice "it isn't safe to go to lunch around here!"

So did Director Anderson use his position to influence the outcome for the Commercial and Recs in Grays Harbor? Depends on your view as the Recs yup but no from the Commercials I imagine. It is the Directors role to guide WDF&W through processes but out of the public forum underway? Behind closed doors? Nah ain't buying that BS. Mr. Anderson is a knowledgeable man and if he has views he should state them openly, in a forthright manner to the ENTIRE group of folks in attendance. The failure of WDF&W to grasp that the lack of openness and transparency continues to erode the public's faith in WDF&W as a government institution. Frankly lack of openness and transparency helps drive WDF&W's lack of ability address the many challenges facing the users and resource itself.

Offhand these guys need to do a serious reboot if they have any desire regain the public's trust. The real question is do they give a damn?


The letter below is a response from Commission Chair Wecker who does appear to care and attempted to address the Advocacy's concerns about the Directors influence.

July 18, 2014
Twin Harbors Fish and Wildlife Advocacy
PO Box 179
McCleary, WA 98557

Dear Sirs:

I am writing in response to your letter dated May 17, 2014. The gist of what you request is contained in this paragraph from your letter:

"This all leads us to the point where we ask for the support of the Commission. Again, not to adopt or oppose any particular season and, certainly not to micro‐manage. Rather, we simply ask that the members of the Commission use individual or combined influence to insure the public that the professional staff within Fish Program have the freedom to make the final decisions for a 2014 commercial season based on their combined professional judgment using the education and expertise they hold and to do so without fear of damage to their careers."

The Commission views its role in holding the Department accountable as one of its more important jobs. I have no evidence that Department staff have been unable to use their professional judgment due to "threat of damage to their careers." That said, I do understand that season setting in Willapa Bay has become increasingly contentious and likely will become more so. It is vital that the public have confidence that the Department is adhering to high standards of professionalism especially with respect to our conservation mandate.

This year, some changes have been proposed in setting the Willapa salmon fishing seasons. The Commission will not be able to thoroughly review Willapa fisheries management options until we begin our official consideration of the development of a policy for Willapa salmon management -- a process we expect to begin in October.

However, in the next couple weeks, I will have a conversation with the Director regarding the mechanisms that are in place to assure that staff can offer their best professional judgment in the decision-making process that leads to the setting of seasons in Willapa Bay.

Thank you again for your comments,

Miranda Wecker, Chair
Washington Fish and Wildlife Commission

The information below is from Region 6 and the CR 102 Commercial Grays Harbor. A link is provided to WDF&W's website.



In an effort to reduce unnecessary printing costs and help protect our environment, we are asking those interested in viewing the CR-102 proposed WAC changes to access it electronically at the following web site, where it can be viewed or downloaded.

http://wdfw.wa.gov/about/regulations/development.html

A public hearing will be held in accordance with RCW 34.05.325 at the Region 6 Montesano Office in the large conference room, 48 Devonshire Road, Montesano, WA 98563 on Tuesday, August 26, 2014.

Discussion times will be:

1:00 p.m. – 3:00 p.m. WAC 220-36-023 - Rules for commercial salmon fishing in Grays Harbor.

In case you are unable to or do not wish to attend the public hearing you may submit written comments to: Rules Coordinator via mail at: WDFW Enforcement 600 Capitol Way N., Olympia, WA 98501-1091, via e-mail: Rules.Coordinator@dfw.wa.gov or via fax: (360) 902-2155 by August 19, 2014.

If you would like an email copy or need a printed copy of the proposed rules, please send a request
to: Rules.Coordinator@dfw.wa.gov or call (360) 902-2700.

In sorting a Public Document Request I happed upon this document. It is a summary of comments to the Commission from the public as the Commission developed the new plan. Some may find this to be Interesting reading and there is a wide range of thought to be sure.



11 January 2014

Summary of public comment regarding draft Grays Harbor Salmon Management Policy.

Included below are excerpts from written comment received between October 21, 2013 and January 9, 2014, and verbal testimony summarized from the December 7, 2013 Fish and Wildlife Commission meeting. Comments have not been edited for content or to correct spelling, grammar, or punctuation.

Comments were summarized into ten (10) categorizes including: allocation, alternative fishing practices, communication/transparency, conservation, data rigor, economic value, enforcement/accountability, hatcheries, limit effort, and miscellaneous.

Categories are collated by major reason for which the policy is needed (Enhance Conservation Focus, Restore and Maintain Public Trust, and Clarify Sharing of Impacts), followed by a section with remaining categories.

Enhance Conservation Focus

Conservation
• The state wants to kill down to the last fish. We need to think about conservation.
• Calculated in FRAM down to the last fish the bycatch to the last fish.
• complete closures have been implemented before and the fish come back. It that is what it takes fine. It comes down to conservation. We need the fish in the gravel.
• ESCAPEMENT GOALS and SALMON CONSERVATION must be the #1 Priority. Once the resource is gone, everyone loses.
• Escapement ,We must meet escapement goals each and every year. This is imperative to the survival of the fish that swim and spawn in these waters. Any type or length of fishery should always be secondary. I am well aware that this could mean on lean years that we do not have a directed fishery by anyone and if that is what it takes then so be it.
• It was abundantly clear from the vast majority of attendees that consevation of Grays Harbor wild salmon is their highest priority. Several topics were included within the conservation umbrella; opposition to the Chehalis River dam, ocean-derived nutrition, harvest management and more.
• The state is driving to ESA.
• As for Conservation, everyone needs to do their part.
• My big thing is in-season management. I think conservation needs to be the top priority, even if it limits my opportunity to fish ensuring that over-forecasting doesn't have to result in overharvest, and subsequently missed escapements.
• This fishery must have season checks and balances to ensure that we do not over harvest on any given year
• Guiding Principles Item 14; When a mark-selective fishery occurs, the mark-selective fishery shall be implemented, monitored, and enforced in a manner designed to achieve the anticipated conservation
benefits. Everytime the WDFW feels that the selective harvest is expected to impact fishery escapements goals, the fishery is shut down, but it's only shut down to sport fisherman and not tribal/commerical havesting.
Escapement goals are not being met, yet we allow the tribal fisheries to run nets 7+ days a week which has a much greater impact on returning salmon than any sportsman catch.

• At the heart of the current difficulties is not just rec v commercial but rather the inland communities citizens growing and adamant opposition to the failure to make escapement and the practice of WDF&W awarding the vast majority of harvest taking place in the marine area communities of Aberdeen and Hoquiam.
• concerned about failure of Reg 6 management. Not making escapement.
• Continuing to fail for the last 10 years.
• Escapement goals are not being met.
• for too many years too many fishermen taking too many fish.
• Blatant overharvest by the QIN, particularly Chinook. Late coho and steelhead are in a similar state as Chinook.
• Millions of dollars have been spent by tax payers and Logging companies to create more habitat yet WDFW has not increased any Escapement Goals, provided more fish to the gravel, increased wild populations, to match the third largest watershed on the Pacific Coast on the United States. I see some great opportunities to increase fish populations in this wild river system that is capable of providing a better future of this resource.
• The people of our state have invested a lot in enhancing habitat for salmon yet Region 6 has been content to leave goals low and then seldom meet them. In a region which has been satisfied and enjoyed management job security while missing escapement goals for Gray's Harbor and Willapa Bay 9/10 of the time, a culture change would be needed.
• 30 years of experience in the legislative projects. I have worked on habitat recovery and still no fish in Wildcat Creek.
• Unfortunately, too little time was provided for indepth discussion regarding policies to achieve wild salmon recovery in Grays Harbor and its tributaries - far too much time was again consumed for allocation discussions
• If you are concentrating on the escapement maybe you should start in the ocean fishery. You don’t want to admit to the amount of fish you are allowing to be killed in the “catch ten and release to keep one fishery”.
• Article about Alaska Kenai Salmon - "Catch and release practices prevent many salmon from reaching a spawning location or result in poor spawning success."
• For the recreational fishery in Grays Harbor I would like you to consider the following: Any year there are not enough chinook to have a retention fishery that area 2.2 from the Chehalis River bridge (highway 101) to the mouth of Johns River (piling number 8) be closed to all fishing before the first of October. This is needed to save chinook salmon from over harvest via hook and release. Large numbers of fishers show up to see how many chinook they can catch in one day even though they release them. One fisher bragged to me they caught 17 chinooks in one day when it was non retention only.
• The spring chinook fishery is a joke. The only reason the tribe fishes for spring chinook is to harvest wild steelhead that are returning. This practice need to STOP!
• If CTRC is the non-treaty tribes then this draft does not allow a non-treaty spring Chinook fishery in the Chehalis River system. I support no non-treaty tribal fishing for spring Chinook in Grays Harbor and the Chehalis river system.
• Another issue I have is why is ANY spring salmon fishery of any kind allowed on the Chehalis River system?

Limit effort
• I would like to state for the record that I believe that until you curtail the tribal fishery it will be of little use to keep restricting the non tribal fishers.
• One partial solution is to LIMIT GUIDES AND CHARTER OPERATORS TO A SINGLE TRIP PER DAY. It would probably be prudent to have logbooks for guides to get a more accurate reporting of the true catches for salmon, sturgeon, steelhead and walleye.
• A quicker and more effective option would be to use a “drawing” similar to elk harvesting wherein a preset number of license holders will be granted the ability to fish in the upcoming season. While the number of fishers active each season would decrease, establishing a drawing avoids seasons where all the participants suffer when sales of fish caught “….didn’t cover the cost of the diesel”.
• for too many years too many fishermen taking too many fish.

Alternative fishing practices
• We must require sustainable forms of fishing. Currently Recreational fisherman utilize barbless hooks and selective or non-selective fishing as a means of ensuring the right fish are taken at the right times. Entanglement nets are not a sustainable fishing method.
• Make everyone even that's commercial fishermen go back to hook and line
• Following the example set in harvesting razor clams, crab, and shrimp, we propose that WDFW consider establishing commercial seasons wherein recreational and commercial license holders harvest with the same gear (poles), in the same geographical areas and at the same time throughout the entire season. License fees and bag limits could be adjusted as well. One example would be a commercial license at three times the recreational license and the commercial bag limit at three times the recreational in a corresponding fashion.

Restore and Maintain Public Trust

Communication/ Transparency
• The Grays Hbr. Advisory Committee, WDFW Fish biologists, and GH gill net assoc. should be on record as to their method, data and tools used to recommend the catch sharing percentages for each sector outlined in this "draft". I would like to see fishery decisions in Washington State made on biologically sound information. It appears that political influence now dictates many decisions made by WDFW.
• The public needs to be informed that the catch allowed by the non-treaty Chehalis Tribe(s) comes out of the recreational sector. If the category designated as CTCR in the charts is the non- treaty Chehalis Tribe(s), it needs to be designated as such in the draft policy. Non-treaty catch quota should not be taken from the recreational sector. How can WDFW give the non-treaty Chehalis Tribe(s) a catch percentage when they provide no catch figures to WDFW? My recommendation is "no catch figures", "no fishing".
• The Director and the Region need to bring co-management back to Grays Harbor.
• We need to talk about the QIN. They overharvest year after year. Then tell the state what they are going to do without any say from the state. WDFW needs to take them to court.
• There is no co-management in Grays Harbor. If the state is not fishing then the tribe will.
• WDFW needs to include previous run estimates, escapement goals and final catch statistics for each sector to determine an equitable catch percentage. The percentages "proposed in the draft" , for each sector have no meaning without inclusion of above mentioned data from previous years. The percentages outlined in the draft are meaningless w/o previous data.
• Overall the GH management plan is too vague and unclear. It is good to see a committment for an annual review but there is little mention of metrics against which performance would be measured by the commission. This is a region that has regularly underperformed on escapement goals for multiple species for over a decade.
• The current draft does not have specificity. What we are looking for in the policy are deadlines and goals.
• These guidelines are only a tweaking of the current guidelines. In Willapa there are no co-managers – even with no co-managers the results are the same. Guiding principles, communicate, document, etc. these are not principals they are window dressing.
• I offered comment, those are not in the policy; asked for teeth in the policy they are not there either.
• Comments about communication – with the internet, communication is easy. With short notice through the internet look at all the people who are here.
• Thirdly, All participants in this fishery must meet their obligations to be involved in the process of season setting and ensure that their numbers and dates are published in the proper manner.
• I want to see the Public more involved in the WAC process before North of Falcon. This process has only involved a fee people invited by WDFW. The Commercial Fleet has dominated this process for many years with WDFW supporting them over Conservation. The Tribes are also part of the Commercial harvest and should be regulated in the same process instead of WDFW letting them do what they want.

• The APA process is not being followed. I have spent $10K’s of my money bringing lawsuits against WDFW, and have 1000’s of hours of time invested. The public trust is lost. Kehoe, you said for us to write the document, we did that. None of that is in this document. Don’t close the door or your mind on this.
• far too much time was again consumed for allocation discussions… it amounts to nothing more than a wishing session between the gillnetters and the sporties.

Data Rigor
• The tools the department has is like a butter knife. The first improvement needed is the CRC. Like to see timelier reporting like in the PS crab CRC. Adaptive management, like in PS, monitor the fishery more closely and shut the fishery down when the quota is reached. Need a policy that passes fish to the spawning beds. There is no co- management in Grays Harbor. If the state is not fishing then the tribe will.
• Region 6, forecasts runs before fish hit the hatchery; need to let the fish hit the hatchery then forecast. I fish the Skookumchuck and have seen the enhancements.
• needs to be a framework for in-season management, ensuring that over-forecasting doesn't have to result in overharvest, and subsequently missed escapements.
• Science and biology should drive management.
• Calculated in FRAM down to the last fish the bycatch to the last fish. Then set the season in days. The mortality percentages - 45% is not in the Columbia studies. The study is only long-term, where is the short term? Other studies should be reviewed.
• The current Management plan and models for the Chehalis Basin and Willapa Basin are not acceptable anymore and out dated. Millions of dollars have been spent by tax payers and Logging companies to create more habitat yet WDFW has not increased any Escapement Goals, provided more fish to the gravel, increased wild populations, to match the third largest watershed on the Pacific Coast on the United States.

Enforcement /accountability
• The sports fisherman are getting more and more of the allocation every season. The sports fishers are not being held accountable for their catches as we the commercial fisheries are being held accountable for every fish harvested.
• Anglers on guide trips would also furnish license numbers to the guide to record days fished and actual catches to avoid cheating on the annual limits.Daily recording in the logbook should be mandatory and all entries should be made within 24 hours of the trip completion. Alaska uses this system but when boat launch areas are super busy then it is easy to forget to complete the log on site and a 24 hour allowance for recording final catch info would be fair. AK imposed fines for non completion on site and that was strictly a revenue operation and lead to many confrontations between guides and enforcement personnel.
• Selective fishing if its going to happen it needs to follow scientifically designed procedures and protocols. In Grays Harbor they violate all internationally recognized rules.
• They need to fish selectively like they have been trained.
• It was also made clear that there is considerable support for increasing the number of WDFW enforcement officers in order to maximise conservation efforts to recover Grays Harbor wild salmon
• there is considerable support for increasing the number of WDFW enforcement officers in order to maximise conservation efforts to recover Grays Harbor wild salmon.
• The public needs to be informed that the catch allowed by the non-treaty Chehalis Tribe(s) comes out of the recreational sector. If the category designated as CTCR in the charts is the non- treaty Chehalis Tribe(s), it needs to be designated as such in the draft policy. Non-treaty catch quota should not be taken from the recreational sector. How can WDFW give the non-treaty Chehalis Tribe(s) a catch percentage when they provide no catch figures to WDFW? My recommendation is "no catch figures", "no fishing".
• We need to monitor the Quinault’s and take them to court.

Clarify Sharing of Impacts

Allocation
• 77,000 people sport fish salmon in the state of Washington (1.1%); the commercial fishers provide fish to the rest of the state. Allocation should be 50:50 on all species.
• In the survey the sports zeroed out commercial allocation. Sport have lots of opportunity statewide.
• I fully support the non-treaty commercial salmon fishing in Grays Harbor. Generations of families in Grays Harbor have been supported by the salmon gilnetting season - I strongly encourage you to consider those families - it's very important to them.
• I have been a gillnetter for over forty years. In the 70s we would get to fish from the 6th of July till sometime in November. The fleet of boats was over four times what it is today. We had a very valuble sport fishery during those times also.
• I support the non-tribal commercial salmon fishery in Grays Harbor. The non-tribal commercial salmon fishery is vital to many families in our area. Please keep this is mind when determining future allotment of our resources.
• There are other fisheries in GH, we need to be mindful of the share that comes to the state. That is the portion that should be fairly distributed to sport and commercial fisheries. The sports emphasize that there are two fisheries; sport and commercial - and that commercial include the tribes.
• The sports fisherman are getting more and more of the allocation every season. The sports fishers are not being held accountable for their catches as we the commercial fisheries are being held accountable for every fish harvested. Washington gives the tribal fishers 58% of the allocation. Start there. The commercial catch is nominal compared to the tribal and the sports fishers
• The Chehalis side should have a small amount of Chinook set aside for the commercial to access to coho. There are large surplus of coho – hatchery and natural both.
• Divide the catches of Chinook equally between the recreationals and gillnetters for wild chinook. Since wild coho has been the run of concern for the last several years they will be used as incidentals during chinook and chum fisheries. Impacts to be used when run size is below escapement goal will be divided 60% gillnetters and 40% recreationals. The only exception to this is if the run size is 156% greater than the escapement goal then there could be a directed wild coho fishery divided 60% recreationals and 40% gillnetters. Between 110% and 156% of escapement goal the wild coho will be divided 60% recreational and 40% gillnetters. Hatchery chinook
and hatchery coho will be taken during other Humptulips fisheries.
• The goals for recreational fishing involving "experience" or "opportunity" are inappropriate. We are already seeing this concept being abusedd in plans for alternative gear elsewhere in the Columbia. OR officials are talking about closing sport fishing during peaks of runs to allow enough mark selective commercial harvest using purse seines! Sports not to worry, you will get extra days during off peak run times. Seines get the harvest, sports get the "experince" of more fishing with less opportunity per day. This is how sports fishing is to be minimized, along with its superior econiomic benefits. The draft guidelines need to be changed to prevent this approach in Region 6.
• They should not be fishing more than 3 days / week. They are taking huge sections out of the run.
• the commercial gill nets should be in the water one day less than what it was this year. Ive been keeping an eye on the nets in the river because I drive over the Chehalis river bridge in Aberdeen every day and have seen nets in the river, either commercial or native american, 5 days a week. That is unacceptable for recreational fishing because when they take the nets out on Friday, it takes a while for those fish can get through to get up the river to where bank fisherman can have some fun and try and catch some salmon to allay the exorbitant cost for the license. I have no problem paying the license cost but expect the recreational fishery to be given more emphasis.
• One good thing is to allow 3 d/wk without nets. Need a change in the current conscious approach. End of year review – compared to what? Need more in the policy.
• Support 3 days/week proposal for net free.

• The 3 day proposal for net free; what does that mean? The treaty fishery is already fishing 4 days/week, does this leave the NT fleet sitting on the beach?
• The rec option offered 3 days sport and 4 days commercial. The Commercial won’t offer a compromise. Recreation is willing to have days on and days off.
• Tribal and commerical netting should only be allowed on a Sun (1200) - Thursday (1200) during the fishery. If the catch goals are not met, extensions or additional netting days can be addressed and granted, but only after escapement data is reviewed.
• I want to see the Public more involved in the WAC process before North of Falcon. This process has only involved a fee people invited by WDFW. The Commercial Fleet has dominated this process for many years with WDFW supporting them over Conservation. The Tribes are also part of the Commercial harvest and should be regulated in the same process instead of WDFW letting them do what they want.
• Similarly, it was very clear that future, non-treaty salmon harvests should be guided by the greatest benefit to cost ratio - from the data shared this evening it seems that recreational fishing accounts for far greater revenue to Washington state than does the commercial sector.
• At the heart of the current difficulties is not just rec v commercial but rather the inland communities citizens growing and adamant opposition to the failure to make escapement and the practice of WDF&W awarding the vast majority of harvest taking place in the marine area communities of Aberdeen and Hoquiam.
• The QIN fishery represents more than a meaningful commercial opportunity, and it should be the only one they are obligated to allow. I would like to state for the record that I believe that until you curtail the tribal fishery it will be of little use to keep restricting the non tribal fishers.
• Commercial netting should be stopped immediately within Grays Harbor and its tributaries. This is an outdated practice that is not sustainable today in this location due to overharvest and impacts on sensitive species as
it does not allow of selective release listed groups of fish. Addtionally there is not the abundance of fish in Grays Harbor that allow this practice to continue. The economic benefit of having a strong sport fishery in Grays harbor and its tributaries far out weigh the small benefit that harvesting the remaining fish by commercial fisherman
• The public has repeatedly stated that a tribal net or a non-tribal net is a commercial net under state law. The legislative mandate of the Commission and department states, "The department shall promote orderly fisheries and shall enhance and improve recreational and commercial fishing in this state." (RCW 77.04.012). You will notice the law does not require the Department to provide three commercial fishing opportunities based on tribal affiliation. The attached AGO shows the Attorney General was asked if a non-tribal commercial fisherman who opted to take the buyout could sell the boat back to a tribal fisherman. The AG opined that a tribal fisherman was a commercial fisherman under state law and such could not be done. Since the Chehalis and the Quinault commercial fishing takes approximately 58% of the available harvest in Grays Harbor, the mandate is fulfilled without the Department imposing yet another third commercial fishery.
• The inland community does not perceive a difference between the commercials. This ain’t Mobile Alabama 1963 the state needs to get over it, the tribes have the right to take their fish.
• Steady decline in the Chehalis. You see that there are two different gillnets, this is one fishery. We are fishing behind all these nets. There should be a focus on one netting season – 60:40 commercial.
• Two fishing interests – rec and commercial. Both interests desire the maximum allotted to them. The commercials scoop hundreds, the recs use one hook, and can only keep two.
• Economics we important, look at where the money comes from; you are supporting a welfare system for the GH commercial fleet.
• Allocation should be developed on science not public opinion. It needs to be understood that nets are not in the water 24hrs / day, the fish get through. Sound fishery science.

Other

Economic value
• Commercial value does not account for 1000’s of coho that go un-harvested.
• Increasing the sales price of the fish harvested commercially would provide compensation for the reduced harvest volume. WDFW should consider eliminating the would allow the commercial license holders the ability to market the fish caught at retail (i.e.commercially in its seasons in Grays Harbor be sold at wholesale to a licensed fish buyer. This requirement that fish caught “Fresh Tuna” on the dock in Westport, fresh salmon at the farmer’s market in Olympia, etc.).
• I'm a sportfishing guide based out of Olympia. I spend the majority of my days fishing in the Chehalis Basin. A dependable season would make my job much easier. I can book trips without fear of in season shutdowns.
• I look at things in terms of money. Are you getting your numbers up? That is an investment. If we are not getting fish back then why are we spending the money?
• The economic benefit of having a strong sport fishery in Grays harbor and its tributaries far out weigh the small benefit that harvesting the remaining fish by commercial fisherman.
• Also, the economic impacts do help the local economy in a big way My clients, for a two person trip pay me around $175 a person for a days fishing. Many people come from out of the area, spending money on motels, dinner, lunch and assorted other items plus licensing. This benefits many in the local area. I also try and buy my supplies locally as well as fuel and my licensing. Thanks for taking this into account when looking at fishings impacts to the local economy.
• recreational fishery has more economic value than the commercial fishery (at least that is what your data suggests even though you say that it is not comparable to commercial data), that the commercial gill nets should be in the water one day less than what it was this year.
• it was very clear that future, non-treaty salmon harvests should be guided by the greatest benefit to cost ratio - from the data shared this evening it seems that recreational fishing accounts for far greater revenue to Washington state than does the commercial sector
• Economics we important, look at where the money comes from; you are supporting a welfare system for the GH commercial fleet.
• I am writing to express my interest in the Grays Harbor non treaty gillnet fishery. South Bend Products purchases a large percentage of the harvested fish from Grays Harbor. The fishery produces high quality fish that are marketed throughout the country. Please consider the fact that in addition the income the fishery provides to the fisherman, it provides jobs to on- site buyers and crew, truck drivers, plant workers and office staff. Reduction or elimination of the non-treaty fishery is a reduction of jobs in Gray’s Harbor and Pacific Counties. I would appreciate your consideration of maintaining the non treaty fishing opportunities in Gray’s Harbor.
• The GN licenses actively used are about 50% of those sold. You could cut that by 50% again and you might have viable fishery.
• late 1970-80’s commercial buyback. The commission mandate in state law is to maintain the viability of the fishing industry.
• sport fishery $1.5M, in current dollars is close to $2M.

Hatcheries
• We also need to restore the hatchery production that has been lost.
• Also you have to fertilize the River you have to put the salmon carcasses back in the River to fertilize the River, most of the rivers are stale and dead now because they have not had the salmon carcasses that the bugs need to feed on. Let's revive the rivers. Then also put as many fish in the River as possible. Then it would make no difference whether it was a hatchery fish are wild spawned fish it would be in the River and you'd have as many fish as you need.

• As for the hatchery's put the hatchery's at full speed raise as many fish as possible get them in the River, it doesn't have to be a year later after they have attached, put them in immediately.
• enhancing the Salmon returning to Grays Harbor. I only see maintaining what we have now.

Miscellaneous
• Neither current escapement goal methodology nor eelgrass management practices by WDFW take into account the natural carrying capacity of these bays
• Region 6 has been content to leave goals low and then seldom meet them. In a region which has been satisfied and enjoyed management job security while missing escapement goals for Gray's Harbor and Willapa Bay 9/10 of the time, a culture change would be needed.

As the fall salmon season grows near many have questions around the issue if they will see positive change and equity for inriver sports fishers. Yes but just how is dependent upon the fish, weather, and the rivers natural processes. ( flows / temperature, ect. ) So we wait and in the not to distant future it will play out. So rather than babble on and confuse many ( most including myself ) as the various directives in the new Grays Harbor Management Plan ( GHMP ) play out we will explain how the guidelines effect Recreational Fishers as the 2014 Fall Salmon season unfolds.

So has the implementation of the Grays Harbor Management Plan ( GHMP ) been a success? From a Non Treaty Commercial Gillnetter perspective I imagine the word terrible comes to mind. From my perspective it has been a tough go but I think yes is the answer. Do issues still exist that need to be addressed? Oh yeah but a good management plan should not only set direction but bring issues forth that need further review.

This exactly what has happened. In my letter to the Commission below I have outlined several issues that for so many years WDF&W simply refused to address and simply ignored them. So now folks we will watch the process unfold as for the first time in decade WDF&W will have to address these issues in public at the Commission level.

It is going to be interesting watch play out to say the least! My thoughts on issues at the moment are outlined in the letter below.



Dear Commissioners,

The months since the Commission adopted the new Grays Harbor Management Plan ( GHMP ) have been interesting, to say the least. While citizen views are diverse as to the success of the GHMP mine are simple, " it has been 100% successful". Why one may ask? The answer is simple enough. A management plan should not just provide a framework for harvest and set standards to be reached but through utilization of management framework identify issues that require further review. This is exactly what has happened in the implementation of the GHMP again this is not a failure Commissioners but rather a success!

In the adoption of the plan it was made clear by the Commissioners to all the citizens and organizations participating that this was going to be difficult journey as the conservation driven GHMP was implemented. I can say with certainty that has been the case.

In addition the Commission committed to review of the plan to address issues arising from the implementation of the new GHMP. With that in mind Commissioners I wish to bring forth three issues that I feel need to be addressed in the review.

ITEM 1: Humptulips Natural Origin Coho ( NOR )

The Humptulips NOR Coho have not made escapement for 23 consecutive years that I have documentation of and several agency staff believe this is the case since the Humptulips Hatchery began operation. To compound the problem the Hatchery Origin Recruits ( HOR ) Coho numbers spawning went as high as four HOR Coho for every one Natural Origin Recruits ( NOR ) Coho spawning. This year before any harvest the Humptulips NOR Coho would not make escapement even without harvest.

We have been told that the Quinault Indian Nation ( QIN ) sees no issue with this as the combination of NOR and HOR spawning in the gravel combined to make escapement is acceptable. One could reject this position rather easily except there is justification for their position and it exist in the East Fork Satsop River. In the 1990's local volunteers assumed operation of a closed WDF&W facility Satsop Springs and developed programs broodstocking to rebuild Chinook & Chum stocks. Brood is taken, spawned & reared an released on site into river. The returning HOR adults spawn with the NOR adults and broodstocking is utilized to minimize any reuse HOR adults in the egg take.

So how is the issue of Humptulips NOR Coho different from EF Satsop NOR Chinook and Chum? Both are integrated stocks, in fact with the Humptulips HOR staying rates so high for so many years I would venture a guess that the Humptulips Coho hatchery Coho are exactly the same genetically as the NOR spawning Coho. If not for the Chum supplementation by HOR adults it is doubtful EF Satsop Chum would make escapement minus supplementation one generation out and most definitely not two life cycles. I believe that Humptulips NOR Coho need to be high on the review list if not the primary issue.

ITEM 2: Dual Management

We have been told that the QIN has the position that US v Washington ( and other court decisions ) gives them the right to 50% of the harvestable salmonids entering Grays Harbor. That the 50% is applicable to total of streams that enter Grays Harbor. WDF&W on the other hand separate the Humptulips and manage it independent of the bay tributaries and Chehalis River. This results in the model many times ( most ) showing over harvest of either a Chehalis or Humptulips stock. Prior to separating the Humptulips from the Chehalis Basins both WDF&W had the same management plan. It can be said that when both had the same plan it seemed that there was less turmoil.

Additionally we have been told that the QIN asked the question "do the proposed 2014 QIN Commercial seasons violate any court agreed to escapement goals?" To which WDF&W staff responded "no". If the QIN position is correct we have a issue that needs resolution. In my mind the harvest rights of the QIN are court mandated and unchallengeable. So what to do? Model Non Treaty fisheries around the QIN seasons? Continue to move forward and hope the QIN recognizes the validity of the GHMP? Simply put Commissioners this is a co mangers issue and one that citizens can not have much influence on. This is dual management not co management, goes hand and hand with item 1, and needs to be reviewed.

ITEM 3: Wynoochee Mitigation:

Myself, Joe XXXX, and Bill XXXX have been working with Jim Scott, Steve Theisfeld and Region 6 staff to develop a plan to fulfill WDF&W's Wynoochee Mitigation obligations by the end of September as the Commission directed. It was our view that after over two decades of failing to move the Wynoochee Mitigation issue forward it would be difficult but doable. Simply put Commissioners yes we still feel it is doable. As to difficult? That is a understatement of the first order. We believe the task can be completed but I would venture a guess that the issues may push our efforts up against the deadline. Hopefully not but both agency staff and ourselves are attempting to meet the Commission's expectations.

Additional Thoughts 4/3:

One item that will unfold in the next few months is the benefit of the GHMP directive of three consecutive days net free ( 4/3 ). In a recent weeks some have lamented that much of the gains from 4/3 will go to the QIN fishers so 4/3 is a failure. This commissioners is just plain wrong. ANYONE who fishes in river above Aberdeen will benefit greatly. Does this means the QIN set net fishers who fish the tide water reach benefit? In a word yes as the returning salmon will not always clear this reach of the river in three days. While the QIN may gain some benefit the Recreational fishers and the fish itself will reap the greatest benefit.

When one considers that for a decade or more Region 6 utilized the preseason run forecast for inriver recreational fisheries rather than what remained after bay recreational, QIN harvest, and Non Treaty Commercial resulting in inriver recreational fishers only getting approximately half of the season they were entitled to. Frankly Commissioners this whining by those who now must face the issue of equitable distribution of harvest and have been the benefactors of the past practices by Region 6 staff.

In closing let me say again I regard the New GHMP introduction as a huge success. That many in Conservation, Sport, or Commercial camps may disagree depending on their perspective is a given. From my perspective the issues outlined in this correspondence have been present and known for many years by few. The GHMP ended that and required that WDF&W Region 6, QIN, citizens, and user groups address these issues. I, for one, sincerely appreciate the Commissions courage and effort to chart direction for managing Grays Harbor fisheries in a manner that guarantees protection of not just the fish but future generations of harvesters.

Thank You.

In the past weeks I have received questions regarding the Grays Harbor Management Plan ( GHMP ) and just what are a citizens' rights if WDF&W violates the policies put forth by the Commission? One has the right to object to WDF&W in writing from the Director down through the layers of staff. You can also write the Commission and attend Commission meetings and address the issue in the " Public Comment " period of a Commission meeting.

Well and good many feel but that really does not require that WDF&W truthfully and completely address a citizens' concerns. Correct to a point and the Washington State Legislature addressed this by passing the RCW below. ANY citizen who feels that WDF&W has violated a Commission Policy can utilize section two of the RCW below. At the absolute least they have to respond in writing minus the usual smoke & mirror routine. The most you can expect? That the policy is put though the legal process and becomes law which is different than " advisory " as the current GHMP passed by the Commission. WDF&W violate the law and a citizen ( or organization ) can seek to have the courts enforce the law. The legal standards are much different than advisory guidelines the Commission adopts.


RCW 34.05.230
Interpretive and policy statements.

(1) An agency is encouraged to advise the public of its current opinions, approaches, and likely courses of action by means of interpretive or policy statements. Current interpretive and policy statements are advisory only. To better inform and involve the public, an agency is encouraged to convert long-standing interpretive and policy statements into rules.

(2) A person may petition an agency requesting the conversion of interpretive and policy statements into rules. Upon submission, the agency shall notify the joint administrative rules review committee of the petition. Within sixty days after submission of a petition, the agency shall either deny the petition in writing, stating its reasons for the denial, or initiate rule-making proceedings in accordance with this chapter.

(3) Each agency shall maintain a roster of interested persons, consisting of persons who have requested in writing to be notified of all interpretive and policy statements issued by that agency. Each agency shall update the roster periodically and eliminate persons who do not indicate a desire to continue on the roster. Whenever an agency issues an interpretive or policy statement, it shall send a copy of the statement to each person listed on the roster. The agency may charge a nominal fee to the interested person for this service.

(4) Whenever an agency issues an interpretive or policy statement, it shall submit to the code reviser for publication in the Washington State Register a statement describing the subject matter of the interpretive or policy statement, and listing the person at the agency from whom a copy of the interpretive or policy statement may be obtained.
[2004 c 31 § 3; 2001 c 25 § 1; 1997 c 409 § 202; 1996 c 206 § 12; 1995 c 403 § 702; 1988 c 288 § 203.]
Notes:
Part headings -- Severability -- 1997 c 409: See notes following RCW 43.22.051.
Findings -- 1996 c 206: See note following RCW 43.05.030.
Findings -- Short title -- Intent -- 1995 c 403: See note following RCW 34.05.328.
Part headings not law -- Severability -- 1995 c 403: See RCW 43.05.903 and 43.05.904.

Well yesterday was interesting! The Director resigned, the first budget proposal was presented and the Thurston County Court just upheld the lower decision in which the Puget Sound Harvesters Association (gillnetters) argued the 2012 commercial season in Puget Sound was illegal as it did not provide gillnets the same opportunity to fish as purse seiners. The court found that the Department's position that the non-selective nature of gillnets that had higher mortality for bycatch than seines was justification for refusing the gillnetter's request for more fishing opportunity when it passed the season regulation. All in all the total of all three made for a really really bad day for commercial salmon harvesters.

If you want a copy of the decision just PM me and I will get it to you. The budget draft is running in another thread so take a look.

So, the court said a non-selective gear can, when selectivity is needed, be given less time and fish. Wonder how that would play in Federal Court since fishing gear used (I believe) is a personal choice and not a genetic requirement.

That's covered in the opinion. The court (it was actually the state court of appeals upholding Thurston County Superior) held that the gillnetters did not have an equal protection claim under the state or federal constitutions.

Its at least a three banana day

I was not talking about the NT gillnetters.......................

Sounds kinda like a trifecta to me....

One man's trifecta is another man's trifucta. Good to be aligned with truth, justice and wisdom for once!

Recently WDF&W provided documents regarding the recent reduction in Natural Origin Recruits ( NOR / Wild ) Chinook for streams entering Grays Harbor approved by PFMC. Boiled down this is for the Humptulips and Chehalis Basins and is for the accumulative total of both. WDF&W's position and Commission directive that separates the Humptulips and Chehalis Basins for harvest has not been recognized by the Quinault Nation so we have a issue that needs resolution. Dry reading to be sure but for those that choose to monitor the scientific rational for decisions that effect the salmon resource in Grays Harbor the documents are informative. One thing about it is that the reduction was not conservation driven but rather established a new Maximum Sustained Yield ( MSY ) for Chinook stocks. As the PFMC document is rather long I cannot post it up so if anyone wants a copy PM me and I will send it on to you.

I received the comments below on the QIN proposal and PFMC reduction for the Grays Harbor Chinook escapement goal. I found the comments to be very interesting and well thought out.



There is so much about this issue, and as it pertains across all species.
First, it will be very difficult to directly challenge the analysis. There are established methods and they will be used. Consequently, the answer they get is mathematically defensible. Rather, there is a philosophy that needs to be discussed by WDFW. The following questions need to be dealt with, but ultimately it is a policy choice. And since QIN wants a lower goal.

1. The EDT analysis that CBFTF had done for Grays Harbor identified 12, 692,956 square metres of Fall Chinook spawning area. Giving a pair of Chinook 100 square metres (way more than necessary) gives you 126,930 redds, or 250K+ fish just to use all the habitat. Specifically ask why WDFW does not plan to utilize the available spawning area.

2. If WDFW/QIN choose not to utilize the spawning area (a policy choice) will they identify the non-used areas and direct WDFW-Habitat that HPA's not condition applications for Chinook protection.

3. For Puget Sound chum, WDFW set an escapement goal (purportedly MSY) in the late 1970s. In the 1980s and 90s escapements were significantly higher. In at least one case an order of magnitude. When Ricker curves were run on the wild stocks, in each and every case, the "MSY" goal that was calculated was higher. The goals were left unchanged. The point is that significant increase in escapement can increase MSY.

4. Need to realize that MSY is a somewhat ephemeral concept. Ford Arm coho, in SE AK, is managed at a constant 60% exploitation rate. Because of changes in stream productivity brought about by pink spawners the harvest of fish has ranged from 1,000 to 8,000. At no pinks, the 1,000 catch and approx. 600 spawners was "MSY". At 2 kg per square metre pinks they had 5-8,000 harvest and escapements of 3-5,000 spawners. Again, MSY. So, I would insist that rather than calling whatever they come up with "MSY" that they call it some sort of "sustainable escapement goal".

5. The escapement goal they come up with is only as good as the data. Especially the range of data. If all of the escapements that they look at are (say) under 10,000 then there is no way they will call 250K as MSY. It is terminology and this is a good place to start.

Steve Thiesfeld asked that we spread the word on the opener today.



Good morning everyone,

I’ve heard some rumors that the local paper indicated that marine area 2-2 opened this morning. Just a reminder, the only part of area 2-2 that opened today is the part north of Sand Island towards the Humptulips River. The Chehalis River also opened above Highway 101. All other areas are still closed.

Please help spread the word.

Thanks.

Steve Thiesfeld
Washington Department of Fish and Wildlife
Region 6 Fish Program Manager
48 Devonshire Road, Montesano, WA 98563
Steven.Thiesfeld@dfw.wa.gov
360-249-1201