The reduction from 14 days to seven happened at the last Advisory meeting AFTER public participation ended as the sport side Advisers objected in writing to the Commission. In fact when one Adviser brought forward in an Advisory Meeting that the numbers needed to reflect reality Ron Warren responded that " he should be careful what you wish for " and it is on tape you can request it and listen yourself. It was a warning to the Adviser that if you corrected the numbers it would impact the season ( alter / shorten ) the bay sport fishery. Besides will you folks quit listening to what WDF&W says but rather look at what they do. The key thing is R 6 knows the numbers are not correct as the model in the last four four years hugely under estimates the bay sport & NT net impact and over estimates the inriver sport catch shown in the model. The real model impact error over the last four years numbers have been posted in the past on this website and FTC. In addition the mortality on releasing Chinook from the Tangle nets is a joke and the agency knows it. Take a look at it in action http://fishingthechehalis.net/chehalis-fling as WDF&W's own staff recognized in studies that a warm water estuary is nothing like the Columbia and the release does not work as most of the fish are dead. The idea that there is a reduction from that SWAG ( Wild Ass Scientific Guess ) 45% mortality to a lower percentage is just pure BS and WDF&W knows it. Falsifying math to achieve a harvest scenario is called " cooking the books ".

As I said before if you feel nets 6 to seven days a week are sound management you should be happy. Frankly this is little more than the same shell game that R 6 staff has done for years under the present staffing which have shown and unbelievable ability to utilize facts and numbers they know to be wrong and grossly misrepresent to citizens their ability to participate in the decision process. NOF itself is nothing but a " dog & pony show " and you pick the definition of someone that stands in front of a room full of citizens putting forth information that is completely inaccurate and misleading and they know full well it is. I know what my father called it .

Oh almost forgot, " Count your blessings " ? Nah I for one am not going to accept this load of crap. Opposition to the continuing institutionalized discriminatory policies toward the inland communities / inriver sport by WDF&W Region 6 policies is growing and folks have learned they can object to the CR 102 and the WAC right to the Commission as they adopt and more. It is game on.

WDFW (its predecessor WDF) have institutionally supported marine sport fisheries over freshwater since at least the early 80s. Once salmon get in the rivers they are supposed to be left alone to spawn. What is happening in R6 is really nothing new. Getting them to put the freshwater fisheries and communities at a higher priority will be difficult.

From a purely economic benefit standpoint which dead fish in the boat brings more economic value; the coho taken on a Westport Charter or that same coho taken by a Satsop bankie?

We like to argue that recreational fish generate more economic value than commercial catch; that same argument can and will be used to divide up the sport fisheries.

Escapement policy is the real question here, isnt it? The goals are way too low for that system and they are seldom achieved anyway. MSY is an evil mistress.

QIN would argue that the goals are way too high

Based on the way they manage, WDFW would agree that the goals are too high. Otherwise, they would develop management strategies that would show a higher rate of achievement.

What matters in not what the managers say about the resource or their goals. What matters is the end result. And the most important end result for GH fisheries is meeting the Bay net needs, with Bay sport next.

Yep. missing the Chehalis chinook goal 80% of the time over the past 15 years speaks volumes.

Meeting the goals, as low as they are, would be a start.

But to meet even the low goals would mean unacceptable restrictions on fishing.

Funny how WDFW and the tribes scated by the ESA and their own wild salmonid policy to do whatever they want, wherever they want.

While ESA does not apply yet to the chehalis except for bull trout, the WSP says they will meet and/ or exceed escapement goals unless they demonstrate poor habitat capability to benefit from those spawners. So lets see the data demonstrating poor habitat quality to excuse the current dismissal of wild escapement needs. They cant do it, unless they load their models with their own assumptions about habitat capability. And that isnt science, it is fitting models to suit their pre-held assumptions.

Every now and then insight comes roaming through the e-mail world. I found this a rather insightful read.



Here's a thought on the whole harvest thing. May have mentioned it before but it may explain at least some of the why and the powers behind it.

In Hoh v. Baldridge the tribe sued the Feds because they approved of ocean fisheries (the WA sport and troll) that took so many Hoh fish that the Tribe was closed for conservation. The Court held that the Tribes could not be shut down for conservation if the reason was prior harvest essentially, the tribes can't be corked. WDF response, from the technical folks, was OK-close the ocean. Escapement still being the #1 priority. Both the Tribes and Feds said no, just share the harvest. If you take 50 in the ocean, the tribe gets 50 in the river. WDF "went" along. This was begun under Wilkerson; Co-management and sharing the pain.

So, the Tribes are in favor of the ocean and bay fisheries (essentially in front of them) because it guarantees them a fishery. If the management paradigm was no fishing until we confirm runsize (some update fisheries) then the schedules would have to reflect something closer to reality. They tribes, and state, would have to manage in-season (more expensive) and might actually have to be close. The river sport is not only the bastard step-child but would put the tribe(s) in the uncomfortable position of having to be responsible managers as they could not cork the sporties if there was a significant fishery that came after them. This is what the court (Boldt) said about steelhead. The tribe can't cork the sporties.

So, ultimately, getting a significant increase in the river fishery will likely be opposed by not only QIN but many other WA tribes who prefer to see the non-Indians take their fish ahead of the tribal nets, so those nets can fish unfettered and if the run comes in stronger all the benefits are reaped by the tribe because the non-Indians took the shot they wanted.

Well as I have been going after the management of the Chehalis Basin for sometime I thought I would post up my comments on the proposed Grays Harbor Commercial CR 102 Supplemental. For those who do not know it is the legal process used to create a Washington Administrative Code ( WAC ) rule used to legally create a sport or commercial season. Bit long winded but there was a lot of ground to cover. If you want to comment the CR 102 can be at viewed http://wdfw.wa.gov/about/regulations/development.html#13-01-064 and your comments can be e-mailed to Lori.preuss@dfw.wa.gov

July 10, 2013


Lori Pruess copy by mail Via email, hard copy by mail
WDFW Rules Coordinator,
600 Capitol Way North,
Olympia, WA 98501-1091
Fax: 360-902-2155


Ms Pruess,

I am writing to express my opposition to the CR 102 Supplemental for Grays Harbor filed as WSR 13-14-123 on July 3, 2013 for the following reasons.

1. The commercial non treaty net fishery outlined continues the policies of institutionalized discrimination by WDF&W Region 6 ( R-6 ) toward the inland communities and in-river sport fishers. The proposed commercial harvest will remove the ability for the vast majority of fishers in these communities to harvest an equitable share.

2. WDF&W Region 6 continues to refuse to recognize and take as a whole the accumulative effect of three commercial fisheries in the Chehalis Basin / Grays Harbor. I fully recognize that the Quinault Nation's and Confederation of Chehalis Tribes share of the commercial harvest are court mandated and not open to discussion. The Legislature has mandated that the WDF&W Commission manage salmon harvest for both sport and commercial harvest is also true but it is my belief that the two tribal fisheries meet the commercial requirement and needs. For WDF&W R-6 to attempt to maintain and continue the non treaty net commercial harvest in the manner and magnitude proposed is to continue rejected past policies of WDF&W that identify fishers by race and ethnicity rather than accept that the court mandated tribal fisheries are the Chehalis Basin / Grays Harbor preeminent commercial fisheries.

3. During Public process know as North of Falcon ( NOF ) WDF&W Region 6 intentionally mislead the public by failing to identify and define the WAC processes. Staff described it as " opening the WAC " knowing full well that the CR 101 was filed 12/7/12 and CR 102 on 3/6/13 before the first Grays Harbor Adviser or the NOF Public Input meeting in Montesano. In addition staff were told via e mail in 2010 by the WDF&W Rules Coordinator that their approach to the WAC process was incorrect as substantial changes could not be made to the CR 102. WDF&W R-6 chose to disregard and continued with the practice identifying the process to the general public in a manner that was intentionally misleading.

After the public meeting in Montesano R-6 staff presented a modified non treaty commercial season to Grays Harbor Advisers with a season utilizing tangle nets for fourteen days with a 14.7 release mortality. This plan was again presented at the NOF meeting March 29th which is a daytime meeting that few citizens can attend due to having to work. On April 2, 2013 a number of GH Advisers supported a letter to WDF&W Commission Chair Wecker authored by Adviser Dr. Francis Estalilla outlining their opposition to the revised commercial season identified above. After Dr. Estalilla met with Director Anderson and several Commission Members at the following GH Adviser meeting WDF&W R-6 staff outlined a new schedule of 7 days at 25% release mortality which is reflected in the CR 102 Supplemental. At this date WDF&W R-6 has not released or provided documentation of the baseline data or methodology used to develop either the 14.7% release mortality or the 25% release mortality reflected in the CR 102 Supplemental. Having broodstocked both Chinook and Chum utilizing tangle nets, seine nets, and hook & line for over twenty years I can say with certainty the 25% tangle net mortality is not a valid release mortality anymore than the discredited 14.7% tangle net mortality or the previously utilized 45% gillnet release mortality assumption.

The 2013 Grays Harbor Fall Non Treaty Planning Model provided by WDF&W R-6 does not have the Quinault Nation or Confederation of Chehalis Tribes seasons and projected harvest data entered which is badly needed in any assessment of the proposed Grays Harbor CR 102 Supplemental. In addition WDF&W R-6 refuses to release the date, time, or location of the NOF allocation meetings with the Quinault Nation or Confederation of Chehalis Tribes and simply states the meetings are not open to the public. While I fully understand that a citizen can not actively participate in the meetings with the two tribes they can observe.

Blocking public access to WDF&W R-6 interactions with the Quinault co-managers is not a new issue as WDF&W R-6 staff even took the position that the Grays Harbor Adviser meeting could be held behind closed doors away from the public view without records being kept until this year when a newly appointed Adviser strenuously objected. The allocation meetings between the tribes are part of the NOF process and WDF&W R-6 is violating numerous rules and WDF&W Commission guidelines by denying citizens an opportunity to observe the WDF&W / tribal harvest allocation meetings which are part of the mandated public NOF process.

In reviewing the WAC processes utilized by WDF&W R-6 I that have outlined it is doubtful that any citizen would have the information needed to understand or comment on the commercial CR 102 Supplemental in an informed and knowledgeable manner.

4. It is my understanding that the approximately 48 mathematical errors in 2012 harvest model, identified by citizen John Campbell, have been corrected in the 2013 Grays Harbor Fall Non Treaty Planning Model but not the harvest assumptions that create the baseline impacts in the model. The model performance greatly underestimates 2A and 2D non treaty commercial fisheries, and the Grays Harbor Bay sport fishery. It also overestimates the in river sport harvest and both problems have been brought to WDF&W R-6 staff's attention repeatedly.

On average, the marine recreational harvest exceeds the model predictions by a factor of 350% and in 2006, anglers in the marine area overfished the modeled harvest by over 500%. Moreover, the non-treaty gillnets have historically killed 150% of their modeled paper impact over the past decade. The over-exploitation by non-treaty nets has become particularly acute in the past three years, averaging 250% of the modeled rate.

5. The management of Chinook stocks in the Chehalis Basin is in such disarray that Chehalis fall Chinook have only exceeded the minimum escapement goal twice in the previous 11 years and only 3 of the last 15 years. In other words WDF&W R-6 fails 4 out of 5 years to correctly manage harvest / escapement. This is compounded by the incorrect base line assumptions on Chinook release mortalities as WDF&W R-6 does not require utilization of the internationally accepted release protocols.
The survivability of released Chinook in a “selective” tangle net or gillnet fishery is predicated on the following protocols which are 1) avoidance 2) limited soak times 3) careful handling 4) use of revival boxes and 5) gentle release into safe waters. The non treaty commercial fishers simply release netted fish by throwing the captured fish into the river at the time of retrieval of the net at the bottom end of the drift and then proceed back upstream to reset their nets for another drift resulting in the same fish being caught time after time until it perishes, if it was fortunate to survive the first encounter. The use of revival boxes is discretionary and the released fish are simply hurled back into the river be it dead or alive. The end result being that the vast majority released salmon either sink to the bottom of the river dead with those that are alive being very lethargic resulting in the fish falling prey to marauding pinnipeds .
Another element of release survival is that Grays Harbor is NOT the Columbia River, these are NOT spring Chinook, and the water temperature is NOT nearly as cool and conducive to releasing stressed salmon. Water temperature in the time and area proposed is 57 degrees F in the Chehalis estuary compared to 44 degrees F in the mainstem Columbia in early spring. That makes the proposed 25% release mortality for tangle nets in Grays Harbor completely invalid as studies in the Willapa have shown. Factoring in what we already know about how the fish are mishandled the proposed tangle net season is simply a continuation of the same WDF&W R-6 policies of falsely representing the impacts of all Grays Harbor Bay marine fisheries with the non treaty commercial nets being the most egregious.

6. WDF&W R-6 identifies Chum stocks not by stream of origin but rather as Grays Harbor Chum, which is not done with any other salmonid species. Utilizing only three spawning reaches on the East Folk Satsop and Stevens Creek, a Humptulips tributary, the combined spawner escapement is extrapolated to provide the projected spawner success for the entire Chehalis & Humptulips watersheds and future harvest opportunity in any given year. This methodology is extremely problematic as it incorporates the returning adults from the 400,000 hatchery released Chum smolt from Bingham and Satsop Springs hatcheries located on the East Folk Satsop that spawn naturally with the wild Chum spawners. The hatchery origin adult Chum spawning are a substantial portion of the naturally spawning population resulting in massively inflated success ratio for wild naturally spawning Chum adults in the East Fork Satsop. This grossly inflated wild spawner recruitment extrapolated for the entire Chehalis Basin and Humptulips River Chum stocks results in a fatally flawed methodology. This methodology has allowed and dictated the continued overharvest / exploitation of Chehalis River Chum stocks above the Satsop River. This problem is not unknown to WDF&W R-6 as it has been identified by WDF&W's Science Division in the Ecosystem Diagnostic Tool potential projects report and others. In simplest terms the current WDF&W R-6 management of Chehalis Basin Chum harvest continues to decimate naturally spawning stocks of Chum and push many Chehalis tributary stocks above the Satsop River to the point of extinction.

This is complete failure of management. Ron Warren was very defensive and unprofessional when I pointed this out at the NOF meeting.

WDFW, actively destroying Chehalis basin salmon, for what? 19 gillnetters?

Yup. Probably less telling, but possibly more unprofessional, was Warren's snide response to citizen complaints that, despite what appeared to be banner coho returns, anglers had a tough time catching fish in the rivers. His response was (paraphrasing), What do you want me to do? Jump in the river and put a salmon on your hook?

It's pretty clear that Region 6 staff is directed to maximize the non-tribal harvest. Unlike most of the season setting meetings, the public is allowed to participate in NOF. As Rivrguy demonstrates, we're effectively only observers there, too.

Recent events have interesting parallels.

The pilots of the Asiana plane goiung to SFO flew the plane by the (pre-season) models-all the various automatic controls. Even after taking them off they apparently ignored the Real-World data. They were too low and too slow (run not materializing as expected). They took action at the last moment (closed the in-river sport fishery) and still broke off the tail (missed escapement).

In fish management, as in flying a plane, real world data and hands-on management seem to be needed. Unfortunately, this is expensive, time consuming, and may result in "aborting the landing"-closing a bunch of fisheries.

Or, keep flying on autopilot; it works most of the time.

The question was asked of R-6 " Nothing was discussed about the amount of Commercial boats that will be moving North into the Willapa Bay and Grays Harbor fisheries. Could you please tell me what the affects will be? "

Below is the body of the e mail from R-6 in response to the question. Now the model already under estimates NT Nets by 250% the past four years, just imagine what the increased number of boats fishing would do to the models accuracy! Do not know where they would fit them all but silly me did not know where 22 would fit in the river. Oh almost forgot. It took the gentleman several reminders and more than a bit to get the information.

The numbers are not formatted well but you can match them up to the categories.



RESPONSE:
As to your question about the potential effect of effort transfer from the Columbia River to Willapa Bay and Grays Harbor, there is no way to know for certain what shift in effort might occur. The critical factor is that of the human dimension and as a biologist not an economist or psychologist I can only speak to data from licenses issued during 2012.

There were 248 salmon gill net licenses issued for Willapa Bay and Grays Harbor. Of the 248 licenses issues, 201 were active, the remaining 47 were voluntarily placed in a suspended status by the owner. Additional detail is provided in the table below.

License status

Grays Harbor Net / Willapa Bay / Total
Active 47 154 201
Suspended 12 35 47
Grand Total 59 189 248


Possession of either license allows the owner to operate in the Columbia River. It is worth noting that of the 201 active licenses only 24 owners possess a license for both Willapa Bay and Grays Harbor. From that you can infer that there are 177 WDFW license owner that could operate in the Columbia River. As to the magnitude of a potential effort shift, in 2012 there were only 39 license holders who had no landing outside the Columbia River, in other words 39 of the 201 licenses operated exclusively in the Columbia. Of these 39 license holders 28 held a Willapa Bay license, so at most we could see an increase in the Willapa from 126 vessels to 154 or about 22% more than in 2012. For Grays Harbor the potential increase would be from 47 to 58 or about 31%. With the closure only affecting a portion of the Columbia and full opportunities in the SAFE areas it is unlikely that we would see a full shift in effort but some shift is possible.

Hope this helps, and again I apologize for the delay.
Sincerely

I was asked to provide the models and here they are in the links below. Now the links take you to the FTC library and the manner in which they are displayed is confusing and not that great. Our data storage is bulk by pages but if you down load them off the website ( hit the little down arrow ) they come in as fully functioning Excel spreadsheets.

Grays Harbor https://docs.google.com/file/d/0B2tWjgmgVy3ySTEwTWI4WDBJSU0/edit

Willapa https://docs.google.com/file/d/0B2tWjgmgVy3yUk9LMHVwMkQxbXM/edit

Here is template going around for objecting to the CR 102's for Willapa and Grays Harbor. As always it is best to draft your own objections but as so many are not familiar with the WAC process that sets seasons I thought I would put this out. Change or whatever you feel is needed or use this template but one should object. You can hard copy your objections to Lori Pruess at

WDFW Rules Coordinator
600 Capitol Way N
Olympia, WA 98501-1091
Phone: 360-902-2930

Or e mail at lori.preuss@dfw.wa.gov




July 19, 2013

To: Washington Department of Fish and Wildlife

Re: Proposed CR 102 Supplementals for commercial gill net seasons in Willapa and Grays Harbor


I am a recreational license holder that fishes in Willapa Bay and Grays Harbor and their tributaries. I believe my license entitles me to fish and retain salmon just as much as does a license issued to a commercial gill netter. I do not believe it is proper for the Department to intentionally discriminate against one category of license holders in favor of another.

WDFW has historically allocated 75% to 100% of the Chinook, Coho, and Chum available for harvest in GH and the Willapa to commercial gill netters. At the same time, the number of fish actually reaching the spawning grounds continue to decline creating significant risks for future fisherman of all kinds. The current proposed season continues these improper practices by over-fishing with nets to the point the sportsman and the spawning grounds are shorted fish.

I and other sport fisherman purchase products and services from local small businesses in the areas where I am able to fish. The seasons currently proposed will prove as disappointing this year as it was last year. Many sport fisherman have stated they are not willing to spend the money to travel to fish in Willapa or Grays Harbor if these gill net seasons go forward as planned. The proposed seasons act to discourage tourism in the local towns around Twin Harbors and adversely affect the economy of the region.

It is disappointing that hundreds of citizens can say the same things over and over in meetings, hearings, and letters or petitions and have a public institution like WDFW simply ignore them. The two new proposals do not address the concerns that all those citizens raised with their objections to the first proposals announced earlier this year. Once again, WDFW has chosen to simply ignore the public.

I ask that you do not pass the proposed seasons and develop new proposals that are fair and equitable to those who hold recreational fishing licenses. I sincerely hope an agreement that ends the discriminatory treatment of sports fishing and the favoritism shown commercial gill netters regarding harvest allocation can be found.



Most importantly, for all fishing in these areas, are seasons that no longer over fish with nets. We must allow the fish needed to preserve and maintain the runs to actually complete their journey to the spawning grounds and/or to the hatcheries. Without allowing this cycle to function, the complete fishery in these areas will collapse.



What a travesty this would be, to see no more salmon running in these rivers.



Sincerely,

I know it is not the Chehalis but it is last call to comment on the CR 102 Supplemental for Willapa. It is Grays Harbor on steroids as to mismanagement. Over 82% of the harvest will go to the commercials, nearly 9% of the TOTAL Chum run will be moralities tossed over the side and we are talking the total run not harvestable numbers. Pretty much more of the same. What is not normal is the reaction of the local community in objecting to and taking on the agency. Had a full room at the Monte hearing ( such as it was ) on the CR 102 and they are learning they do not have to take it.


From Barbara A Mcclellan WDF&W Region 6

We wanted to inform you that the written comments for the public hearing scheduled for July 23rd for the rules proposed in the CR-102 Supplemental filing for commercial salmon fishing in Willapa Bay has been extended to July 25th, which is two days after the public hearing. The Dept. wanted to provided additional opportunity to comment.

You can view the CR-102 Supplemental filing documents at: http://wdfw.wa.gov/about/regulations/development.html#11-03-058

If you have any questions, please contact us here in the Region 6 office.

Today is the final day to object to the CR 102 Supplemental for Grays Harbor Commercial Gillnets for 2013. The information and links are back up this thread along with enough information to cherry pick yourself over the edge. Bottom line last year one individual ended up on the permanent record objecting to that fiasco ( and it was not me and that is embarrassing to say the least ) Look all your have to do e mail Lori Pruess and identify your objecting to the CR 102 Supplemental for Grays Harbor Commercial Gillnets for 2013. Use your thoughts or others but get in the debate. This problem with the commercial nets is a self inflicted wound on the sports side. As so many are willing to set on their butt bitching and unwilling to take 5 minutes to join the effort to roll back the commercial harvest abuses by Region 6, then the end result is what you see now.