| Wild Steelhead Moratorium |
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The following document, the
Concise Explanatory Statement, is the final step in the rule development
process for the wild steelhead moratorium. This document contains the
original rule proposals that were sent out for comment, a summary of the
major points brought out in the testimony supporting and opposing the
retention of the moratorium, and the modification made by the Commission
to the original proposal, as well as the Commission’s reason for
adopting the rules, and their response to comments on the proposed rules.
Concise
Explanatory Statement
Wild Steelhead Moratorium
Proposed rule change for WAC
232-12-619
| Rule
Description |
Proposed
Rule Change |
| Seasonal
steelhead limit |
Restore
the annual limit of five wild steelhead, taken from waters where
retention of wild steelhead is allowed. |
| Daily
wild steelhead limit |
Restore
the daily limit of one wild steelhead, taken from waters where
retention of wild steelhead is allowed. |
| Wild
steelhead release |
Restore
language that would allow exceptions to the statewide rule of
wild steelhead release. |
| Steelhead
moratorium |
Delete
the language creating the moratorium. |
|
Adopted
Rule for WAC
232-12-619
The adopted rule differs from the above in one way. The seasonal limit
for wild steelhead was changed from five fish to one fish. In lowering
the annual limit for wild steelhead, the Fish and Wildlife Commission
stated their intent to act in a very conservative manner, while still
allowing some harvest of wild steelhead on the streams described below.
Proposed
rule change for WAC
232-28-619
| Area
Description |
Proposed
Rule Changes |
| Bogachiel
River – mouth to Highway 101 |
Restore
rule allowing wild steelhead retention - December 1 through
April 30, one wild steelhead per day may be retained. |
| Calawah
River - mouth to Highway 101 |
Restore
rule allowing wild steelhead retention - December 1 through
April 30, one wild steelhead per day may be retained. |
| Clearwater
River - mouth to Snahapish River |
Restore
rule allowing wild steelhead retention -December 1 through
April 15, one wild steelhead per day may be retained. |
| Dickey
River (including all forks) |
Restore
rule allowing wild steelhead retention - December 1 through
April 30, one wild steelhead per day may be retained. |
| Goodman
Creek outside Olympic National Park. |
Restore
rule allowing wild steelhead retention -December 1 through
last day of February, one wild steelhead per day may be retained. |
| Green
(Duwamish)River- From the First Avenue South Bridge to SW 43rd
Street/South 180th Street Bridge: |
Restore
rule allowing wild steelhead retention - July 1 through July
31 and September 16 through November 30, one wild steelhead
per day may be retained. |
| Green
(Duwamish)River-From the SW 43rd Street/South 180th Street Bridge
to South 277th Street Bridge in Auburn |
Restore
rule allowing wild steelhead retention - July 1 through July
31 and October 1 through November 30, one wild steelhead per
day may be retained. |
| Green
(Duwamish) River- From the 277th Street Bridge to Auburn-Black
Diamond Road Bridge |
Restore
rule allowing wild steelhead retention - July 1 through July
31 and October 16 through November 30, one wild steelhead per
day may be retained |
| Green
(Duwamish)River-From the Auburn-Black Diamond Road Bridge to
the Tacoma Headworks Dam |
Restore
rule allowing wild steelhead retention - July 1 through November
30, one wild steelhead per day may be retained. |
| Hoh River
from mouth to DNR Oxbow Campground Boat Launch |
Restore
rule allowing wild steelhead retention – December 1 through
April 15 one wild steelhead per day may be retained. |
| Hoko River
from mouth to upper Hoko Bridge |
Restore
rule allowing wild steelhead retention - December 1 through
March 15, one wild steelhead per day may be retained. |
| Pysht
River |
Restore
rule allowing wild steelhead retention - December 1 through
the last day of February, one wild steelhead per day may be
retained. |
| Quillayute
River – from the mouth to the confluence of the Soleduck and
Bogachiel River |
Restore
rule allowing wild steelhead retention -December 1 through
April 30, one wild steelhead per day may be retained. |
| Quinault
River, Upperfrom mouth at upper end of Quinault Lake to National
Park boundary: |
Restore
rule allowing wild steelhead retention - December 1 through
April 15, one wild steelhead per day may be retained. (Note:
the end date for the season on the Upper Quinault River was
changed from March 31 to April 15 during the normal rule change
process. The steelhead moratorium then closed wild steelhead
retention on the river. The proposed season shown reflects
the new end date). |
| Soleduck
River - from the mouth to the concrete pump station at the Sol
Duc Hatchery |
Restore
rule allowing wild steelhead retention -December 1 through
April 30, one wild steelhead per day may be retained. |
|
Adopted
rule for WAC
232-28-619
This rule was adopted as proposed.
Summary
of Testimony Received
A huge amount of public testimony (several hundred letters and e-mails
and several petitions) was received on this issue. The bulleted items
capture the main points of those supporting and those opposing the moratorium.
Major
points of those supporting the retention (or extension) of the moratorium:
- It does not prevent
angling, but it does reduce the kill of wild steelhead. It will increase
spawner abundance. During periods of low productivity this has paid
off in watersheds such as the Chehalis.
- This regulation
was recently enacted and should not be changed until the end of the
trial period.
- Harvest of wild
fish should be put on hold until the impact on wild stocks is understood.
Harvest could impact stocks to a point they could not recover. The
2-year ban on harvest will allow time to review the data and make informed
decisions based on science rather than emotions.
- Federal, State
and Local governments are spending millions of dollars to save and protect
wild steelhead runs, and private property owners have to grant protective
buffers and treat water to protect these fish. Catch and release fishing
has proven a successful alternative (Montana trout, Yakima River, etc.)
providing local tourist/angler service industries dollars.
- MSH has a very
poor track record for a variety of species. Too often, commercial interests,
struggling against each other, farmed fish, etc. take a short-term view
for their own survival. They are generally will organized and funded
and make rational-sounding arguments calling for increasing harvest.
The striped bass fishery is a case in point.
- We are at a crossroads.
The runs are depressed in nearly every river system. Over the last
50 years, we have watched the number of healthy steelhead streams allowing
wild fish harvest has dwindled from over 125 to a dozen. Most of the
streams still open are in trouble as well, as the number of wild steelhead
returning is on a downward trend.
- Urge you to make
the moratorium permanent. Any community that thinks I am more likely
to spend my fishing dollars in their city because I can kill a wild
steelhead is mistaken – the opposite is the case. I don’t care to fish
where wild steelhead can be killed.
- It is time to realize
our natural resources are limited and there are too many people on the
earth. There is no lack of protein in our society.
- Many states have
gone to wild steelhead release and the result has been overwhelmingly
positive. Your own angler questionnaire showed over 56% of Washington
steelhead anglers favor wild steelhead release.
- The runs deemed
“sustainable” are by the standards of history greatly depleted. Never
forget that combined with environmental degradation and other factors,
we have the capacity to overharvest a resource to its extinction
- Wild steelhead
are a state resource requiring protection throughout the state. The
belief of managers that there is a harvestable surplus on the west end
is a false premise based on outdated management paradigms and will lead
to the long term demise of wild steelhead. The issues raised by the
tribes concerning allocation have been solved in SW Washington where
wild steelhead release has long been practiced.
- There is only one
river system in the state with tribal and sport fisheries that is meeting
its escapement goals; the Quillayute. If the Hoh and Queets cannot
make escapement, something needs to be done. Tribal harvest is much
greater than sport harvest, but we need to do what we can. Another
issue is the overharvest of the Clearwater. With so few rivers open
to harvest those open have intense harvest.
- The factual data
presented to you is the white paper from the Wild Steelhead Coalition.
To continue killing wild steelhead in the face of this information cannot
be justified by what opponents of the moratorium are calling WDFW’s
“good science.”
- Read the legislative
mandate again (RCW
77.04.012) Use your judgment. In the 1950’s there were 125 rivers
providing 60-90,000 wild steelhead a year. By 2001-02 the number was
6786, by 2002-03 3554. That is not preserving, protecting and perpetuating.
- MSH forces managers
to focus solely on fishing and harvest.
- The affected rivers
do not have healthy runs only “relatively” healthy runs. Escapement
goals are too low and wild fish are hurt by hatchery programs. Catch
and release is not enough – rivers should be closed altogether and catch
and release rivers should be limited to baitless, unbarbed hooks.
- Catch and kill
fisheries open the door to those who bend the rules. Zero retention
is easy to patrol. Killing wild steelhead is a thing of the past.
- The moratorium
is in direct accordance with National Park Service Fisheries Management
Policies, designed to 1) protect and perpetuate native aquatic species
and natural habitats 2) focus on preserving or restoring natural behavior,
genetic viability and ecological integrity of native fish populations
and 3) provide quality and diverse recreational fishing opportunities
only when ecosystem impacts are minimal.
- The reasons for
the decline are as follows” Hatcheries: Chamber’s Creek stock. There
is no hope of restoration of this early component while this brood stock
is used in hatcheries. The hatchery fish are still spawning in the
wild. MSY resulted in only a pathetic handful of runs that will support
harvest. In streams now closed, the stocks have deteriorated until
there are not enough left for recovery. Habitat losses are severe and
the warming climate intensifies the magnitude of runoff from melted
snow, resulting in shallower, wider, higher velocity streams with few
meanders, etc. Tribal and non-tribal fishing equipment has progressed,
so any place steelhead travel can be easily fished. Anglers come from
other states and provinces. The March-April fish are under terrible
pressure.
- Hatchery fish compose
97.7% of the harvest, so the moratorium is only a perceived loss of
opportunity.
- I would support
the Commission’s decision to establish a trophy wild steelhead retention
of only 1 fish per calendar year if and only if the tag/permit was issued
for $1000 and the proceeds went to stream restoration work or land purchase.
- The moratorium
is essential. Look at the success of the coho management in Neah Bay
to see how much positive impact can come from increased healthy runs
of wild fish. Increased runs=increased opportunity=more jobs=increased
income. Forks is really more interested in preserving the opportunities
for locals to kill fish than it is in preserving or improving its local
economy.
- I do not believe
that anything in Washington state’s constitution, statutes or regulations
requires the Commission to manage wildlife resources to maximize a particular
local community’s economic opportunities
- Most fishers enjoy
1) fishing for steelhead, 2) catching steelhead and 3) harvesting steelhead,
in that order. Having wild fish to catch satisfies #2.
- The importance
of genetic diversity in wild populations cannot be understated. Wild
harvest regulations selectively eliminate specific segments of a population,
altering the evolutionary future of populations. Other factors demanding
wild steelhead release are: repeat spawners, favorable hook and release
mortality studies, region wild release management tools in BC Idaho
and Oregon, increasing recreational opportunity and favorable economic
benefits statewide.
- Allocation with
the tribes is a function of WDFW and tribal rule making. These rules
can be changed and should not affect your decision as to the biological
base for implementing the moratorium.
- Arguments claiming
that banning retention of wild steelhead fails to maximize the utilization
of the resource RCW
77.04.012, upon much of which the legal control arguments rest,
is incorrect. In which scenario is the resource best utilized - one
providing for the catch and release of a fish, which can potentially
be caught again and will give rise to genetically diverse offspring
that will be best adapted to their ever changing environment or eliminating
the fish from the resource the first time it is caught?
- Retention models
are based on macro information and do not allow the level of detail
necessary to adapt to reality in real-time, nor to the resource on a
micro level. By the time we are in a position to adapt our rules, the
damage has been done
- Most of those
complaining about the moratorium are more concerned about the money
in their pocket now than about having healthy wild steelhead runs for
the next generations.
- If the fishery
were more substantial and fish-friendly in Forks, our guide service
would book more trips over there. It is time this state gets a grip
on life and realizes that the money the economy could gain from the
fly-fishing industry is substantial.
- In Oregon, there
is currently a moratorium on wild steelhead retention, due primarily
to the listing of nearly all the runs as threatened or endangered under
ESA. While initially unpopular, the situation has become accepted,
and has shown some success. The John Day run (a totally wild run) has
recovered to the point that there may be some wild harvest allowed in
the near future.
- There are no “excess”
wild fish- there are too many environmental hazards. No-kill rules on
interior and Puget Sound rivers were put on too late. The concept that
wild fish are expendable and that we can go back to a hatchery-based
production is an arcane, Machiavellian stroll into a past policy that
has not worked.
- Catch and release
with single barbless hooks and artificials only retains angling opportunity
with the least impact on the fish. The community benefits economically
from angler days. Everything points to the lowest mortality with this
type of gear. Data from the internet: hooking mortality for bait 31.4%,
lures 4.9%, flies 3.8%, barbless hooks 2.6%, barbed hooks 4.8%. A closure
takes the angler out of the equation and leads to disinterest. Steelhead
are essentially invisible to the public and anglers are their representatives.
- A March 2004 PSMFC
meeting included a presentation on Washington steelhead runs, showing
that 4 moved from healthy to depressed, six remained depressed, five
remained healthy and one went from critical to depressed. We need to
work toward resolving the depressed returns before it becomes a crisis
situation.
- Here are the top
10 reasons to support the moratorium: 1) The moratorium sets in place
the opportunity to create a proactive management system instead of a
reactive system. 2) The escapement goals on most if not all rivers
in Washington are set too low. 3) The majority of steelhead fishermen
want wild steelhead release. 4) The system WDFW has employed to manage
fish stocks has proven to be less than adequate, as may be seen in the
many closures due to low returns. 5) It’s odd that the only 12 rivers
in the lower 48 states where people can harvest wild steelhead. Something
is amiss. 6). B.C. does bit allow the retention of wild steelhead.
7) The Wild Steelhead Coalition has presented data showing wild fish
are in a decline. 8) Hook and release fisheries can be self-sustaining,
allowing for reduction of the hatchery program and more money for habitat
restoration. 9) Wild steelhead numbers are declining while the numbers
of fishermen are increasing. 10) It is the right thing to do.
Major
points of those opposing the retention of the moratorium
- The Commission
needs to base resource management on meeting wild steelhead escapement
goals. Rivers meeting the goals should permit wild steelhead retention.
The Commission sets rules based on science and studies conducted by
state and tribal biologists. The Commission should not support a moratorium
based on special interest group’s agenda items.
- Your work has
kept the returns of wild steelhead at levels above what is necessary
for maintaining viable runs. The opportunity to keep or to catch and
release a wild steelhead will disappear in Washington waters if the
moratorium is maintained. Some alternatives are reduction of the yearly
limit of 5, early closures, gear restrictions, including reductions
to boat access and an effort to encourage the release of wild steelhead
by sport, subsistence, and commercial fishers. Another alternative
would be the establishment of a limited license draw system where angler
applicants could pay for up to 5 wild steelhead tags, with a maximum
number of tags set for each river. Fees generated could be used for
steelhead recovery programs.
- Reasons to rescind
the moratorium: 1)Technical staffs of WDFW and Tribes have jointly expressed
their opposition based on fishery management science not supporting
any need for such action. 2) Moratorium is in conflict with current
Mission Goals for WDFW and the Administrative Procedures Act. 3) Members
of Washington’s Legislature informed the Commission that the process
being used is in violation of the law. 4) The Northwest Indian Fisheries
Commission, speaking in behalf of the Boldt Case Tribes, informed the
Commission that the process used of the Moratorium and its review violates
the co-management requirement called for in the Federal Court action
on U.S. vs. Washington.
- Reasons to oppose
the moratorium: 1) Escapement has been met or exceeded in the Quillayute
system for the last 25 years. 2) WDFW fish biologists did not recommend
it. 3) The Tribes and their biologists did not recommend it. 4) The
Tribes were not consulted before the Commission took this action. 5)
The Tribes will continue their gill net fishery through the moratorium
and negate its effect. 6) Sufficient regulations are already in place.
7) Special interest groups should not manage the steelhead fishery.
It should be managed by science. 8) Economic impacts to Forks were not
taken into consideration nor was the City of Forks allowed input into
this decision. 9) There is a tradition in Forks of harvesting your own
fish – a form of recreation for the senior citizens. 10) Scientific
data shows the average run size will not increase from the moratorium.
11) Harvest rates for all fisheries are only 40% a very safe level.
If the moratorium stands I will continue my lawsuit against the Commission.
- The wild steelhead
resource should be available to all citizens not just the elite I-5
corridor condo dwellers. If escapement goals cannot be met, close the
stream and allow it to rebuild with no C&R for the rich.
- Reasons not to
extend the moratorium: I oppose extending the moratorium and my reasons
follow: 1) wild steelhead C&R is not the only tool we can use.
It should not be used as a broad-brush gesture to appease vocal special
interest groups. 2) Recreational fishers are saddled with the brunt
of WDFW’s actions to manage declining runs, when there are many other
causes. 3) The Quillayute system’s runs are increasing. 4) Refer to
WDFW’s survey In 2001 where 72% on Washington’s fishermen wanted to
take a wild steelhead home.
- Some clients who
are members of the Wild Steelhead Coalition were excited about the moratorium,
but when I told them the King run is in way worse shape than steelhead
they have no problem killing them to take home. People supporting the
moratorium are not interested in total fish release, just the fish that
interest them. And most of them are fly fishermen. I think the rule
would only benefit a small portion of special interest groups.
- The moratorium
is inequitable and insupportable and should be repealed. The determination
should be made on a river-by-river basis and the Commission should have
a standing policy with the following concepts: “The Commission supports
any measures necessary for the restoration of harvestable numbers of
salmon, trout and steelhead in specific rivers provided it can be legally
demonstrated that conservation measures are needed and there is agreement
by all management authorities to enforce the measure.”
- Going from two
fish a day to zero is ridiculous. You should consider 2 wild fish per
season and voluntary catch and release. If you continue this course
of no opportunity we will no longer fish the Olympic Peninsula and save
out money for a yearly trip to Canada or Alaska.
- A 2-year moratorium
proves nothing. It doesn’t even include a cycle of returning fish.
The benefits of a restricted fishery in BC have been minimal. The Thompson
River has been catch and release since 1985 and is dominated by a fly
fishing fraternity and the runs have declined to a point where they
plan to prevent fishing of any kind.
- When runs continue
to meet escapement goals, limited harvest of wild fish is essential.
Emergency closures, when necessary, provide necessary protection. When
such closures are implemented, all fishing should be closed, including
catch and release.
- I plan on fishing
in southern Oregon where ODFW has opened 6 new streams to wild steelhead
retention. Why do Washington and Oregon diverge so greatly on the issue
of wild steelhead retention? If you were really serious about the health
of native steelhead stocks, you would have placed a moratorium on all
fishing for wild steelhead, not just retention. Fish die in catch and
release fisheries. Hooking mortality in Peninsula streams is about 25%.
Fish are played too long on light tackle, then held up for a picture,
then the fly is removed, all increasing the mortality. By enacting
the moratorium you are increasing this scenario many fold and increasing
hooking mortality rates. It also encourages poaching. Poachers know
there is little chance of being caught because of lack of enforcement.
The only way to truly enforce escapement is to close all fishing.
- We are dependent
on winter steelhead fishermen for economic stability and as consumers
we depend on the catch of fish for our heart healthy diet and on their
eggs to catch more.
- I would like to
see continued attention paid to the environment this species thrives
in.
- Concerns of the
Quileute Tribe: 1) Without a conservation need, it is possible returning
fish could exceed the carrying capacity for rivers and adversely impact
survival per spawner. 2) A mechanism to evaluate the first point exists
pursuant to Hoh v. Baldridge for Pacific rivers – they must be
managed on a river-by-river and run-by-run basis. Yet, the tribes were
not included in any discussion or consultation regarding the moratorium.
Omission of such consultation violates U.S. v. Washington. 3)
Because we have no information that steelhead in the Quillayute watershed
need to be in conservation status, we have not closed the tribal fishery.
That situation has the potential to create racial tension towards tribes.
4) WDFW staff did not find a need for the moratorium – what, then, was
the motive? 5) We are concerned that the lawful administrative process
was not followed when the moratorium was enacted; instead, it came by
fiat of the Commission. For the upper reaches of the tributaries of
the Quillayute River, both retention and catch and release management
policies should be addressed. Reduction of fishing pressure might improve
survival. Therefore we suggest closing fishing in the upper reaches
of the following rivers from February 28 through May 31:Dickey, Sol
Duc, Calawah River and Bogachiel. These changes will maintain and increase
the number of wild steelhead in the Quillayute River System and promote
sustainable harvest fishing opportunities into the future.
- I see no justification
for Washington to sponsor Torture and Abuse (C&R) under any circumstances.
That decision should be made by the individual fisherman.
- On the Hoh, the
average returns over the last 5 years have been about 198% of the escapement
goal. On the Queets the average returns over the last 5 years have been
about 140% of the escapement goal. On the Quillayute, returns have averaged
305% of the goal. In the Green/Duwamish river system the hatchery production
of summer steelhead has introduced a small wild population where no
native summer stock had existed. The juveniles compete for food and
habitat with the native winter steelhead. It would be in the best interests
of the native stock to allow harvest of these fish. No one knows for
sure the cause(s) of the recent decline of many of our steelhead stocks,
but sport harvest is seldom, if ever, among the causes. During the
years when the Quillayute was averaging three times its escapement goal,
the numbers on many catch and release rivers that empty into the Strait
of Georgia have plummeted, even though they are protected.
- Northwest Indian
Fisheries Commission (NWIFC) stresses the need to recommit to regular
discussions between the tribes and the Fish and Wildlife Commission
(FWC) and also point out the functional relationship between the tribes
and the State of Washington is not simply one of agreeing to cooperate,
but a legal co-management relationship established by court orders,
requiring consultation and agreement on all significant fishery
management decisions. If the FWC continues to make specific fishery
management decisions for steelhead, rather than delegate that authority
to the director as you have done for salmon, we will have to continue
to meet directly with you and work out procedures for making co-management
decisions. NWIFC member tribes oppose the moratorium and request that
you immediately repeal it. This decision should be made on a river-by-river
basis with joint management between WDFW and the effected tribes. Statewide
wild steelhead release raises a number of complicated legal and policy
questions concerning opportunity, allocation and conservation. Hoh River
steelhead is a specific example. If the FWC does not repeal the ban,
negotiations on Hoh steelhead will have to be reinitiated and litigation
may be resumed.
- Hoh Tribe says
the Commission should have knowledge of a pending lawsuit filed by the
state against the Hoh Tribe and its proposed steelhead fisheries beginning
in the 2002-03 season and the unresolved issues underlying that suit.
As a result, the Tribe has to consider the Commission’s actions to be
made as a gesture of disrespect toward WDFW, the Hoh Tribe, and existing
federal court orders that recognize the tribes as co-managers.
- City of Forks says
they suspect that some Commissioners may try to look at this issue as
a “numbers game” – so many for or against the moratorium. Think about
what has occurred since February - a remarkable agreement opposing the
moratorium has arisen amongst a truly diverse group of interests that
include the City of Forks, Quileute Tribe, NWIFC, Steelhead Trout Club
of Washington, Puget Sound Anglers, the King County Outdoor Sports Council’s
steelhead committee, and numerous Legislators.
Amendments
to proposed rules
- Suggest a one fish
wild steelhead limit per license year on some rivers. Regulate the
keeping of wild steelhead with spaghetti tags. The tag to keep one
wild steelhead should cost $10. No replacement tags should be issued.
No retention of wild steelhead on Puget Sound rivers unless a river
has met its wild steelhead escapement goal for three consecutive years.
- One fish limit
with two in possession.
- Would support any
number between 5 and 7. Would propose that wild steelhead retention
is allowed on the Skokomish, Hamma Hamma and Duckabush rivers. Allowing
wild steelhead retention will provide more fishing opportunities there
and would not result in a negative impact on the wild steelhead runs.
On the Skokomish there is no clear distinction between wild and hatchery
steelhead. Should not use the term “wild steelhead”, but marked and
unmarked instead. Should consider the total run when setting regulations
for this river.
- Chehalis River
– mouth to Porter Bridge – restore the rule allowing wild steelhead
retention December 1 – April 31, one wild fish per day.
- Lessening the catch
limit would be close to as effective as a total ban, even if it is only
for two years. Maybe lessening the daily limit to one or two per day
per licensed angler would be beneficial to meeting your goal while making
a multitude of anglers consistently anxious to fish in WA.
- Suggest adding
language to the proposal that limits anglers to “5 wild steelhead per
year, 1 wild steelhead per calendar month.”
- Propose a daily
limit of 1 and a yearly limit of 10, not more than 3 from any one river.
Propose opening the Sol Duc and Bogachiel to the Park boundary for wild
fish retention and the Calawah to the South Fork
- Green/Duwamish
season should run to December 15 instead of Nov 30.
- Any moratorium
should be delayed until the catch and release matter has been given
thorough airing and consideration.
- Here are some Amendments
for discussion: 1) Bogachiel, Calawah, Clearwater, Dickey, Goodman,
Hoh, Hoko, Pysht, Quillayute, and Soleduck – wild steelhead retention
allowed Thursday, Friday, Saturday and Sunday, one a day, four a year.
2) Same rivers, but release all wild fish over 23# to be determined
by the Commission for example all make fish over 36” and all female
fish over 34” must be released. 3) Close the above rivers Monday-Friday
the last week of March including the tribes. 4) Same rivers, wild steelhead
retention allowed; 1 wild fish a day, 4 per year. 5) January 2006 review
wild fish harvest on punch cards and tribes catch of wild fish to determine
how plentiful the wild fish runs are. 6) If catch and release on the
rivers above is retained, propose to the Commission to triple the hatchery
production to produce more fish in December and January. Green River
could use an increase in hatchery plants. 7) Green River - restore rules
and regulations allowing wild steelhead retention except change to one
wild steelhead a day and annual limit of 4 wild steelhead.
- The rules should
be changed to allow a sport fisherman to retain 10 wild steelhead per
license year with no more than 2 from any one river and no more than
one per day.
- My proposal is
2 wild steelhead and catch and release in the month of April.
Other
Ideas, issues
- Should increase
winter hatchery production on the Cowlitz River – what is going on at
Blue Creek hatchery? Plant more summer steelhead in the SF Toutle.
The Skykomish River should be open above Reiter Ponds all summer.
- Change the regulation
on no bait on Snoqualmie River. Single hook, barbless is fine, but
I like to fish bait. Fly fishermen don’t own the river, bait fishermen
pay for the fishery like anyone else.
- Get local groups
like Puget Sound Anglers and tribal hatcheries to plant smolts in rivers
and creeks. Planting trees and other vegetation to keep waters cool
are great, but more is needed.
- De-commercialize
steelhead fishing by phasing out guide licenses. You allow a business
directed to catching steelhead for profit – sportfishing? Politically
the state hasn’t shown the will to attempt to control Indian fishing.
In common means same regulations – netting rivers, etc.
- If there is a harvestable
number of wild steelhead, there should be a catch limit of five per
year per fisher. See no evidence that not retaining wild steelhead
has helped fish numbers in the Chehalis system. Broodstock program
on the Satsop was cancelled two years ago because they could not meet
their quota, but tribal net fishery continued to net. If there are
enough fish for a gill net season, sport fishermen should certainly
have the opportunity to keep a wild fish for dinner anywhere in the
state.
- Steelhead are better
protected by timely closures of commercial fisheries that are taking
so many “incidental” steelhead as to cause serious doubt as to what
fish are truly targeted.
- Have you considered
the damage done to a tired spawning steelhead to tire them to exhaustion
on a fly rod, then release them? What percentage of these catch-and-release
fish die?
- Have always seen
many spawning coho on Newman Creek, Vance Creek, Dry Bed Creek, and
many unnamed tributaries. This past season I only saw 4 salmon. You
have a shortage of coho and it will show up on catches a couple of years
from now. Might consider some restrictions.
- I do not understand
the difference where ocean caught undersize/unclipped salmon cannot
be removed from the water prior to being released. Under the moratorium
large wild steelhead seem to be removed from the water for photos
- I am disappointed
with the decision to “not remove the fish to be released from the water
- I applaud your
early closing of the Skykomish last winter to protect native runs.
- While nets kill
these fish, my throwing back a few fish will not make a difference.
Neither will the moratorium. So, with all due respect, why do you and
I even bother? Forget the moratorium, and open all the rivers to steelhead
catch and keep. Then between the sports catch of maybe 10% and the
Indians kill of 90% all wild runs will be gone and we can forget the
whole issue.
- On the Green/Duwamish
a schedule allowing nets only the first week of each month would let
more fish clear the area and allow a greater chance for sport anglers
to selectively harvest hatchery fish.
- The best way to
take care of a river with diminishing returns is to close the upper
reaches (spawning areas) after February 28 and give the fish a chance
to spawn without Flyfishers beating the water to a froth and trampling
over fresh redds. Get rid of the moratorium, go back to 10 wild fish
a year, gather data and make informed decisions.
- I ask four things
of the Commission:
- Return the
rivers of the Olympic Peninsula to Wild Steelhead Retention.
- Return the
Big River to the same standards as 2003-2004; with wild steelhead
retention allow keep of game fish and remove the selective gear
rules.
- Don’t impose
closures without knowing the conditions present. Don’t assume something
is wrong and therefore feel the need to act.
- Provide bang
for my buck and get back to the business of taking care of the Big
River and adjacent Ozette; be an active governmental caretaker of
our fish and wildlife resources. If funding is a problem with providing
just a seasonal staff to collect the data (continue the indexing
of Boe Creek for example), I call upon my legislature to remedy
this.
- My suggestion is
a quota system with immediate reporting to monitor escapement of wild
fish. Daily reporting is possible with email and the communications
systems available today. Punch cards and fish checkers would provide
a system of checks and balances so that the reports can’t be manipulated.
Wild fish could be retained until a quota was reached. When this happens,
the nets should also be removed. This would encourage guide boats to
release more wild fish to extend the quota into the season.
- If a river is
open to netting it should also be open to sport fishing. In fact it
should be open to hook and line fishing for everyone including sport
fishermen and tribes well before it is open to netting as the netting
that occurs with gill nets does not allow for proper release of endangered
or protected species.
- If you took every
steelhead fisherman who fished last year and multiplied by 5 (the annual
limit) the sport harvest would not be even close to what the Native
Americans netted off the Hoh River last year. The moratorium should
be rescinded. The daily limit should be 2 wild steelhead per day and
the annual limit should be raised until the sportsman gets 50%.
- The 5-10% mortality
associated with release is well known What is not well known is the
stress related effect of catch and release fisheries on reproductive
fitness. Animals have a 2-part response to stress – an adrenaline rush
and the cortisol response. The adrenaline response has an immediate
effect, the cortisol response is slower, and is the one that effects
reproductive success. In some studies of stressed fish the fish ovulated
earlier, fecundity and egg size were different, egg survival was lower,
etc. The effects are worse at higher temperatures. Novice anglers
injured more fish in the studies, but they landed fish faster, which
is better for the fish’s blood chemistry. (literature cited attached)
- I suggest the following
course of action: 1) Count the fish. We must have better science and
data on this issue. 2) Put a quota on guides. 3) Restrict the method
of harvest. 4) Restrict the use of power boats to the Quillayute only.
Reason
for adopting the rule, response to comments on proposed rule
The Fish and Wildlife Commission acknowledges that there are powerful
arguments and strong feelings on both sides of this issue. A strong conservation
ethic was expressed by both sides, as was the need for more information
about the health of wild steelhead stocks around the state. The Commission
also understands the importance of the cultural value placed on these
fish. In recognition of all these factors, the Commission has decided
on a compromise where some wild steelhead harvest is allowed, but the
amount of harvest is further limited by decreasing the annual limit from
five fish to one fish. The Commission also reiterated their assignment
to Department staff to produce a scientific assessment of wild steelhead
stocks and a fishery management plan for wild steelhead.
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