|Reference ID: DFW263555|
|Critical Conservation Need Submission Type: Public|
|Species covered in proposed rule|
|Rule to Change:|
|New Rule Proposal:|
TCA asks the Commission to simplify and harmonize angling regulations rules as follows:
• Wild Steelhead, searun cutthroat and bull trout catch and release only state-wide, year round; no exceptions. In the alternative, for those rivers where the Commission determines to permit the harvest of wild steelhead, require anglers to pre-purchase, river specific wild steelhead harvest tags. The number of tags sold for each river shall not exceed the sports allocation in the state-co manager fishing plan for each river. Require anglers who wish to kill wild steelhead must purchase the tags in advance of harvesting a steelhead from a particular water (similar to purchasing an area specific deer tag prior to hunting deer);
• Selective fisheries regulations coupled with no fishing out of boats regulations (i.e. boats may be used for transportation only) first Saturday in June – April 30: Sauk River; Hoko River; Hoh River Hwy 101-ONP boundary; Bogachiel River; Humptulips River upstream of Hwy 101; Elwha River (when open); Skykomish River upstream of Sultan River; Kalama River upstream of lower salmon hatchery;
• Open anadromous reaches of all rivers December 1 – January 31 without gear restrictions to facilitate harvest of hatchery steelhead; open all anadromous reaches February 1-April 30 with selective fisheries regulations except in those systems where ESA listed steelhead may be present. In those rivers, open anadromous reaches February 1-April 30, catch and release, fly fishing, unweighted flies only, daily two fish CnR limit (i.e. once an angler has brought two steelhead to hand, he must stop fishing);
• Selective fisheries on all anadromous reaches first Saturday June-November 30 (to protect juvenile steelhead);
• Direct the WDFW to recommend guide management policies to include issuance of area specific guide licenses, reporting requirements (number of angler days, species harvested, number of wild steelhead harvested by guided anglers, etc.) to be considered by the Commission in the next major regulation cycle.
|Why the change is needed:|
Current steelhead regulations vary widely across the state in those fisheries with ESA listed stocks. The regulations are overly complex and in many instances are internally inconsistent. Many/most major Columbia/Snake river tributaries, from the ocean to Idaho, are open for fishing, including steelhead fishing, when ESA listed (endangered) steelhead and Chinook are present in the fisheries. Many of these fisheries are open year round without restrictions to gear or method and include bait fisheries while the remainder are typically open through the end of March which overlaps with the spawn timing of endangered steelhead. Contrast these regulations with those in the Puget Sound DPS where virtually all the rivers are closed to all angling from either January 1 or February 16 even though the steelhead populations in question are listed as threatened rather than endangered. Why are Puget Sound rivers closed while Columbia/Snake and tributaries remain open to angling even though the latter fisheries include endangered stocks?
In the absence of any real steelhead recovery plans, WDFW has managed wild Puget Sound steelhead almost exclusively by simply closing the rivers to angling January 1 or February 15. These policies have many negative consequences without much in the way of benefits to wild stocks:
• These closures dramatically reduce angling opportunity while simultaneously concentrating angling pressure (and mortality) on the relatively few systems (Olympic Peninsula) that remain open in February – April 15 for wild steelhead harvest;
• These regulations leave scores of rivers bereft of anglers for six months or more a year. The regulations have done nothing to recover wild steelhead populations;
• Rivers without anglers are rivers without defenders. Nobody cares more about rivers and their fish than anglers. Anglers without rivers soon turn to other pursuits permanently robbing our precious resources of defenders and sources of financial support.
• Rivers without anglers are open only to poachers.
For these reasons alone, closures, especially of non-harvest fisheries, are a bad idea. Consider the Suiattle River which has been closed to winter steelhead angling since 1976. How many times has that wild river been patrolled during the winter season during the past thirty five years? Probably never. During this period, the only people who have fished the Suiattle are the many local poachers. They fish in solitude while law-abiding anglers are deprived of a near-wilderness fishery two hours from Seattle.
The closure of Puget Sound rivers was unnecessary, unwise, did nothing to recover listed steelhead stocks and deprived non-treaty anglers the opportunity to fish for healthy stocks of searun cutthroat and bull trout as well as hatchery steelhead. Further, the management policies adopted for non-treaty anglers in Puget Sound rivers are inconsistent with the management/fishing plans of various Puget Sound treaty tribes. Tribal fishing plans provide for fisheries that kill up to 4% of the predicted wild steelhead run. Applying the same incidental kill standard to sports fisheries, WDFW could easily provide greatly expanded recreational fisheries under various gear/method restrictions while limiting unintended mortality to less than 4%.
TCA urges the Commission to be more proactive in adopting regimes which restore angling opportunity but limit mortality through the adoption of various gear/method restrictions. Such approaches provide mechanisms to preserve angling opportunity and reduce angler-induced mortality. Similar concepts have long been utilized in the hunting community – less efficient methods allow for more people to hunt for longer period. For example, bow hunters are allocated much longer seasons, including big game rut periods, than other methods which are much more “efficient” in harvesting game.
The Commission has an extensive menu of gear/method restrictions from which to choose:
• Ban the use of bait. Bait is many times more effective and lethal than other lures for steelhead. Relative effectiveness/mortality:
1. Flies: relative encounter rate -- 1; per encounter mortality 1.5%
2. Artificial lures: relative encounter rate -- 4 (i.e. catch per unit effort is four times that of a fly), per encounter mortality 4%;
3. Bait: relative encounter rate -- 10.8 (i.e. catch per unit effort is 2.7 times that of artificial lures and almost eleven times more than fly fishing), per encounter mortality 10%. Additionally, we know that preservatives used to cure salmon eggs are lethal to juvenile salmon, cutthroat and steelhead.
• No fishing from boats. Regulations prohibiting fishing from a boat immediately provide extensive in-river sanctuaries and greatly reduce the encounter rates. As an added benefit, such restrictions would increase in civilized behavior by requiring boat anglers to disembark and mingle with the bank anglers instead of simply fishing through the run without regard to the shore anglers.
• Catch-and-release. The mortality associated with catch and release steelhead angling is low as noted above: flies -- 1.5%; artificial lures – 4%; bait – 10%.
• Fly fishing only. For steelhead, fly fishing is by far the least efficient method and therefore provides the greatest angling opportunity while causing the lowest impact on wild stocks. NOTE Using the relative effectiveness for different methods noted above: a single bait fisher has the same mortality impact on the steelhead population (catch per unit effort times the per encounter mortality) as 86 fly fishers or 6 anglers using artificial lures. The efficiency of fly fishing can be further reduced by requiring the use of floating fly lines, banning weighted flies and so on.
• Establishing limited entry or draw/lottery fisheries such as practiced for Atlantic salmon and, increasingly, by BC steelhead managers. If kill fisheries are authorized, the department might sell limited numbers of river specific tags.
• Limiting the number of guides licensed on particular waters and/or restrict the number of wild steelhead which may be harvested by anglers guided by each guide.
In other words, gear and method restrictions offer many options for insuring continued angling opportunity while limiting non-harvest mortality. These tools are not some sort of class warfare, but are a suite of management options to preserve opportunity while limiting lethal impacts.
If the Columbia/Snake rivers and tributaries can remain open to fishing when endangered species are present with little or no restrictions, surely the Puget Sound rivers should be open under restrictions on gear/method.
|Names of individuals or groups with whom you have discussed this change:|
Wild Steelhead Coalition
Wild Fish Conservancy
Federation of Fly Fishers, Steelhead Committee
|Describe their support and/or concerns:
|Submitted by: SOVEREL, PETER W — EDMONDS, WA|
Date submitted: 06/07/2012
Reference ID: DFW263555
There are elements of this proposal that may require legislation. Some of the statements are incorrect. Steelhead and Chinook in the Snake River basin are not endangered, but they are listed as threatened. DFW could not tell if all the proposed changes were only for west side streams that were named or whether some of the recommendations were to be adopted across that state. In southeast Washington, DFW does not wish to have bait removed as an option for fishing. This area already has a barbless hook requirement for steelhead and Chinook fishing, but the rule allows bait and multiple gear types to remove hatchery fish so they are not available to spawn naturally. This proposal needs to be clearly defined as to where the proposed changes would occur, and then it can be considered further. DFW has strong evidence that the hooking mortality with barbless hooks and multiple fishing gear produces less than 3% incidental mortality for steelhead, and we use 5% in our planning efforts to be overly conservative to protect native fish.
TAHCELL, JONATHAN T October 08, 2012
GIG HARBOR, WA
I would like to see all cutthroat trout, bull trout/dolly varden and especially wild steelhead be managed as catch and release state wide. This is crucial to maintain the resource or improve it.
HOPPLER, WES C January 29, 2013
Do not adopt these proposals. There is so much wrong here.
Rule simplification generally means loss of opportunity, as things are then managed to the lowest common denominator. I appreciate the departments efforts to carve out opportunity where they can amid various protection measures. Of course the simplest rule is closed - not an enhancement from my perspective.
I do not wish to see limited entry at this point - Winter steelheading weather variability would really be a problem with river specific entry. As it is, you often fish where you can as opposed to where you originally intended.
Generally do not favor gear/method restrictions, believe fisheries should be as inclusive as possible,the angling community is split enough already.
Do not favor "boats for transportation only" - fishing from boats is a very popular fishing method and i do not wish to see it limited - crawling in and out of my boat all day is not an enhancement, I'm getting old.