| Reference ID: DFW725075 | | Critical Conservation Need Submission Type: Public | Rules Category: Statewide | Species covered in proposed rule • Steelhead
| Rule to Change: None | New Rule Proposal: Selective Gear Rules ONLY:
Westside Rivers - Trout and Steelhead - February 1 to April 30.
Eastside Rivers - Trout and Steelhead – Year Round
| Why the change is needed: Catch and release mortality can vary widely depending the gear type used. Hooten (2001) found that hooking mortality was consistently at least 3 to 9 times higher when using bait verses using artificial lure or fly. Bruesewitz (1995) found that the highest percentage (17. 8%) of critical area hookings (tongue, esophagus, gills, and eyes) occurred when using bait and treble hooks in winter steelhead fisheries. Because steelhead and stream-resident rainbow trout are the same species, inter-spawn, and both can produce anadromous forms, it is important to consider wild rainbow trout conservation when managing for wild steelhead sustainability and recovery. Many studies have shown significantly higher mortality in trout when angling with bait verses artificial lures/flies (Taylor and White 1992; Schill and Scarpella 1995; Mongillo 1984; Wydoski 1977; Schisler and Bergersen 1996). Taylor and White (1992) showed an average mortality of trout to be 6-8 times greater when using bait verses using lures or flies, respectively. Selective gear rules are necessary to minimize the mortality impacts on wild steelhead populations (including many ESA listed stocks). | Names of individuals or groups with whom you have discussed this change: The Wild Fish Conservancy - Trent Donohue and Nick Gayeski
Native Fish Society - Mike Moody
Bill McMillan, Biologist and Outdoor writer
John McMillan, Fish Research Scientist
Wild Salmon Center - Devona Ensmenger
Conservation Angler - Pete Soverel
Will Atlas, Steelhead Conservation Committee – Federation of Fly Fishers
Doug Schaad, Conservation Committee - Washington Fly Fishing Club
Dave Steinbaugh, Waters West
Dave McCoy, Emerald Water Anglers
Bill Robinson, Fish Advocate and Chair of the WDFW SCPAG
Mike Gross, WDFW Fishery Biologist
| Describe their support and/or concerns:
Discussed in Detail with Mike Gross of the WDFW. This Rule proposal is supported by all others listed. | | Submitted by: LUKE KELLY (CONTACT), WILD STEELHEAD COALITION — KIRKLAND, WA Date submitted: 06/14/2012 |
Reference ID: DFW725075 Disagree with the intent of year-round restrictions in eastern Washingotn, but only seasonal restrictions in western Washington, with no justification for the differences. We have some very strong evidence from ODFW regarding hook and line collection of steelhead in the Grande Ronde River by volunteers during the fall season over a period of years and then holding those fish for many months in a hatchery. The mortality from hook and release was very low.
SENYOHL, AL January 28, 2013 KIRKLAND, WA Comments: The WDFW has previously not recomended this rule proposal for consideration. The Steelhead Trout of WA dose not recomend this proposal. It would appear that the conservation agenda is being used to support or inhance only 1 type of fishing method when there are many options & gear types that all should be considered before making any rule changes. There is no justification for the seasonal restrictions in Western WA as noted by the WDFW.
Al Senyohl Pres, Steelhead Trout Club of WA TRIGGS, BOB January 27, 2013 PORT TOWNSEND, WA Comments: I support the selective gear rules with one caveat: I feel that we should not be using bait or barbed hooks, nor more than one hook on ANY of our fisheries at this point. We are trying to protect wild fish, and to recover them. This will not happen unless you get serious about minimizing impacts across the entire spectrum of fishing seasons. At one time we had wild fish spawning from fall to spring. Limiting selective gear rules to seasonal periods will only further allow avoidable injury to wild fish that may have the potential to reestablish earlier runs of fish. Selective gear rules should be in place statewide,year-round. SMITH, IRA A January 27, 2013 SEATTLE, WA Comments: I am unfamiliar with the ODFW study cited, and would like the dept to publicly examine the study with an emphasis on looking at the nature of the gear cited. On the other hand, the literature is full of studies pointing to the exact opposite conclusion; e.g.Taylor and White 1992; Schill and Scarpella 1995; Mongillo 1984; Wydoski 1977; Schisler and Bergersen 1996 all conclude that the mortality rate using bait is much higher than when using atrificial lures or flies. In fact a well known and often cited Hooten study in 2001 shows that mortality is 3 to 9 times higher with bait than with artificial lures or flies.
If the Department feels there is "no justification for the differences" between the proposed regulations on the west and east sides of the state, then the dept should ban bait statewide. MCMILLAN, BILL January 26, 2013 CONCRETE, WA Comments: What gear method was used and does this catch, handling, and “release” method really represent the diverse angling community and wild steelhead population(s) of that area? Is this “evidence” accepted as the best available science as directed by the WDFW’s Statewide Steelhead Management Plan? This proposal is to eliminate the use of bait and barbed hooks, neither of which the WDFW has mentioned from the Oregon work.
In Bob Hooton’s 2001 scientific study, he found hooking mortality was consistently at least 3 to 9 times higher when using bait verses using artificial lure or fly.
Steelhead and stream-resident rainbow trout are the same species, can inter-spawn, and both can contribute to future generations of wild steelhead. Many studies have shown significantly higher mortality in trout when angling with bait verses artificial lures/flies (Taylor and White 1992; Schill and Scarpella 1995; Mongillo 1984; Wydoski 1977; Schisler and Bergersen 1996).
It is clear from the best avail PAGE, DAN January 26, 2013 YELM, WA Comments: I support the Selective Gear Rule in any situation where wild fish release occurs. Bait and treble hook use must cause more mortality. EHLERT, CHUCK January 26, 2013 WOODINVILLE, WA Comments: Critical to remove any potential impacts that are critical to the management of a dwindling resource. Citing a single study and not equally including studies that have different results is short sided. Based on information presented above the risk seems to high to continue on our current path. Recommend including and approving ROHN, DOUGLAS A January 25, 2013 HONOLULU, HI Comments: I agree with the original proposal for the following:
WDFW should review the published literature on subject which shows a significant loss of fish that are caught and released. The Oregon information has not been reported on in any papers we are familiar with and we would like to see it available by gear and hook type. Note that both the Hooton (2001) and Bruesewitz (1995) studies we reported on found the largest mortality associated with bait (as high as 17.8%), followed by gear and the lowest was with fly caught fish. Our proposal was to eliminate the use of bait and barbed hooks, neither of which you have mentioned from the Oregon work. On the other hand, the recent WDFW study in Puget Sound found a 14% mortality rate (Ashbrook, 2010). Clearly the elimination of bait and barbed hooks will greatly reduce CnR mortality on wild fish. Note also that British Columbia has eliminated bait and barbed hooks on the Skeena system for the reasons detailed above. SUTTON, MARCEL January 25, 2013 SEATTLE, WA Comments: Please do impliment the proposed new rules: Selective Gear Rules ONLY: Westside Rivers - Trout and Steelhead - February 1 to April 30. Eastside Rivers - Trout and Steelhead – Year Round
Thank you! BUDD, ROBERT M January 22, 2013 HOLLIDAYSBURG, PA Comments: There is no downside to using techniques that have been shown to be safer for catch and release of wildfish.Many other states have been convinced, (including barbless only hooks/flyfishing only in my home state of PA)so why not the state of Washington? I came to Washington for many years to fish the Skagit River in April for wild steelhead...but not anymore. Clearly, changes have to be made.Perhaps there may be issues with increased predation in the Ocean, but should we not be doing as much as we can with regards to rules and regs we can change? SLAUGHTER, JEFF January 22, 2013 HOLLAND, MI Comments: Please consider that there is a proven difference in angling methods and their impacts.
What gear method was used and does this catch, handling, and “release” method really represent the diverse angling community and wild steelhead population(s) of that area? Is this “evidence” accepted as the best available science as directed by the WDFW’s Statewide Steelhead Management Plan? This proposal is to eliminate the use of bait and barbed hooks, neither of which the WDFW has mentioned from the Oregon work.
In Bob Hooton’s 2001 scientific study, he found hooking mortality was consistently at least 3 to 9 times higher when using bait verses using artificial lure or fly. JOHNSON, DANIEL L January 22, 2013 NEWCASTLE, WA Comments: I agree with WSC proposal for reasons stated in their written justification as stated below.
Catch and release mortality can vary widely depending the gear type used. Hooten (2001) found that hooking mortality was consistently at least 3 to 9 times higher when using bait verses using artificial lure or fly. Bruesewitz (1995) found that the highest percentage (17. 8%) of critical area hookings (tongue, esophagus, gills, and eyes) occurred when using bait and treble hooks in winter steelhead fisheries. Because steelhead and stream-resident rainbow trout are the same species, inter-spawn, and both can produce anadromous forms, it is important to consider wild rainbow trout conservation when managing for wild steelhead sustainability and recovery. Many studies have shown significantly higher mortality in trout when angling with bait verses artificial lures/flies (Taylor and White 1992; Schill and Scarpella 1995; Mongillo 1984; Wydoski 1977; Schisler and Bergersen 1996). Taylor and CHADICK, JASON January 22, 2013 NEAH BAY, WA Comments: Dear WDFW,
This rule proposal increases angler opportunity on the westside and protects eastside wild trout. I do not see a single reason for not implementing this rule. Please reconsider.
Thanks,
Jason Chadick CORDONNIER, JUSTIN January 22, 2013 NEEDHAM, MA Comments: • What gear method was used and does this catch, handling, and “release” method really represent the diverse angling community and wild steelhead population(s) of that area? Is this “evidence” accepted as the best available science as directed by the WDFW’s Statewide Steelhead Management Plan? This proposal is to eliminate the use of bait and barbed hooks, neither of which the WDFW has mentioned from the Oregon work.
• In Bob Hooton’s 2001 scientific study, he found hooking mortality was consistently at least 3 to 9 times higher when using bait verses using artificial lure or fly.
• Steelhead and stream-resident rainbow trout are the same species, can inter-spawn, and both can contribute to future generations of wild steelhead. Many studies have shown significantly higher mortality in trout when angling with bait verses artificial lures/flies (Taylor and White 1992; Schill and Scarpella 1995; Mongillo 1984; Wydoski 1977; Schisler and Bergersen 1996).
• It is clear from the best BREHM, BERT January 22, 2013 EVERETT, WA Comments:
What gear method was used and does this catch, handling, and “release” method really represent the diverse angling community and wild steelhead population(s) of that area? Is this “evidence” accepted as the best available science as directed by the WDFW’s Statewide Steelhead Management Plan? This proposal is to eliminate the use of bait and barbed hooks, neither of which the WDFW has mentioned from the Oregon work.
In Bob Hooton’s 2001 scientific study, he found hooking mortality was consistently at least 3 to 9 times higher when using bait verses using artificial lure or fly.
Steelhead and stream-resident rainbow trout are the same species, can inter-spawn, and both can contribute to future generations of wild steelhead. Many studies have shown significantly higher mortality in trout when angling with bait verses artificial lures/flies (Taylor and White 1992; Schill and Scarpella 1995; Mongillo 1984; Wydoski 1977; Schisler and Bergersen 1996).
CIRILLO, KEITH January 22, 2013 SEATTLE, WA Comments: Both the Hooton (2001) and Bruesewitz (1995) studies found the largest mortality associated with bait (as high as 17.8%), followed by gear and the lowest was with fly caught fish. We should eliminate the use of bait and barbed hooks, neither of which were mentioned in the Oregon work. Further, the recent WDFW study in Puget Sound found a 14% mortality rate (Ashbrook, 2010). Clearly the elimination of bait and barbed hooks will greatly reduce CnR mortality on wild fish. Note also that British Columbia has eliminated bait and barbed hooks on the Skeena system for the reasons detailed above. YOST, DEREK N January 22, 2013 EUGENE, OR Comments: Hello-
Treble hooks have been shown to cause more mortality even in released fish. Please consider restricting harmful fishing tackle to help wild fish recovery.
Best regards,
Derek Yost TOMINE, DYLAN January 22, 2013 BAINBRIDGE ISLAND, WA Comments: I support, and urge you to consider, the change to selective gear rules for steelhead rivers in Washington. This would reduce mortality on our dwindling wild adult steelhead returns in the catch-and-release fisheries, and have a major impact on smolt and resident rainbow mortality as well.
In this day of shrinking wild steelhead returns statewide, it is critical that we place maximum effort into preserving these runs. This rule change would help. Thank you for your time. ALEXANDER, ROBERT G January 22, 2013 BEAVER, WA Comments: If the State provides no evidence that bait and barbed hooks do not cause fish deaths and the conservation groups reference numerous reviewed studies which point to much higher mortality with bait and barbed hooks, one can only conclude that the State has no such evidence or fails to duly consider the proposal. The recovery of wild steelhead populations will be greatly enhanced with adoption of selective gear rules. Please adopt the proposal. HIAR, EDWARD C January 22, 2013 LYNNWOOD, WA Comments: I have seen the cost of usage of bait first hand.
I recommend the suspension of the use of bait in all of our Westside and Coastal Rivers particularly after Feb. 1 when the numbers of native fish in our river systems increase. WANG, DAVID January 22, 2013 MEDFORD, OR Comments: I agree with the Wild Steelhead Coalition's position that the type of gear used should be restriced in western Washington. LARISON, JOHN January 22, 2013 CORVALLIS, OR Comments: As a guide, I hope this proposal becomes a new state regulation. DUNPHY, LOGAN January 22, 2013 EUGENE, OR Comments: I agree w/ WSC:
"What gear method was used and does this catch, handling, and “release” method really represent the diverse angling community and wild steelhead population(s) of that area? Is this “evidence” accepted as the best available science as directed by the WDFW’s Statewide Steelhead Management Plan? This proposal is to eliminate the use of bait and barbed hooks, neither of which the WDFW has mentioned from the Oregon work.
In Bob Hooton’s 2001 scientific study, he found hooking mortality was consistently at least 3 to 9 times higher when using bait verses using artificial lure or fly.
Steelhead and stream-resident rainbow trout are the same species, can inter-spawn, and both can contribute to future generations of wild steelhead. Many studies have shown significantly higher mortality in trout when angling with bait verses artificial lures/flies (Taylor and White 1992; Schill and Scarpella 1995; Mongillo 1984; Wydoski 1977; Schisler and Bergersen 1996)."
PARKS, MATTHEW January 22, 2013 CORVALLIS, OR Comments: I support the position of the Wild Steelhead Coalition, and the need to recover what are currently devastated runs of wild steelhead and salmon. WHITAKER, DAN B January 22, 2013 ELLENSBURG, WA Comments: The disapproval of this proposal should not be based on 'some' evidence from a single instance. Plus, the mortality difference between barbless/no bait, and the opposite, shouldn't have to be monumental in order to put the proposal through. The deciding factors in this battle against massive declines in wild steelhead and salmon we are facing could easily come down to small percentages going one way or the other, so there is no reason not to do everything we can, even if it's only going to help a little. Also, I didn't see any reasons in your rebuttal that were significant enough NOT to give it a try. Every little thing helps, so please, make it happen.
Dan LENT, MARK H January 22, 2013 BREMERTON, WA Comments: Your comments on the Eastern Wa Steelhead population do not take into consideration the impact of the columbia river dams. How can you reference the study of mortality on a single river (Grande Rhonde) when the entire eastern washington species is on the brink of anniliation.
Is your solution more hatcheries more barges? LENT, MARK H January 22, 2013 BREMERTON, WA Comments: Your comments on the Eastern Wa Steelhead population do not take into consideration the impact of the columbia river dams. How can you reference the study of mortality on a single river (Grande Rhonde) when the entire eastern washington species is on the brink of anniliation.
Is your solution more hatcheries more barges? SLIGHTOM, BRUCE W January 23, 2013 EUREKA, CA Comments: I support the selective gear proposals for west side rivers. VRADENBURG, JOHN S January 23, 2013 FALL CITY, WA Comments: Catch and release mortality can vary widely depending the gear type used. Hooten (2001) found that hooking mortality was consistently at least 3 to 9 times higher when using bait verses using artificial lure or fly. Bruesewitz (1995) found that the highest percentage (17. 8%) of critical area hookings (tongue, esophagus, gills, and eyes) occurred when using bait and treble hooks in winter steelhead fisheries. Because steelhead and stream-resident rainbow trout are the same species, inter-spawn, and both can produce anadromous forms, it is important to consider wild rainbow trout conservation when managing for wild steelhead sustainability and recovery. Many studies have shown significantly higher mortality in trout when angling with bait verses artificial lures/flies (Taylor and White 1992; Schill and Scarpella 1995; Mongillo 1984; Wydoski 1977; Schisler and Bergersen 1996). Taylor and White (1992) showed an average mortality of trout to be 6-8 times greater when using bait verses LAWRENCE, ANDREW R January 23, 2013 LYNNWOOD, WA Comments: I support this proposal due to the reasons cited above by the Wildsteelhead Coalition. LYONS, KIMBERLY A January 23, 2013 BOTHELL, WA Comments: WDFW should review the published literature on the subject which shows a significant loss of fish that are caught and released. The Oregon information cited has not been reported on in any papers that the local science-based wild steelhead recovery groups are familiar with. Note that both the Hooton (2001) and Bruesewitz (1995) studies found the largest mortality associated with bait (as high as 17.8%), followed by gear and the lowest was with fly caught fish. Eliminating the use of bait and barbed hooks, as requested for this proposed rule-change, was not addressed in the anecdotal Oregon work referred to. On the other hand, the recent WDFW study in Puget Sound found a 14% mortality rate (Ashbrook, 2010). Note also that British Columbia has eliminated bait and barbed hooks on the Skeena system for wild steelhead conservation. Clearly the elimination of bait and barbed hooks is a science based fact and will greatly reduce CnR mortality on wild fish, promoting resource conservation. NOTTINGHAM, DAN C January 23, 2013 CLANCY, MT Comments: I agree with this proposal. By eliminating bait the mortality of native fish will be greatly enhanced. Barbless hooks and single hooks make it much easier to release fish unharmed. BIALOUS, ROGER January 23, 2013 SEATTLE, WA Comments: Due to the diminished borderline endangered state of wild steelhead, I believe that it should never be legal to retain a wild steelhead, thus all waters should be selective gear rules all year to facilitate the survival of any hooked wild steelhead. LINDQUIST, RICK January 23, 2013 SEATTLE, WA Comments: I am very much opposed to this proposal, and support the WDFW Staff position.
The mission statement of WDFW is:
To preserve, protect and perpetuate fish, wildlife and ecosystems while providing sustainable fish and wildlife recreational and commercial opportunities.
While the proposers are very well intentioned, this proposal would markedly restrict recreational fishing without signifigently improving wild fish survival.
Well intentioned but extreme, I think. CLARK, GARY January 23, 2013 BELLINGHAM, WA Comments: Bait nolger is need as we all know. Plus the impact on all Juvenile salmonids.
WDFW should review the published literature on subject which shows a significant loss of fish that are caught and released. The Oregon information has not been reported on in any papers we are familiar with and we would like to see it available by gear and hook type. Note that both the Hooton (2001) and Bruesewitz (1995) studies we reported on found the largest mortality associated with bait (as high as 17.8%), followed by gear and the lowest was with fly caught fish. Our proposal was to eliminate the use of bait and barbed hooks, neither of which you have mentioned from the Oregon work. On the other hand, the recent WDFW study in Puget Sound found a 14% mortality rate (Ashbrook, 2010). Clearly the elimination of bait and barbed hooks will greatly reduce CnR mortality on wild fish. Note also that British Columbia has eliminated bait and barbed hooks on the Skeena system for the reasons detailed abov BIGGINS, DENNIS P January 24, 2013 HILLSBORO, OR Comments: Please consider these proposals. For the future of wild fish in your fine state. Thank you, Dennis Biggins SENYOHL, CHRIS J January 28, 2013 FALL CITY, WA Comments: I am against this proposal and while I chose to predominately use selective gear methods (fly, no bait), I also don't think that anglers who choose different methods should be discriminated against. There are many waters already put aside for anglers who choose selective methods. WALLACE, TOM M January 28, 2013 SEATTLE, WA Comments: I am not in support of this proposal. I don't believe it will save fish. Steelhead are rarely hooked deeper than their mouth. I fish selective waters and have found an occasional steelhead will swallow a fly as well. Also on many lures if you take off the trebble hook the alternative is a larger single hook that does more damage to the fish. GAVIN, MARK J January 28, 2013 NORTH BEND , WA Comments: Strongly disagree with this proposal.
It is not needed.
The proposal favors special interest group.
The data by the groups that originally made this proposal is not valid.
In the extremely few cases where there there really needs to be a conservation limitation to protect the fish make it a total closesure to all fishing methods. HOPPLER, WES C January 29, 2013 SEATTLE, WA Comments: Oppose this proposal on a blanket westside basis.
Bait remains the most popular method for winter steelheading and is reasonable to use under the difficult water conditions often encountered during the winter and spring steelhead fisheries targeting wild fish.
Really must point out the strong ties to the fly fishing community of the proposers/endorsers of this proposal - a fisheries grab dressed as conservation - well it would not be the first time that has ever happened.
I might be up for barbless hooks if it was not tied to no bait through the selective fisheries rule. SHARF, JOHN D January 29, 2013 KENMORE, WA Comments: No change required, believe survival of fish when properly released is same no matter which type method used to catch them. SIMONSON, WILLIAM R January 29, 2013 SEATTLE, WA Comments: This proposal should not be considered. At the point that selective gear restrictions are considered necessary because of the potential small differences of mortality in the small number of caught fish, the fishery should be closed to all; not left open to a faction. MALLOCH, STEVE January 29, 2013 SEATTLE, WA Comments: In reference to DFW725075: Please help concerned anglers decrease wild steelhead mortality by eliminating the use of bait. A throat or gut-hooked (and bleeding) steelhead is a dead steelhead. How many more years do we have left to even HAVE this discussion? Please, move to selective gear immediately.
Steve Malloch ANDERSON, SHANE January 29, 2013 OLYMPIA, WA Comments: Please enact selective gear rules to the OP rivers before its to late and all fishing will be cut off due to low returns. I have seen first hand the northern cal rivers rebound in the years after selective rules regulation. Hopefully some day the abundance will return and harvest can happen, but now is not the time. Please set an example and do whats right for the fish, not the fisherman.
Thank You,
Shane Anerson SIMMS, RICH K January 29, 2013 MUKILTEO, WA Comments: What gear method was used and does this catch, handling, and “release” method really represent the diverse angling community and wild steelhead population(s) of that area? Is this “evidence” accepted as the best available science as directed by the WDFW’s Statewide Steelhead Management Plan? This proposal is to eliminate the use of bait and barbed hooks, neither of which the WDFW has mentioned from the Oregon work.
In Bob Hooton’s 2001 scientific study, he found hooking mortality was consistently at least 3 to 9 times higher when using bait verses using artificial lure or fly.
Steelhead and stream-resident rainbow trout are the same species, can inter-spawn, and both can contribute to future generations of wild steelhead. Many studies have shown significantly higher mortality in trout when angling with bait verses artificial lures/flies (Taylor and White 1992; Schill and Scarpella 1995; Mongillo 1984; Wydoski 1977; Schisler and Bergersen 1996).
It is clear from the best availabl
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