GHMP COMMENTS

GHMP COMMENTS

I thought I would put up my comments on the GHMP that I submitted for the Grays Harbor review by the Commission. 

 

 

Good morning Commissioners my name is Dave Hamilton and I would like to address two issues. First is since the adoption of the GHMP we have all struggled as it was implemented but staff has struggled more than the citizens of the Chehalis Basin. District 17 staff have never received the support necessary to fully do their job prior to the GHMP and even more so now. Just things, the tools needed to do ones job with some hope of success. In Willapa this was not the case as that support was provided internally but not Grays Harbor. I am asking that this be addressed immediately as issues such as in season monitoring which is a critical element of any management strategy will not be possible. The failure to provide the tools to District 17 staff or even recognize the need is a serious issue and frankly we failed staff. We ..... Commissioners from the Director to advocates such as myself on this issue we failed staff. The District 17 staff need to be provided the tools to do their jobs.

My second issue is what is known as the 3/5 penalty box which requires no targeted fishery on a stock that has failed to make escapement three out of five years.  Since the implementation of the GHMP myself and others have struggled understand how the 3/5 provision works for conservation as it is applied. Last year a neighbor who is 82 years old asked why no Chinook retention and I explained it right down to reading the passages from the GHMP as he is legally blind. His response has stayed with me and goes to the heart of the issue. " Why are we being punished? We did nothing wrong! " He is correct Commissioners as the Rec fisher has had little to do with the failure to make escapement but are the ones who are being required to shoulder the burden of the 3/5 conservation standard.

To further complicate the issue is the simple fact that all the Quinault Indian Nation fishery ( QIN ) managers have to do is fish as they always have coupled with small runs or below escapement forecast in one or more species and over a period of years the GHMP 3/5 will dictate almost zero non treaty harvest. Add to mix all the QIN managers need to do is move a couple of days strategically to remove any opportunity for NT commercials. The Chehalis Chinook and Humptulips Coho are two prime examples as the GHMP 3/5 coupled with the 5% limiter due to a small runsize forecast and non treaty fisheries are almost nonexistent. With the 2016 Coho run being forecasted at a small run designation coupled with the GHMP 3/5 provision for Chehalis Chinook & Humptulips Coho it is hard to imagine any meaningful season for the Rec or the NT Commercial fisher.

In the coming weeks the 2016 seasons must be crafted. The question is how can this be done with the 3/5 provision without punishing those not responsible for the failure to make escapement in the past? Additionally information provided at the NOF preseason forecast meeting indicates that the QIN forecasting methodology had been changed resulting in vastly different numbers than WDF&W. This lends credence to the thought that the QIN representatives are manipulating their processes to create the most dire situation for the non treaty fishers and undermine the GHMP.

Whatever the outcome of the 2016 season setting process there is a pressing need to address the fact that the 3/5 provision regardless of the intent has in the end punished those who had almost zero to do with the issue of failure to make escapement, which is the inland fresh water Rec fisher, and did little to solve the issue. The fact is the non treaty fisher is being punished for the failure of the QIN managers to address equitable sharing of harvest. Add to the mix the fact the 3/5 clause actually provides an incentive to the QIN managers to not address the failure to make escapement as 3/5 actually provides benefit to the tribal managers for failures to make escapement by limiting non treaty harvest resulting in an even larger QIN harvest share at the states non treaty fisher's expense. This issue needs to be addressed immediately to insure that the non treaty fishers are not again punished for the past failures to make escapement as they had little to do with that failure.

Commissioners recognition is needed of the fact as written the GHMP 3/5 provision punishes with the greatest severity the non treaty Rec fisher who had the least to do with the failure to make escapement. A adjustment of some sort is required to insure that the Rec fisher does not continue to shoulder the entire conservation needs of the fish driven by the ongoing issues & disagreements between the state and tribal managers in Grays Harbor.  

 

 

 

 

 

 

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