The Agency request for comments and input for the Grays Harbor Management Policy review for is underway so I thought I would post mine up for folks.
COMMENTS GHMP REVIEW:
In general the Grays Harbor Management Policy ( GHMP )
worked as well as it could under the circumstances we faced in the 2015
seasons. In the end we had failings but I feel I must point out that these were
failings of staff to follow the intent of the GHMP not the GHMP itself. That
said I will limit my comments to these items.
Guiding Principles: ( Also known as
4/3 ) while staff has voiced concerns over the "
difficulties " poised by this section in reality they do not exist except
for one issue. It prevents staff from combining Non Treaty Commercial fisheries
with tribal fisheries to create seven day a week commercial net seasons which
is the purpose of section 8 to prevent just that.
Recreational and WFDW-managed commercial fisheries shall be structured (e.g.,
schedule, location, gear) to minimize gear and other fishery conflicts.
WDFW-managed commercial gillnet fisheries in a fishing area or aggregate area
(i.e., Area 2A/2B/2D; or Area 2C) shall be scheduled, if possible, so that in
any given calendar week there are a minimum of three consecutive days when no
treaty or state-managed commercial fisheries occur. If the treaty fishery
occurs 4 or more days in a calendar week, no WDFW-managed commercial fishery
shall occur in the remaining days of the week.
Management Item 1: ( known as the 3/5
penalty box ) This section has troubled many including myself and as much as I
would like to see it removed it needs to remain in place. Had not for the 4/3
& the 3/5 penalty box this past year we would have likely not made
escapement for Chinook as the run cannot sustain two full out fisheries, the
numbers do not permit it. With the continuing disagreement between Region 6 (
R-6 ) staff and the Quinault Indian Nation ( QIN ) regarding harvest sharing not
being resolved it is the penalty we fishers must endure to protect the
Management: As a component of the annual fishery management review, the
Department shall assess if spawner goals were achieved for Chehalis spring
Chinook, Chehalis fall Chinook, Humptulips fall Chinook, Chehalis Coho,
Humptulips Coho, and Grays Harbor chum salmon. If the number of natural-origin
spawners was less than the goal in 3 out of the last 5 years (beginning in
2009), the Department shall implement the following measures:
predicted fishery impact for that stock in WDFW-managed fisheries in the Grays
Harbor Basin will not exceed 5% of the adult return to Grays Harbor; and
b) If a
spawner goal for fall Chinook salmon is not achieved, the Grays Harbor control
zone2 off of the mouth of Grays Harbor will be implemented no later than the
second Monday in August and continue until the end of September.
Principle section 7: While the 4/3
provision provides fish available for the inriver fresh water recreational
fisher it is reinforced by Section 7. From my perspective that for whatever the
reasons this section of the GHMP was not adhered to. This is reinforced by how
the 2015 seasons played out with almost the entire conservation needs being
borne by the inriver recreational fishery as the Coho run failed to
materialize. This is not a GHMP failure but rather a failure of R-6 staff to
follow the intent of the GHMP.
7) In a
manner consistent with conservation objectives, fishing opportunities will be
fairly distributed across fishing areas and reflect the diverse interests of
The next issue is complex but goes to the heart of the
failure in Grays Harbor salmon management in 2015. In the season setting
process staff worked to provide opportunity to all. In fact I would say that
the efforts of Steve Thiesfeld and Mike Scharpf in the season setting process
were exceptional and need to recognized. As much as I support the R-6 staff in
the 2015 season setting process what followed in the months afterward I do not
view in a favorable manner.
From the beginning the preseason forecast for Coho was
problematic and in not supported by the NOAA PDO forecast for ocean survival.
This was followed by landings showing the Coho runs coast wide appearing to be very
weak right up to the first Grays Harbor fisheries. On week 38 ( September 13-19
) the QIN fishers harvested but then Week 39 ( September 20-26 ) pulled for a
week. The QIN resumed scheduled fisheries through Week 42 ( October 11-17 ).
Additionally R-6 scheduled half day Non Treaty Commercial fisheries for a half
day in front and after the Week 42 QIN fisheries and two days in Week 43 before
closing all fisheries for conservation followed by the QIN doing the same.
R-6 has stated it received the QIN harvest numbers
October 18th other than the Week 38 numbers which had been posted on the
WDF&W website. This is a very serious problem as Week 40, 41, & 42 are
the primary weeks of the Coho run through the estuary and when the numbers were
made available to the public they showed a total collapse of the Coho run
forecast. This raises the question. Did the QIN withhold harvest numbers and
continue fishing their schedule knowing the forecast run was not
materializing? Did R-6 fail to ask for
the QIN harvest numbers in a timely manner? Many believe that staff had been
given the QIN harvest numbers verbally and that staff chose to withhold the
information from the public which is problematic on so many levels it is
difficult to describe. The questions I and many others could fill pages but can
be boiled down to this. What did R-6 know about the QIN harvest
numbers both Coho and Chinook and the failure of the Coho run forecast and when
did they know it? If the QIN did not share the harvest numbers this is
a substantial issue. If R-6 did not ask for the numbers or disregarded them
this just as large failure. I would like
to point out that in Willapa R-6 did react in a positive manner to adjust to
the issue of the Coho run collapse be it to being late in the game.
Additionally the time it takes for Grays Harbor harvest numbers to be placed
upon WDF&W's website is appalling! This does not happen in other regions so
why does R-6 struggle with posting Grays Harbor harvest numbers?
The citizens who worked so hard to get the GHMP in
place deserve a forthright and honest explanation for the staff failure as it
is totally unacceptable. Then one must recognize the broader issue. With what I
outlined previously coupled with the landings and harvest in the ocean
fisheries and the first returns to the Columbia showing a total collapse of the
Coho run why was not action taken by the marine managers? Where is the
monitoring and coordination of harvest between the ocean and fresh water? To
wait until the very end to implement any conservation objectives only at the
terminal fisheries defies logic. In fact in my mind the failures of R-6 pale in
comparison to the failure of senior WDF&W staff to coordinate and manage
the 2015 marine harvest and frankly did a very real injustice to R-6 ( and
other regions ) fresh water management staff. The street slang for the manner
in which the ocean managers functioned is called " autopilot " and I
do believe that is just how senior harvest managers functioned in 2015. I doubt
any terminal management policy can succeed with ocean managers and Olympia
based senior staff conducting business in that manner.
My final thoughts reside in a issue that plagues all
of WDF&W staff and it is the refusal to not speak in forthright and open
manner. As a example I will use Steve Thiesfeld's comments in his presentation
at the Commission meeting in which R-6 made a presentation updating the Grays
Harbor 2015 season several weeks back. In that presentation he identified the
many challenges faced but one particular statement stood out. When addressing
the failure to likely to make escapement he more or less stated that the small
commercial season Coho harvest even if cancelled would not have allowed us to make
escapement. That is true except that the other fact is by allowing that fishery
to proceed it totally destroyed any chance of a inriver fishery, violated
Guiding Principles Section 7, and did not address just why the three prime week
QIN harvest numbers were not made available. Later when many reacted in a
unfavorable manner it was followed by staff describing the South Monte
tidewater fishery as providing inriver equity. The Chehalis River is the second
largest watershed in the state and to call tidewater fisheries meeting
requirements is simply fiction. Whatever the issue is WDF&W staff cannot
regain the public's trust if they do not speak candidly. It is true that when
the agency staff have spoken frankly it has made many people angry. The other
side is when they do not speak frankly they make everyone angry. I urge
frankness and openness as in the long run folks can respect honesty but not
A very good example of how to be open and transparent
is the Power Point that R-6 recently provided that is going to be presented at the
Commission meeting shortly. Mike Scharpf forwarded it out to the Advisers and
public for them to look at and offer suggestions on its content rather than
wait until it is presented to the Commission. I can say nothing negative as to
this effort to reach out to the citizens. It is a excellent example on how
staff should function which gets lost in the discussion due to it not being the
consistent ongoing manner that staff does business.
One final item. Wynoochee Mitigation and remember Mr.
Osborn and kicking the can down the road? Sad to say the only thing that has
moved forward is the can, down the road, and little else. I grade it F- as
little to nothing has been accomplished since the adoption of the GHMP
instructing staff to move forward and meet the mitigation requirements.
Posted on Tue, February 16, 2016
by Dave Hamilton