As we truck on down the road I thought I would let everyone get a look at my comments to the Commission.  Now these are my thoughts but agree or disagree I urge everyone to comment directly to the Commissioners on the continuing process of remaking the Grays Harbor Management Plan. A e-mail or letter but all the citizens in the Chehalis Basin communities need to participate.   commission@dfw.wa.gov   is the Commission address and staff will direct your correspondence to each Commissioner.


Dear Commissioners,

I am writing to express my concerns regarding the current effort by WDF&W staff to review and modify the Grays Harbor Management Plan. As a member of the GH Advisers I applaud Mr. Scott's efforts but this is not the case to many citizens that have communicated to myself and others as they fail to see any fundamental changes from the failed past practices of Region 6 District 17 staff. In fact the term " dog & pony show " is once again being utilized to describe the process by many citizens. Little faith exist that the input from the public is not being " sanitized " to in effect not allow the public's comments to fully and accurately provided to the Commissioners. This being the case I have attempted to define some basic issues and provide alternative solutions.

1. Failure To Make Escapement: The Grays Harbor / Chehalis Basin has failed to make escapement on Chinook and Chum stocks for one reason and one reason only, commercial over- harvest. The desire by all elements of the public as a whole for the greatest possible harvest opportunity creates a climate of that nearly dictates the failure will happen again and again. In fact I ask the Commissioners to ask of yourselves and others this question. " What other river in the state does the WDF&W Commission authorize commercial fisheries six to seven days a week with stocks not making escapement? " I urge the Commissioners to consider the following as a policy guideline that is a rock solid baseline policy not to be violated.

4 & 3
" In any given calendar week commercial fisheries not exceed four days and those days must be consecutive."

Boiled down to the simplest terms one citizen put forth this simple definition. " Four days a week for harvest and three days the gravel / fish " In addition all recognize that the Quinault Nations Commercial fisheries do exceed four days at times this guideline is intended to address the cumulative days of both the non treaty and tribal commercial fisheries but not in any way abridge the QIN treaty rights. Also as the Humptulips and Chehalis Rivers are managed separately by the state but not so by the tribal co managers it is recognized further " side boards " would need to be defined.

2. The Harvest Model: The model utilized for the management of Grays Harbor fisheries has been the subject of intense scrutiny. After considerable input ( or harassment depending on your view ) from citizen John Campbell over forty eight math errors and false data points have been corrected but not the failure of the model to correctly predict the commercial and recreational impacts. This has been brought to R-6 District 17 staff repeatedly yet little has been done to correct this issue. I must admit though Dr. Estalilla was told be careful what he wished for in a 2013 Advisers meeting he strenuously objected to this practice. Simply put Commissioners staff must be required to utilize the model in a manner that insures accuracy and NOT in a manner that insures it is absolutely not accurate as R-6 District 17 presently does.

3. Selective Fishing: In Grays Harbor the Commercials and Recreational fisheries utilize catch & release ( C&R ) and in both the true and actual impacts are not correctly represented in the model. In the case of the non treaty commercial fisheries it is particularly egregious as the impacts have been intentionally misrepresented. In the Grays Harbor Non Treaty Commercial Fishery training is required, the British Columbia training films are utilized, recovery boxes required, protocols reviewed, mortality applied, ( developed in the Columbia River ) and other elements outlined. I am sad to say it is a complete farce as it is a Selective Fishery in name only. District 17 violates virtually every protocol from avoidance to revival box use. Two videos documenting this abuse can be viewed on the Fishing The Chehalis website and for Grays Harbor practices I urge you to review the Chehalis Fling and for the lack of the correct development view Selective Fishing. I urge the Commission to require the processes and protocols to be utilized in selective fisheries be clearly defined and not open to manipulation and abuse as R-6 District 17 staff currently practices.

4. Inland Communities: At every meeting for the current GH Management WDF&W has time and time again represented the current difficulties as a Recreational fisher vs a NT Commercial fisher. This 100% correct and yet is 100% incorrect. At the heart of the current difficulties is not just rec v commercial but rather the inland communities citizens growing and adamant opposition to the failure to make escapement and the practice of WDF&W awarding the vast majority of harvest taking place in the marine area communities of Aberdeen and Hoquiam. It should also be understood by the Commissioners that the inland citizens do not separate the commercial fisheries by race and ethnicity but view the both QIN and NT nets as commercial, period. The inland communities citizens have borne the vast majority of the cost environmental reform / timber harvest reform and neither they or the fish receive any benefit. R-6 District 17 continues the practice of institutionalized discrimination towards the citizens of the inland Chehalis Basin by directing the vast majority of harvest opportunity to the bay and terminal fisheries centered around the communities of Aberdeen and Hoquiam.

Commissioners I urge you to end this practice immediately! In the coming months and years additional sacrifice will be required to address the court mandated culvert replacement and other issues relating natural origin salmon populations. For what? To have any benefits to be harvested at Aberdeen & Hoquiam and not enhance the spawning salmonid populations? To continue to deny the vast majority of Chehalis Basin citizens that shoulder the financial burden any of the benefits? The management of the Grays Harbor / Chehalis Basin has been referred to as the " poster child for not supporting any additional citizen cost in taxes or regulation. " It is difficult to challenge that view as neither the fish or citizens of the inland communities will see any benefit under Region 6 District 17 policies.

The issues I have outlined are complex yet the solutions need not be. If the Commission does not take dramatic steps to resolve the issues I have outlined the future will not hold much promise for the Grays Harbor / Chehalis Bain watershed but rather a ever growing controversy returning to the Commission year after year.


Dave Hamilton

I urge all who visit D's Rants to do the contact bit and I will add your name to the contact list so whenever we have something interesting posted you can be notified.

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