Hi all,


As the REC season has been nearly finished with the seasons put forth to staff are acceptable ( I guess as they do not say much else ) so staff is not accepting further input on Rec seasons.


What about the Commercial season? Problems everywhere to say the least. Staff have proposals that try to get around 4/3, have nets in 2A & D ( downtown Aberdeen ) on the weekend knocking out the working guys family fishery, over harvest Chehalis Chum by taking the aggregate ( combination of Chehalis & Humptulips ) all on the Chehalis side which is a conservation issue, try to button hole the QIN by fishing directly in front of the tribal fishers, and in general create mayhem wherever possible.


So what is WDF&W going to do? Got me but so far they have adamantly refused to put forth anything for review. All they ( according to them ) are doing is taking input. Throw whatever at the wall for Commercial seasons regardless of how ridiculous it is and in the hopper it goes for consideration. Makes it a little difficult to follow what on earth is going on and nearly impossible to comment on anything as it is just input. I doubt anyone will know what is what until they file the CR 102 creating the WAC for the Commercial season.


That leaves one with trying to identify what is a proposal and comment on it, which in my opinion is what WDF&W desires. So below are my Comments on the last proposal from the Commercial side. In answering the issues in it I was able to address several other issues from other proposals.



To: Steve Theisfeld

       Jim Scott


After reviewing of the Commercial Proposals submitted on 5/1/15 several issues are present. In looking at the modeling of the proposed seasons by the Commercial sector, revised by WDF&W, I propose the changes outlined below. I also have attached a modified copy of the WDF&W spread sheet reflecting the changes.


It appears that the model failure of not reflecting harvest impacts of prior harvest be it Recreational or NT Commercial prior to the QIN fisheries is still present. I should not be able to place NT Commercials in seven days a week with the QIN fishing 4 days and show zero impacts to the QIN fishery. This was corrected for the Recreational fishery last year but it appears staff failed to do so for the QIN fisheries.


Also the model does not provide ex-vessel value for the NT Commercial harvest. This is a serious failure by staff to provide all the information necessary to evaluate any NT Commercial season proposal. This should be addressed immediately and added to the model as was done in the revised Willapa Harvest Model.


Recommended Changes To the 5/1 Commercial Season Proposal:

Week 42:

On October 11th the proposal places the NT Nets directly in front of the QIN scheduled fishery on October 11th. This is inappropriate and appears to be  intended to strike out at the QIN & GHMP. Again this is inappropriate and should be removed from any further consideration.


On October 14th the proposal has the Non Treaty fishers going in directly as the QIN fishers are pulling their nets completing fishing for the week. With limited boat ramp availability and the combined number of QIN, NT, and Recreational boats intermixed in such a small area the potential for safety issues and conflict exist. I suggest a minimum of a 1:30 PM start for NT fishers to allow the QIN and Recreational fishers who choose to do so to get their catch and boats off the water safely without unnecessary conflict.


Week 43:

The proposed season is utilizing the aggregate for Humptulips and Chehalis Chum but taking the vast majority on the Chehalis side. This is inappropriate and vastly increases the probability of serious damage to the Chehalis Chum stocks should the runsize forecast meet predictions and guarantees substantial damage to Chehalis origin Chum if run does not  exceed preseason expectations. This differs greatly with the QIN proposed seasons with harvest projections of a Chum harvest of 2916 Chehalis origin  and 1275 Humptulips origin which seek to maintain somewhat of a balanced harvest. The proposal also places the NT Commercial fleet in the river at 2A & D at Aberdeen thus removing the weekend fishery for the family Mom & Pop recreational fishery. This particularly egregious as 2A is the primary bank fishing area for handicapped Recreational fishers  This is totally unnecessary as it can be avoided by simply utilizing other days of the week. To address this issue and the imbalance between the harvest of Chehalis and Humptulips Chum in the aggregate I propose a reduction to two NT Commercial days on October 21 & October 22 in week 43.


Regardless of what days of a week  WDF&W staff choose to install the NT Commercial fisheries in 2A & D Saturday or Sunday should not be utilized for Commercial days to avoid the Recreational and Commercial gear conflicts which was a goal of the GHMP.  


Week 45:

The proposal in week 43 results in gear conflict between Recreational & NT Commercials as the proposal places the NT Commercial fleet in the river at Aberdeen in 2A & D thus removing the weekend family Mom & Pop and handicapped recreational fishery. This is totally unnecessary as this can be avoided by utilizing other days of the week. To accomplish this a week 45 fishery of November 1 through November 4 is necessary with a start time of  1:30 PM on November 1st to avoid conflict with recreational fishers is required. This allows for four days of NT Commercial harvest.


Additionally  the schedule outlined previously for week 45 allows for three days between the NT Commercials and QIN which allows for limited impact to the quality of the QIN and Recreational fisheries.


The final issue I wish to address as a GH Adviser is the failure to record or take formal minutes of the May 1st Adviser meeting create a record of the meeting which is also inappropriate. It was my understanding that this issue had been resolved some time back and WDF&W would create the required permanent record of Adviser meetings. If staff has changed or altered the  manner it creates a permanent record  I would appreciate you provide me the revised procedures.


Dave Hamilton




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