The WSC supports river closures for wild steelhead fisheries when the runs are showing a decline and have not made their escapement goals over time. However, we have not found any information that supports the escapement goals and early closures of the Willapa Bay rivers. We note that some other rivers are not making escapement (the Grays River as example) and appear to have had escapement goals set above the historical run sizes (1980s).
We have reviewed the Gibbons et. al. (1985) report and did not find these rivers listed. Further, the WDFW has not been able to furnish us with information describing the process and models used to set these goals. We respectfully request the WDFW re-evaluate the escapement goals for these river systems and retrieve and use the following information for this re-evaluation:
- Reconstructed run data for the period of 1980 through 1995. We have this data for years 1996 to present and do not believe that information alone supports the escapement goals or this closure. Based on that information alone, there is reason to believe the goals were set too high.
- A description of how these escapement goals were set such as modeling Potential Parr Production counts with spawner counts (as done in Puget Sound and other Boldt case area rivers by Gibbons et. al. 1985) , or modeling river spawner/annual recruit data, or other.
Given that these rivers are extremely important to sport fisheries and the above data may be missing or no longer appropriate after approximately 27 years of management since these goals were established, we request the WDFW re-evaluate the escapement goals for these river systems and delay the proposed closures until that review is completed.
Furthermore, WDFW needs to be committed to providing catch and release wild steelhead fisheries through selective gear rules and close monitoring by WDFW. Simply closing wild steelhead sport fishing opportunities to rebuild runs is not an effective management plan and it has not worked in Washington, while at the same time increasing resident rainbow trout harvest that are essential to wild steelhead recovery and sustainability.
Please take a minute to write WDFW and tell them not to close steelhead fishing in areas where escapement goals need to be re-evaluated.
Comments can be submitted before December 30th to WDFW’s rule coordinator at:
Or by mail:
WDFW Rules Coordinator Lori Preuss
600 Capitol Way N.
Olympia, WA, 98501