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Submit Comments on Washington State Regulation Changes

Category: WSC Updates | Posted by: Jonathan | 1/22/13 | Comments: 1

Summary: Take action and submit your comments to the WDFW for regulation improvements during the 2013/2014 sportfishing rule proposals adoption process.
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In April 2012, the Washington Division of Fish and Wildlife (WDFW) invited the public to take part in the 2013 Sportfishing Rule Proposals process, stating that “Only those proposals that are necessary for resource conservation…should be submitted to WDFW.”
Using the best available science, we carefully drafted rule proposals, submitted a paper, and had numerous meetings with Washington Fish and Wildlife Commission members with our overall goal of a rules package that will remove hatchery fish from spawning grounds, reduce angling encounters to improve wild steelhead survival and spawning, help rebuild early-timed runs that are now depleted, and improve their range of genetic and adaptive diversity. In a nutshell? Help stop the slow decline of wild steelhead in Washington.

But now we need your help.

Through January 29, the WDFW is accepting comments on the Sportfishing Rule Changes for the 2013/2014 season.

Please take five minutes and tell the WDFW that these proposals, which were put forth by the Wild Steelhead Coalition, with the support of 14 other organizations, businesses, and scientists, should be adopted to help conserve wild steelhead, one of Washington State’s greatest economic and recreational resources.

Listed below are four proposals available for public comment. We have included our original comments, the WDFW comments, and our rebuttals and bullet points for your use. If you do not wish to provide original comments, feel free to copy and paste the bullet points or paragraphs rebuttals into the online comment form links found below (minimum of 1,000 characters).

The comment period has been extended until January 29, 2013, so act now! And watch your inbox for a Save The Date for the upcoming Fish and Wildlife Commission meeting in February, where testimony can be provided and is a critical factor to getting these proposals adopted.

Hatchery steelhead1) Mandatory Hatchery Steelhead Retention – Statewide

WSC Original Proposal Justification:
Unharvested Puget Sound hatchery steelhead create a negative impact to wild steelhead populations when allowed to spawn in the wild. This is a critical conservation measure to reduce the overall impact of hatchery steelhead on wild steelhead populations through the required retention of hatchery fish. Hatchery steelhead stray far worse than wild steelhead and often spawn in rivers on non-origin.  Hatchery steelhead have lost most of their productivity (Araki et. al. 2008) but do spawn with wild steelhead and reduce the overall rivers production.  Hatchery steelhead also spawn together and their fry compete with wild fry for food and space (Kostow 2009).    The state steelhead management plan describes the need to increase the harvest rates on hatchery-origin fish. This regulation is already in place during steelhead fisheries in the upper Columbia and its tributaries that provide both angling opportunity while reducing impacts to recovering ESA listed steelhead.
 
WDFW Comments:
This proposal would restrict option for catch and release fishing and would be very hard to enforce.
WSC Rebuttal/Justification:
Although the WDFW states: “This proposal would restrict option for catch and release fishing and would be very hard to enforce.”
  • Nearly all of the current WDFW Sportfishing Rules for wild steelhead are very hard to enforce with a diminishing budget and very few “on the ground” enforcement officers.
  • This proposal would further reduce the number of hatchery steelhead available to spawn with wild steelhead, assuring reduced hatchery vs. wild steelhead introgression (negatively affects healthy and ESA listed wild stocks).
  • The Kostow 2003 study found: “Our data support a conclusion that hatchery summer steelhead adults and their offspring contribute to wild steelhead population declines through competition for spawning and rearing habitats.”
  • A recent biological opinion in OR found that productivity/spawning success can be less than half when hatchery fish are left in the system and available to spawn with wild steelhead: “the reduction in productivity between a population comprised entirely of wild fish and one comprised of equal numbers of hatchery and wild fish is 66 percent for steelhead” (Section 2: Updating the Scientific Information in the 2008 FCRPS BiOp May 20, 2010, Page 118 and Lower Columbia River Salmon Recovery Plan 9‐2010 ODFW)
We recognize this rule cannot be perfectly enforced; however fisheries enforcement officers know the areas and times where fisheries take place for the hatchery fish and that there are only small numbers of wild fish at those areas and times.  This rule proposal carries with it intent to save wild fish from introgression and ecological impacts that sport fishers will come to understand.  The rule alone will stop most of the hatchery fish releases.  Hence it will accomplish much of its purpose.

>>SUBMIT YOUR COMMENTS FOR MANDATORY HATCHERY RETENTION STATEWIDE<<


2) Selective Gear Only – Feb 1 to April 30, west side rivers

WSC Original Proposal Justification:
Catch and release mortality can vary widely depending the gear type used.  Hooten (2001) found that hooking mortality was consistently at least 3 to 9 times higher when using bait verses using artificial lure or fly.  Bruesewitz (1995) found that the highest percentage (17. 8%) of critical area hookings (tongue, esophagus, gills, and eyes) occurred when using bait and treble hooks in winter steelhead fisheries.  Because steelhead and stream-resident rainbow trout are the same species, inter-spawn, and both can produce anadromous forms, it is important to consider wild rainbow trout conservation when managing for wild steelhead sustainability and recovery.  Many studies have shown significantly higher mortality in trout when angling with bait verses artificial lures/flies (Taylor and White 1992; Schill and Scarpella 1995; Mongillo 1984; Wydoski 1977; Schisler and Bergersen 1996).  Taylor and White (1992) showed an average mortality of trout to be 6-8 times greater when using bait verses using lures or flies, respectively.  Selective gear rules are necessary to minimize the mortality impacts on wild steelhead populations (including many ESA listed stocks).
WDFW Comments:
Disagree with the intent of year-round restrictions in eastern Washington, but only seasonal restrictions in western Washington, with no justification for the differences. We have some very strong evidence from ODFW regarding hook and line collection of steelhead in the Grande Ronde River by volunteers during the fall season over a period of years and then holding those fish for many months in a hatchery. The mortality from hook and release was very low.
 
WSC Rebuttal/Justification:
Although the WDFW states “We have some very strong evidence from ODFW regarding hook and line collection of steelhead in the Grande Ronde River by volunteers during the fall season over a period of years and then holding those fish for many months in a hatchery. The mortality from hook and release was very low.”
  • What gear method was used and does this catch, handling, and “release” method really represent the diverse angling community and wild steelhead population(s) of that area? Is this “evidence” accepted as the best available science as directed by the WDFW’s Statewide Steelhead Management Plan? This proposal is to eliminate the use of bait and barbed hooks, neither of which the WDFW has mentioned from the Oregon work.
  • In Bob Hooton’s 2001 scientific study, he found hooking mortality was consistently at least 3 to 9 times higher when using bait verses using artificial lure or fly.
  • Steelhead and stream-resident rainbow trout are the same species, can inter-spawn, and both can contribute to future generations of wild steelhead.  Many studies have shown significantly higher mortality in trout when angling with bait verses artificial lures/flies (Taylor and White 1992; Schill and Scarpella 1995; Mongillo 1984; Wydoski 1977; Schisler and Bergersen 1996).
  • It is clear from the best available science that the elimination of bait and barbed hooks will greatly reduce catch and release mortality on wild steelhead/rainbow trout.
WDFW should review the published literature on subject which shows a significant loss of fish that are caught and released.  The Oregon information has not been reported on in any papers we are familiar with and we would like to see it available by gear and hook type.  Note that both the Hooton (2001) and Bruesewitz (1995) studies we reported on found the largest mortality associated with bait (as high as 17.8%), followed by gear and the lowest was with fly caught fish.  Our proposal was to eliminate the use of bait and barbed hooks, neither of which you have mentioned from the Oregon work.  On the other hand, the recent WDFW study in Puget Sound found a 14% mortality rate (Ashbrook, 2010).  Clearly the elimination of bait and barbed hooks will greatly reduce CnR mortality on wild fish.  Note also that British Columbia has eliminated bait and barbed hooks on the Skeena system for the reasons detailed above.

>>SUBMIT YOUR COMMENTS FOR SELECTIVE GEAR ONLY<<


 

3) Hoh River – No fishing from a floating device Feb 1 – Nov 30, Morgan’s Crossing to ONP boundary

WSC Original Proposal Justification:
This is an important spawning area for mid and late run wild steelhead in the Hoh River.  Wild early run and South Fork steelhead rest and slowly pass though this area during the early winter months and spawn in upriver areas.  By early March, later run steelhead have begun spawning in the area in good numbers, continuing throughout the spring.   Boats can access every possible holding and spawning lie in the entire river, while bank anglers have less access to challenging lies.  Wild steelhead are caught-and-released (CnR) in large numbers, often while in their spawning phase.  Repeated and high levels of CnR can negatively influence behavior, reproduction, and survival of wild steelhead (Ashbrook 2010; Hooton, 2001; others).  This proposal will provide a partial refuge, increasing chances for steelhead survival and effective spawning.  Over time this regulation should increase wild steelhead abundance and diversity, improving their health and the fishery for future generations.
WDFW Comments:
The “no fishing from a floating device” regulation to reduce negative effects of catch and release fisheries on wild steelhead is typically not a tool used to address conservation objectives. Currently wild steelhead are meeting escapement in this river. Limiting harvest of wild steelhead to one per year per angler statewide, to be taken only in the lower stretches of rivers that are routinely meeting escapement goals, has reduced the non-treaty harvest of wild steelhead in these rivers by roughly 70 percent. Upper reaches of the north coastal streams under both State and Olympic National Park jurisdiction require selective gear and some are closed during much of the year, further limiting impacts of catch and release fishing. WDFW welcomes discussion of this and other ideas to better manage the wild steelhead stocks of the North Coast, as escapements, and catch and effort trends continue to develop in the future.
 
WSC Rebuttal/Justification:
Although the WDFW states that this “is typically not a tool used to address conservation objectives. Currently wild steelhead are meeting escapement in this river.” 
  • This management practice has been a conservation tool implemented on many steelhead rivers in Oregon and British Columbia with proven success.
  • Hoh River wild steelhead have missed their escapement goal in 10 out of the last 20 years.
  • The Hoh River wild steelhead abundance has fallen approximately 50-75% since the 1950’s and 30% since the 1980’s.
  • This proposal promotes the same fishing season for all diverse fishing methods.  Without change to management and continued declines in wild steelhead escapement, the next step may be to close the Sportfishing season early, affecting the fishing opportunity for bank and floating anglers alike.
  • The WDFW MUST find new methods to protect wild steelhead stocks from declines.  The current management is not working, as can be seen with 7 out of 7 of WA’s steelhead populations (ESUs) either listed under the Endangered Species Act, Chronically under-escaped, or experiencing population declines.
WDFW must find new methods to protect wild steelhead stocks from the declines we have seen statewide.  Using the only metric- making escapement- applied to stocks in Puget Sound and was in part responsible for the run failures. Using additional metrics as evaluating long term abundances and the changes in fishing effort will add considerable knowledge to conservation evaluations.  In the case of the Hoh River, the abundance has fallen approximately 50 to 75% since the 1950’s and 30% since the 1980’s; this slide is slower than the one in Puget Sound but of similar significance.

In this proposal we have suggested a change that will keep people fishing full season while protecting both holding and spawning early and late run fish.  The alternative in a few years may be a closure in these areas by late February that will greatly disrupt economies, guides and other float fishers alike.  Making this change now can potentially stave off more radical changes in the near future.

>>SUBMIT YOUR COMMENTS TO PROTECT HOH RIVER WILD STEELHEAD<<


4) Sol Duc River – No fishing from a floating device Feb 1 – Nov 30, Sol Duc Hatchery to 101 bridge upstream of Klahowya Campground

WSC Original Proposal Justification:
This is one of the most important spawning areas for early wild steelhead in the Sol Duc River (McMillan et. al. 2007).  Virtually every piece of holding water and spawning riffle is now fished hard and repeatedly by anglers in boats and they catch-and-release (CnR) numerous steelhead during a single day (WDFW creel surveys). Heightened CnR has been shown to have negative consequences on the behavior, reproductive success and survival of many species including adult steelhead (Ashbrook 2010; Hooton 2001, others).  This regulation will continue to allow ample sport fishing opportunity from the bank and establish a partial reserve for resting and holding steelhead. WDFW plans to designate this river as a Wild Steelhead Management Zone to protect steelhead genetics while allowing sport fishing.  Reduced angling encounters will improve wild steelhead survival and spawning, help rebuild the early-timed run now depleted, and improve their range of genetic and adaptive diversity.
WDFW Comments:
UPDATED: The “no fishing from a floating device” regulation to reduce negative effects of catch and release fisheries on wild steelhead is typically not a tool used to address conservation objectives. Currently wild steelhead are meeting escapement in this river. Limiting harvest of wild steelhead to one per year per angler statewide, to be taken only in the lower stretches of rivers that are routinely meeting escapement goals, has reduced the non-treaty harvest of wild steelhead in these rivers by roughly 70 percent. Upper reaches of the north coastal streams under both State and Olympic National Park jurisdiction require selective gear and some are closed during much of the year, further limiting impacts of catch and release fishing. WDFW welcomes discussion of this and other ideas to better manage the wild steelhead stocks of the North Coast, as escapements, and catch and effort trends continue to develop in the future.
WSC Rebuttal/Justification:
Although the WDFW states “The no fishing from a floating device regulation to reduce negative effects of catch and release fisheries on wild steelhead is typically not a tool used to address conservation objectives. Currently wild steelhead are meeting escapement in this river.”
  • All Coastal Olympic Peninsula Rivers are experiencing declines in wild steelhead escapement, including the Quillayute River and its tributaries.
  • The area proposed here is one of the most important spawning areas for early wild steelhead in the Sol Duc River (McMillan et. al. 2007), and currently the early wild steelhead stocks are estimated at just a fraction of their historic levels.
  • The Quillayute River drainage’s wild steelhead abundance, which includes the Sol Duc River, dropped more than 70% during the last decade.  WDFW needs to give additional protection to the depleted early run in order to restore and maintain the abundance, productivity, and diversity of the total run.
  • This management practice has been a conservation tool implemented on many steelhead rivers in Oregon and British Columbia with proven success.
  • Making these reasonably minor changes now to protect wild steelhead spawners on this critical stretch of the Sol Duc River can help divert the trend of declines, help in the rebuilding of the early run, and keep these rivers open to fishing all season for diverse angling methods.
In addition to our above comments on the Hoh River proposal, note that all coastal Olympic Rivers have experienced major declines.   The Quillayute system upheld its abundance until recently when it showed its first major decline.  Over the 10 year period following the late 1990’s the stock abundance fell over 70%.  Although abundance has partially recovered today, that recent decline shows the importance of further stock protection.  Again, we predict that our suggestion to close one spawning and holding area for early and late run fish will stave off future declines of this magnitude and keep all tributaries, including the Sol Duc, open to fishing the full season.  We also note that the Queets stock abundance has fallen from an average of about 10,000 fish in the late 1980’s and early 1990’s to about 6,000 fish today, a decline of 40%.  The Quinault has fallen from about 8,000 fish during the same period to about 5,000 fish today, a 40% decline.
WDFW and sport fishers must recognize that these coastal rivers are the last region where stocks are making escapements and can remain open to sport fishing.  Yet all the major coastal rivers show the same trend of declines of declining towards sub escapement goal levels and depletion in the near future.  Making these reasonably minor changes now to protect spawners can help divert the trend of declines and keep these rivers open to fishing.

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One Response

  1. McMac says:

    Desperate times call for desperate measures ! We can’t make everyone happy, but these proposals are needed. WA St is way behind on its WILD Steelhead laws ! Extinct is forever, so lets put the threatened Steelhead first.

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