Make sure to get your comments into WDFW regarding the 2010-2012 Rules Proposals-
Feel free to use any of the WSC comments.


Comments to the WDFW regarding the 2010/2012 Rule Proposals
From the Wild Steelhead Coalition

The Wild Steelhead Coalition (WSC) appreciates the opportunity to submit comments on the WDFW proposed recreational fisheries rule changes for years 2010 to 2012. We were pleased with all but one of the proposals and support their final approval by the Washington Fish and Wildlife Commission. With the failing condition of wild steelhead runs in virtually all rivers in Washington, we believe that the changes we support below are critically needed to aid recovery and prevent the few remaining healthy populations from becoming depleted. Our comments to proposal #23 request additional protection to wild salmonid fry, smolts and rainbow trout, the resident form of wild steelhead. We speak on record as being encouraged by the directions and steps taken by WDFW in this major rules cycle to protect and recover wild steelhead and support more restrictive regulations to further protect the diversity of both (anadromous and resident) forms of the species.

Proposal #23. Stream Strategy for Puget Sound and Straits.
This is the one proposal for wild steelhead that we do not support as written. The WSC has reviewed this proposal in a generic manner, as commenting on each proposed change would mean considerable redundancy. Many individuals and organizations, including the WSC, proposed selective fishing gear for all trout species and catch and release for rainbow trout (RTB). This enhanced protection is critically needed to protect juvenile wild steelhead, salmon and rainbow trout, the resident form of wild steelhead.

The WDFW Stream Strategies proposals in Appendix 1 for Puget Sound protect trout and juvenile wild salmonids only from February 16 to the closing date of the steelhead fishery (generally March 31) through selective gear and catch and release regulations. However the remainder of the season (generally June through February 15) the WDFW continues to allow harvest of 2 rainbow trout 14” or larger with all gear types as well as barbed hooks, which unfortunately continue to contribute a very high mortality rate of all small wild salmonids hooked and released (about 30%) and the continued harvest of needed rainbow trout spawners.

The WSC finds it scientifically enigmatic to understand why the WDFW can protect one form of steelhead trout, the anadromous steelhead, but continue to allow harvest of the other form, the resident rainbow trout. Both forms, by definition and taxonomy are classified as the same species, steelhead trout, Oncorhynchus mykiss, and are genetically the same in each watershed. Each form contributes to the abundance and productivity of the other form. The state of Washington should not follow the shallow Federal Governments political split of this species into “trout” and “anadromous” population units so they can be managed by two agencies; the state can be much more responsible to the species and its survival by managing these two forms as one integrated population. Rainbow trout, through participation in the late winter/spring spawning interactions of wild steelhead improve the success of fertilization of female steelhead, especially during April, May and June. During this period, male wild steelhead becomes depleted and the population is in part reliant on rainbow trout to provide the male partner for spawning.

Rainbow trout can be an important component in the recovery of wild steelhead stocks and the rebuilding of declining stocks. Steelhead and rainbow trout can produce independently the opposite form (i.e., rainbow trout can produce anadromous smolts, steelhead can produce resident fish). Rainbow trout can be the leading or single source of anadromous smolt production when the abundance of steelhead is depleted or extinct. This fact has been documented in several California rivers where steelhead stocks (example: Ventura River) were considered extinct. Wild steelhead returned many years after a river’s run was classified as extinct, and appeared to be the progeny of the river’s rainbow trout population. In consideration of the highly depleted condition of most Washington rivers, prudent management should strive to save all rainbow trout. Also, the WDFW does not have abundance estimates of the rainbow trout populations, due to budget restrictions, to understand their stock health or provide adequate management. Scientific recovery and stock protection procedures for both the anadromous form and the resident form should dictate the elimination of harvest of both forms in ESA listed rivers and of rainbow trout in the few remaining healthy rivers. Anything short of this will only inhibit and possibly prevent the recovery and rebuilding of wild steelhead stocks.

We encourage the WDFW to pursue stream management strategies that protect all juvenile wild salmonids and rainbow trout while continuing to allow selective fisheries for adult salmon and steelhead hatchery fish. We believe this is the direction the Stream Strategy section should take rather than the limited changes for rainbow trout protection proposed in Appendix 1. To accomplish this protection, the WSC proposes the use of one of the two following strategies:

1. Devise a hook size separation strategy and the use of selective gear which protects rainbow trout and wild salmonid juveniles. This proposal would allow hook sizes up to size 6 for all trout and require selective fishing gear as well as catch and release of all juvenile salmonids and all rainbow trout. Allow a minimum hook size (barbless would be best) of 1/0 (or possibly 2/0) and larger for adult steelhead and salmon fisheries. This would continue to allow the range in gear presently used including bait. The trout fishery could be set in a season of June through October to further reduce hook and release mortality which can be more than 30% with most gear types. These changes will save most juveniles and rainbow trout.

This change will promote rainbow trout as a sport CnR sport fishery. As larger rainbows are available through savings, we believe that a healthier population will develop that provides the diversity needed in steelhead trout spawning and an improved sport fishery for rainbows.

No strategy for achieving this management goal will be perfect or 100% enforceable but we think this one comes the closest to protecting rainbows and allowing other fisheries to continue. Given the very poor condition of steelhead runs in Puget Sound and the slow but steady decline of the runs on the coast, a management change that uses these types of gear and fishing opportunities is badly needed.

2. Require selective gear for all fisheries and catch and release of RBT with a June through October fishing season for RBT. This may be the easiest regulation (s) to enforce and simplest to apply.

Additional Comment: The stream Strategy Steelhead Status nomenclature does not often fit the streams. We recommend review of these before they are made permanent. We offer a few examples:

For the Skykomish River, the category needs to be moved to either D or more appropriately E given the current state of the steelhead runs and the fact that there is a high population of juvenile steelhead in the lower river during June and early July. This should include all stretches. It is interesting to note that the South Fork’s tributaries are listed as D but nothing else is. All areas of this watershed accessible to steelhead need to be D or E (for the selective gear rules).

Given the current state of the Snoqualmie River including its tributaries, the Tolt and the Raging, the category needs to be moved to E even though the Snoqualmie is already selective gear rules in the summer, if the state is going to follow the stream strategy, it should be classified as D or better yet E. It does not make any sense when you have various rivers like the Pratt which is a tributary to the MF of the Snoqualmie and natural barrier cuts it off from anadromous fish is listed as E and F which should be classified as D for sake of consistency.

Both Forks of the Stillaguamish River should be classified as E given the poor status of wild steelhead in the Stillaguamish and the need to limit harvest and the use of bait and barbed hooks to minimize the mortality on juvenile steelhead.

Proposal #25. Wild Steelhead Retention Seasons.
The WSC submitted this suggestion and continues to strongly support it. Rebuilding wild stocks will not be successful without recovering the early run component which has become badly depleted. The early runs were historically (pre 1960) very large and
probably constituted 40% to 50% (more or less) of the total run for most west side rivers (based on Washington Department of Game Bulletins). Today the early runs are nearly gone and must be rebuilt if total stock recovery and rebuilding has a chance of success. There will be opposition to this change, but it is clearly necessary and imperative to protect and recover wild steelhead. And we mention that there are good numbers of hatchery fish at this time of the year. We continue to support the use of barbless hooks during the entire winter steelhead season to improve the survival of wild fish released. This is analogous to ocean salmon fishing that improves survival of released salmon at sea and is also a proposal (#31) for the Columbia River.

Proposal #31. Columbia River Salmon and Steelhead—Single-Point Barbless Hooks.
We support this proposal to help eliminate snagging and promote higher survival rate of released wild fish.

Proposal 57-64. Closures of the Nooksack River, Pilchuck Creek, Pilchuck River, Raging River, Skykomish River, Snohomish River, Snoqualmie River and Stillaguamish River on February 15.
We support these proposals due to the depleted condition of wild steelhead.

#65. Skagit River.
We support the three changes described in the Statewide Rules proposals.

Below we commented on the proposals in the Stream Strategy Appendix which apply to additional closures of the Skagit River steelhead fishery.

Stream Strategy Appendix 1 proposals. Although these changes are difficult for steelhead fishers as they close selective gear fishing during the last month of the season, the last three years of low escapements indicate the need. The escapement to the Skagit River last year was only 2510 wild fish, far below the 6,000 wild fish escapement goal as well as the expected return. We further request the managers close the river to all steelhead and trout fishing during the proposed closures and not just the sport fishery. We further request that the river be closed all years when it is not projected to make 100% of its escapement goal, not the 80% level often managed for. This recognizes the serious threat to the stocks and should aid in the recovery process of the Skagit stock.

# 66. Green/Duwamish River Wild Steelhead. River
We support closure as the run to this river has continually declined over the last 6 or so years and last year the total run was only about 1/6 or the required escapement.

# 78. Hoko River and #80 Pysht River Wild Steelhead.
We support these closures to protect these small stocks and help assure continued depletion does not occur.

#82. Bogachiel River.
We support this proposal to protect juvenile wild salmonids from hooking mortality during the summer/fall fishing seasons. We request consideration be given to making this area catch and release for all trout species (or at a minimum RBT) during the rule change process next year.

##83. South Fork Calawah River.
We support with the same reasons and the same proposed changes for next year as for the Bogachiel River.

#84. Hoh River.
This proposal makes the Hoh River above the 101 Bridge catch and release selective gear rules for wild steelhead while two hatchery steelhead may be retained. Support. This is one of the WSC rule suggestions to establish ecosystem management to protect wild steelhead, and the juveniles and adults of all other species from further decline. However, it is not clear if this proposal closes harvest of RBT and other trout species to harvest, if not, we request it should.

#85. Sol Duc River.
Makes the section from the 101 Bridge downstream from Snyder Creek to the ONP catch and release and selective fishing, except two hatchery steelhead may be retained. First, we recommend that the area be described as “from the mouth of Snyder Creek to the ONP. This makes the description less confusing to all fishers, even though your area description has been used for many years.

We are not sure what change in season this proposal makes as this section of the Sol Duc River is already closed to wild steelhead harvest, selective fishing rules and closed to fishing October 31. It actually appears to be opening the area to fishing after October 31 which we strongly oppose. Please explain what this proposal is intended to change. This area was proposed as a WSMA two years ago to protect all juveniles and RBT and we continue to recommend this change. As with the Hoh River proposal, it is not clear if harvest of RBT is closed.

Other: Wild Salmonid Management Zones
A number of proposals were made on behalf of the Steelhead Summit Alliance members regarding Wild Salmonid Management Zones (WSMZ). The WSC continues to support the concept of WSMZ as these areas will provide ecosystem protection by supplying reserves for juvenile salmonids, resident rainbow trout and genetic protection of wild fish. We continue to request the WDFW and Commission to provide further attention to developing these areas to aid in recovery of listed stocks and rebuilding the last few remaining unlisted stocks. We urge WDFW and the Commission to make this priority as a step to help recover stocks and managing for abundance.

Thanks again and we appreciate the opportunity to participate in the process and look forward to continuous efforts by WDFW and state fishers to protect and enhance wild steelhead runs.

Respectfully Submitted,

Wild Steelhead Coalition


Richard Burge
VP Conservation


Richard Simms
President