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You still have the opportunity to comment on the WDFW Strategic Plan regarding wild fish.The comment period has been extended until August 6, so that will give everyone ample time to submit individual comments.


The following are the WSC comments that have been submitted, feel free to use the information to compose your own comments.

July 20, 2010

Re: WDFW 2011-2017 Strategic Plan

The Wild Steelhead Coalition and the Washington Council of Trout Unlimited appreciate the opportunity to comment and make recommendations for the new WDFW Strategic Plan. In general we agree with the materials in the basic draft and our suggestions are made to add a few significant concepts to the important priorities and help in the construction of goals and objectives.

Priorities and Initiatives

Achieving Healthy Rivers and Ecosystems:
We recommend adding this category as a top priority to this section.

Recovery of wild fish will depend on the actions taken to recover and preserve river basins and their historical ecosystems. Rivers are continually degraded by piecemeal actions that often are too numerous to monitor and stop. WDFW should seek legislative mandates to assure protection of all remaining river habitats, including the adjoining upland areas. Additional efforts should be made to preserve river corridors in regions where wild stocks will not be subjected to extreme impacts of climate change including flooding and high water temperatures this century. In this case we are suggesting that WDFW concentrate on saving the best habitats in regions that will have the lowest predicted impacts from climate change. We suggest reviewing the recent paper by Nate Mantua, et. al., 2010. (Climate change impacts on streamflow extremes and summertime stream temperatures and the possible consequence for freshwater salmon habitat in Washington State. Climate Change (Journal)) that discusses regional impacts in the Pacific Northwest.

Assuring healthy habitats and ecosystems in the future will require preservation of riverine habitats by establishing wide corridors adjacent to the river banks. These corridors will help reduce the impacts of climate change, eliminate other anthropogenic habitat damages, and, in time re-establish quality river ecosystems that can sustain and produce healthy wild stock runs. The present impacts of logging and agriculture, under existing rules and regulations, even in rural areas, will synergize with climate change and continue the destruction of the river ecosystems. We recommend the WDFW concentrate on preserving wild corridors (preferably in the dimensions of a ½ mile to a one mile on each side of the river similar to the one existing along the Queets River by the US Parks Department). Preservation and /or protection can be achieved through several acts and activities including the proposed Salmon Strongholds act, Wilderness Areas, National Parks, Wild and Scenic Areas and Conservancies. We suggest reviewing a paper by Richard Burge, 2010. (A PNW Option for Saving Wild Salmon and Steelhead). Osprey 66, May 2010) that discusses this approach. Where-as these designations will not be easy to achieve in many areas, there will be considerable fisher and environmentalist support and huge wild Salmonid benefits from establishing corridors through these methods.

In the category of "Recovering Salmon and Steelhead Populations" and other subsections as appropriate we recommend the WDFW note the importance of applying modern science and even cutting edge science to stock/DPS recovery, rebuilding and management programs. Due to the political framework that WDFW must work in, and the fact that managers often continue in the same management mode due to time, past experiences and historical limitations, we have noted that new science often takes several decades to be incorporated into management. We also suggest that WDFW perform evaluations on old scientific management practices that are presently in use. We suggest two examples: 1--developing ways to manage at very conservative Optimum Sustainable Yield concepts (OSY) rather than the historic form (basically near 60 years old) of Maximum Sustainable Yield (MSY) which as been found this last two decades to have far too many error factors (large management error, weather/ocean cycles, lost diversity and distribution, depleted stocks, etc.); and 2- past and recent research findings on hatchery production has often been suppressed by political and harvest demands favoring higher production. This has prevented improved hatchery practices and has, in many situations, caused increasing impacts to wild stocks.

A second recommendation for this category is noting the importance of recovering and managing wild salmonids through higher levels of the Viable Salmonid Population (VSP) parameters. VSP levels should include perspectives from the historical record on abundances, life history diversity and the distribution of wild fish.

The Category of Climate Change should include major objectives such as reducing the threats of flooding due to the already damaged condition of all Washington watersheds; and the synergism with logging, agriculture, etc with early winter large flash floods due to climate change. Impacts from flooding that must be avoided include loss of river meander, loss of large woody debris and its sources, loss of streamside shading, wider and less shaded river beds that increase water temperatures, narrower river channels that increase the flow velocities, and the loss of pools and riffles needed for nursery habitat and spawning.

In Renewing our Conservation Focus WDFW should provide information in this priority category on the importance of managing wild salmonids at elevated VSP levels to improve wild stock health, increase stock resilience and decrease the future potential of depletions from the uncertainty of riverine habitat impacts from climate change, natural environmental damages (as large landslides), extended periods of unproductive ocean conditions, past and ongoing hatchery impacts, cyclic management error and over harvests, and the impacts from mans activities. WDFW should also assure that correct management science is applied to harvest planning by completing all fisheries management plans before fishing.

The category of Managing and Reforming Hatcheries and Harvest might be split into two categories, given the importance of each. Under reforming hatcheries we again suggest the strategic plan draw attention to the literature and the new science that exists on subject. In particular, it is important to manage hatcheries to avoid introgression and loss of wild stock productivity, ecosystem imbalances (such as competition) and to avoid mixed stock fisheries which may cause the depletion of parts of annual runs which often have genetic differences from the other run components. The science on wild brood stock programs, both recovery and supplementation, is suggesting from most studies that these programs will cause further harm to wild stocks through the loss of productivity and diversity (genetic changes) and should be avoided at all junctions except where they may be the only way to save a badly depleted/endangered stock that is approaching extinction.

Harvest Reform should implant the idea of managing for conservation and for healthier stocks rather than immediate harvests that impede recovery or impact listed or declining stocks. We suggest in this priority that WDFW briefly discuss alternative methods to prosecute fisheries including the use of selective fishing and selective gear. As example, today most steelhead fishers prefer longer fishing opportunity instead of wild stock harvests and shorter seasons. There has been a loud public call for the release of wild steelhead to assure their continued health and provide the opportunity for stock rebuilding. This approach might be incorporated into salmon fishing as well where stocks are struggling to make their minimal required escapements and there is high fishing pressure on the runs.

2011-17 Agency Goals and Objectives

1. Conserve and protect native fish and wildlife

A. Improve conservation practices to enhance protection and restoration of fish and wildlife

• Given today's environmental, habitat, and weather uncertainties, Maximum Sustainable Fishing concepts should be replaced with new and more conservative management concepts that assure stocks will sustain and return to maximum health and productivity. WDFW will develop new harvest models that are based on very conservative Optimum Sustainable Yield concepts. These models should be (1) conservative in prescribing harvest levels, (2) designed to maintaining the VSP principles at their highest potential levels and (3) programmed to reduce or eliminate the errors of the present MSH models (management error, loss of diversity, flaws in the theory, including atmospheric and oceanic cycles, missing ecological needs, and ignoring historical abundances). Management error should be buffered and the incidental and illegal catches should be documented for modeling purposes. These models should have the ability to allow for further stock rebuilding as habitat is recovered. Models should be based on riverine productivity only (they should not include ocean survival in the spawner- recruit productivity ratios) to assure we are fully stocking all rivers to maximum juvenile capacity. Studies should be maintained on a long term scale to account for environmental variation. These activities should be planned and conducted with the co-managers (the Washington Tribes), if possible, to assure it has full support and interest in implementation.

• Preventing over harvests of wild fish should be a major goal of WDFW. Management plans for all steelhead and salmon fisheries should be completed before fishing to reduce management error and over harvests. These plans should assure equal state/tribal harvest allocations to assure more wild fish reach the spawning grounds from state savings, reduce the potential of over harvests and provide fish for a harvest buffer. Preventing over harvests should be a top priority of WDFW.

• WDFW will manage hatcheries conservatively to eliminate impacts to wild stocks based on the best available science. Where hatcheries are not productive, or having impacts on wild fish VSP parameters the department should close those hatcheries and use the hatchery budgets for improving wild stock management and recovering habitat. The hatchery reform recommendations, as suggested by the Hatchery Science Research Group, will be used for hatchery operations and facility changes. However, more recent science should govern decisions on hatchery operations. In areas where the hatchery or wild smolt survival to recruitment is low, WDFW will either eliminate or reduce the hatchery production to less than 50% to determine if the hatchery production has been too high and responsible for reducing the survival of hatchery and wild fish.

• Conduct a scientific review (possibly by the University of Washington researchers) of hatcheries and their importance and impacts to the past and future health and management of wild stocks. This review should include:
o Ability of hatcheries to replace wild fish populations and harvests lost to dams, diversions, and other environmental changes. (As these values on the Columbia River in the 20th and 21st centuries where dams have severely reduced natural production (how well have hatcheries actually performed in comparison to the original environmental conditions and stocks). This evaluation should show the present stock abundances (hatchery and wild) and potential harvests in comparison to those in a series of historical time scales.

o Effects on depleted wild populations after recovery hatcheries have recovered the stock and the hatchery production is then reduced or terminated (have they permanently recovered, or do they decline when the recovery hatchery is terminated). This study should evaluate the VSP parameters of the recovered stock over several generations,

o Biological impacts on wild stocks by both segregated and integrated hatcheries (including impacts to wild stock productivity, diversity, genetics and ecological needs)

o Impacts of mixed stock fisheries (hatchery and wild stocks at the same time and place) on the long term abundance and production of wild stocks.

• Develop management programs that protect juveniles and all life history forms of wild stocks using a system of closures, selective gear and CnR and education. As example, recovery of the early run of wild steelhead can, in time, potentially double the wild stock abundance in many rivers; providing protection of rainbow (steelhead) trout, steelhead parr and surviving spawners (kelts) in anadromous rivers improves the productivity of the stocks and can help in recovery efforts of depleted/listed populations.

• Investigate and publish the causes for decline of wild stocks as these are largely unknown (as example Puget Sound wild steelhead) or not well understood by the public. These studies should include changes in river and estuary habitat, changes in the receiving waters, pollution, climate changes, harvest, etc. The results of this investigation should be published in a form that is understandable to the public.

• Develop a system of Wild Salmonid Management Zones within each described population (as Distinct Population Segments) to protect and restore functioning ecosystems for wild anadromous and resident fish, the resident aquatic species and all of the populations that depend on a healthy river ecosystems.

• Develop a plan to protect and manage wild fish and their habitats in response to climate change. This plan should address the needs to recover and protect wild fish habitats, manage more conservatively to assure maintaining peak values of the VSP principles, and assure that anthropogenic activities are contained within the needs of the riverine habitats and the native fish and wildlife.

B. Increase protection and restoration of ecosystem functions.
The key to recovering and maintaining healthy wild stock populations is through the protection and restoration of their riverine habitats and adjoining terrestrial zones. It must be recognized that WDFW cannot alone win the political and social battles to restore and protect these habitats (as example, the logging, agriculture, grazing, development and other industries have far too much collective power and are generally successful in tailoring regulations to fit their needs). For this reason, we recommend WDFW take two avenues to the protection of fish and wildlife habitats:

• Recover damaged habitats that are of high priority and key to wild stock recovery and productivity. The department will assure that all components of rivers systems are addressed so that missed links do not occur; beyond the needs of the rivers, estuary and receiving waters are also important to restore. The department will first place its highest priorities on watersheds that have the highest probability of successful recovery. Monitoring of the recovery actions and wild stock response will help determine how these actions can be improved and applied to other river systems.

• Establish river corridor preserves on all productive rivers through joint efforts with other state and federal agencies, and through conservation and conservancy programs that advocate for increased river protection. Buffers should be designed much wider than earlier science has suggested (as example the FEMAT Study, the Man Tech study, the State Timber, Forest and Fish Report) due to the increasing impacts of climate change. Recent studies have suggested we may only hold on to the fish abundances that exist following habitat recovery (see Battin, et. al., 2007. Projected Impacts of Climate Change on Salmon Habitat Restoration. National Academy of Sciences, 2007).
River buffers can be proposed for federal legislation under the proposed Salmon Strongholds Act; the Wild and Scenic, Wilderness Areas and the National Parks existing Acts; and by Conservancies. Buffers can also be proposed by concurring state agencies (such as WDFW, DNR, and DOE) on state lands and state/federal agencies on federal lands. These avenues should propose methods to establish wide buffers (of up to ½ mile to 1 mile wide) that will provide the future protection that rivers and wild fish need to survive climate change and future anthropogenic activities (see Burge, 2010. A PNW Option for Saving Wild Salmon and Steelhead. Osprey 66 May 2010) in the 21st Century.

• WDFW should also seek legislation to improve their regulatory authority under the Hydraulic Project Approval (HPA) State Act that now provides some limited authority to control in-river activities. New legislation should give the WDFW the power to set riverine and terrestrial protection rules and regulations for timber harvest, farming practices, shoreline development, discharges and all in-river and stream bank alterations..

C. Promote and improve compliance with natural resources laws.

• Violations of harvest and gear rules can have a major impact on wild stock health and sustainability. WDFW and the legislature should develop harsher penalties for commercial and recreational violations based on the impact of the violation. As example, illegal harvest of wild stocks should be considered a more severe violation than harvest of hatchery fish. Anyone taking a wild fish (including a juvenile or protected rainbow trout) in violation of the law should be subject to the same penalties as a hunter that takes a big game animal during the closed season or the fisher that takes a threatened or endangered species. Eyes in the Woods/Stream Watch volunteers should be made available for observations on all rivers. WDFW could encourage this program through established fishing organizations. Each river might have a designated "stream watch officer" who would be the main contact for the public and with wildlife officers.
2. Provide sustainable fishing, hunting and other wildlife related recreational experiences.

A. Increase the economic benefits and public participation derived from sustainable fish and wildlife opportunities.

• WDFW should increase their management tools necessary to maintain and lengthen fishing seasons. These should include lower harvest limits, limitations on the annual take of each species (as example, salmon could have a 10 or 15 combined salmon limit yearly, and Halibut to 5 or 6, each coupled with catch and release fishing so that fishing opportunity continues until the yearly limit is reached); Catch and Release fishing for some species either in extra seasons, or during the established season, to allow additional fishing time; fewer days per week or month, etc. These tools could also be used to maintain conservative fisheries for species that are regionally listed or are in decline.

o Longer steelhead seasons can be offered using the states existing allocations or more conservative harvest regulations during the present season.

B. Expand access for fishing, hunting and other recreational opportunities.

• River access is severely limited in many areas, harming conservation goals. An example is the excellent hatchery runs in the Salmon River, tributary to the Queets River that has limited access due to tribal ownership. Opening this river to fishing would accomplish conservation as well as access objectives. Harvest of these hatchery fish is important to conserving wild stocks and may also shift effort away from other wild stock fisheries on the coast.

Respectively Submitted,

Wild Steelhead Coalition

Rich Simms

Richard Burge
VP of Conservation

Washington Council Trout Unlimited

Tom Van Gelder
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