Wishin there were fish
Sorry, I did not mean to jump down your throat, after writting several letters to the WDFW I was feeling a litlle grouchy. As I am sure you realise we all need to support these reg changes as they are a step in the right direction.
You bring up some good points about hatchery fish and wild fish inter-breading, which weakens the gene pool. These fish are genectically different from the pure native strain but it would take a lot of scientific testing to determine the differnce. The hatchery stocks in WA are not usually taken from native brood stock though. Most hatchery steelhead are Skamania stock fish from the White Salmon area of Washington (these seem to be a hearty strain and are also used in the great lakes region aka steelhead alley).
As for TU I feel your frustration. The people on the WA council really care about our fisheries but the organization runs mostly on volunteer support. With out that support they can only do so much, so I urge you to get involved. TU has done great things in many states and will do the same in Washington. Right now I am working with the WC of TU to get the Bellevue-Issaquah Chapter reactivated. With over 300 members it is a huge group of anglers that could make a real difference improving local fisheries, from stream restoration to policy changes.
Here is a rather long policy proposal the Washington Council of TU is sending to the state. It includes requiring hatcheries to use broodstock to re-populate runs. I think you will agree this is another step in the right direction
THE WASHINGTON COUNCIL OF TROUT UNLIMITED
WILD STEELHEAD CONSERVATION POLICY, 2001
"We regulate our fisheries… but we concentrate them on the best races, and one by one these shrink or vanish, and we don't even follow their fate… knowing only that our total catches diminish, as one by one small populations disappear unnoticed from the greater mixtures that we fish… so we greatly underestimate what is needed or when it is needed and feel self-righteous about our conservation."
W. F. Thompson, l965
Wild steelhead yield and escapement estimates in practice today have not protected most stocks from population depression. Additional research is needed to determine new management criteria that will conserve wild runs in all Washington waters. Maximum Sustained Yield (MSY) calculations and annual run size estimates should be used in the future only if they consider watershed ecology, improved determinations of freshwater carrying capacity for each river system and its tributaries, variations in oceanic and freshwater conditions, and the impacts of hatcheries on wild fish survival. These factors, along with new research on stock dynamics and improved escapement and harvest estimates, are essential in developing a new management regime to protect and conserve wild fish.
The concept of harvest goals should be based on a conservation ethic that provides protection to wild fish first and allows a yield only when all risks of over harvest have been minimized and all benefits of stock rebuilding have been satisfied. The Washington Council - Trout Unlimited (WC-TU) recommends moving away from MSY and toward a policy of Maximum Carrying Capacity if we are to restore and maintain healthy wild steelhead populations in all Washington River systems. Additionally, a new management model should incorporate additional risk factors that err on the side of wild fish.
To provide the time to accomplish the suggested research and develop new management models, WC-TU recommends an 8-year moratorium on the harvest of wild fish in all state waters.
WC-TU expresses its interest in working with co-managers and the State Legislature to obtain the funding needed to improve wild steelhead management and the enforcement needed to recover and properly manage these treasured native fish.
The 20th Century saw significant general declines in salmonid stocks throughout the Northwest with many factors to blame. These declines occurred despite the fact that the region maintained the nation's largest system of hatcheries to supplement harvest opportunities and wild runs. Washington's more recent salmon recovery efforts, albeit late and in reaction to ESA listings, are nonetheless admirable and should benefit steelhead as well. However, steelhead still take a back seat to the more visible salmon. Wild steelhead, a native northwest treasure, also deserve dedicated attention to their needs. The Washington Council of Trout Unlimited (WC-TU) expresses its interest in taking an active role in working with the co-managers and the state legislature to obtain the funding to improve wild steelhead management and enforcement needed to recover and properly manage these native fish.
WC-TU has reviewed the status of steelhead as we enter this new century, particularly the state of the irreplaceable wild stocks, and has drafted this policy statement for internal and external guidance in managing and conserving this valuable species in Washington State. This document stresses the importance of developing accurate scientific data for modeling and managing wild steelhead.
This policy contains five elements. Each is deemed by this organization to be vital to the recovery of depressed stocks and the future conservation of and fishing opportunities for wild steelhead. The five integral elements include: (1) habitat protection, (2) enforcement, (3) conservation goals, (4) hatchery production, and (5) catch policy. The reader will recognize that the elements are general with limited detail, as a complete plan would require preparation by scientists from many disciplines. However, the intent is to recognize the important needs of wild steelhead and outline the major steps needed for improved conservation. WC-TU believes a complete review of the state's wild steelhead management program is necessary based on the declining stocks. The present co-management program is not providing annual harvest production from many rivers and considerable new information has become available on hatchery fish impacts, habitat protection, population genetics, watershed ecology, and natural environmental variation since the publication of the harvest model presently used.
As the co-managers have stressed in recent years, river habitat (spawning and rearing) is a key factor to the health of salmonid stocks. We concur that habitat recovery and preservation is vital to the recovery of wild steelhead stocks in concert with the other solutions outlined herein.
There are many types of detrimental impacts to salmonid habitat that have long been identified but are still ignored or too laxly permitted. Stronger controls and multi-agency enforcement are necessary in land and water use, logging, agriculture and livestock husbandry, growth and development, mining, and the unpermitted private abuses of the riparian zone. A continued human influx (an additional one million people by 2020) must be anticipated and planned for to assure continued habitat protection for fish, and our quality of life.
A multitude of land use activities, statewide, have had deleterious effects on essential salmonid habitats, in the fishes' various life history stages. These are in spite of a number of federal and state laws and policies such as ESA, CWA, GMA, CZM, NEPA, SEPA, Shorelines Management Act and forestry agreements. Some of these acts and agreements have been effective, but many have not. Significant multi-agency involvement and coordination is required to ensure the enforcement and compliance of these mandates.
Impacts from logging practices, even decades ago, still plague riparian areas. We see this continuing from steep slope cutting, sediment transport, temperature increases, and lost buffer zones. The science associated with the monitoring of these activities must be developed through an adaptive management process between state and federal agencies, the tribes and the conservation/environmental community.
Water and land use activities from agriculture and livestock significantly impact salmonid survival. Diversion of water from river systems for irrigated land causes untold mortalities. Water quality degradation continues from uncontrolled overgrazing and a range of TMDL implications that are not enforced, while fertilizers and pesticides further threaten the fish as well as human health.
Growth and development has clearly had negative impacts on our fish. Examples are in unnatural stormwater flows, permanently altered hydrology of watersheds, point and non-point pollution, and the practice of "exempt wells." Transportation priorities, paving of land and even streams, and clearings of riparian zones add to the loss of fish.
Dams have severely damaged habitat and blocked upstream migration to spawning and rearing areas as well as providing high mortality barriers to downstream bound steelhead. Violations of contractual agreements with hydropower companies and other holders of dam operations licenses , such as the usurping of minimum flow agreements, have continued to plague wild fish populations. These avoidable violations need to be dealt with in the strictest terms and need to be addressed both by the courts and in the dam relicensing process.
Other man-made fish barriers continue to block thousands of miles of historical stream habitat. With the current limited attention and funding for the replacement of poorly designed culverts, it will take decades to open these waters that wild fish once used for spawning and rearing. The priority and funding must be raised to bring back this habitat for all salmonids. We applaud the removal of such barriers as the Elwha and Condit Dams and encourage more removals wherever feasible. Each additional mile of accessible stream will lead to additional adult returns, regardless of the management model used.
As with many issues, citizen, governmental and industry education is lacking in the realm of the steelhead. It must be expanded and improved to ensure due respect and concern for this species.
The most critical element of wild steelhead recovery is protection of the remaining stocks by the co-managers. This protection is generally accomplished through a scientifically based set of rules designed to protect the species. The importance of protecting depleted fish stocks in a recovery mode cannot be overstated. It is the fundamental building block for recovery.
Wild steelhead are highly vulnerable to unlawful harvest due to a disregard for the regulations and the circumstances under which they are taken. Many Washington rivers are isolated from the view of officers and sport fishers, creating many illegal opportunities for those who disregard conservation regulations. The amount of illegal harvest is impossible to quantify and remains unknown, but is believed to be significantly high. The goal of enforcement in rebuilding the wild steelhead populations should be to protect wild stocks to the highest practical level. This protection can be accomplished by placing officer emphasis on the following enforcement strategies:
1. Create a highly visible presence on the state's rivers to deter the breaking of regulations designed to protect wild steelhead, with an emphasis on unlawful harvest.
2. Conduct frequent random patrols by out-of-uniform officers posing as fishers, by boat and on foot, to identify and arrest those who flagrantly disregard the harvest regulations. An emphasis should be placed on prosecuting to the full extent of the law those who flagrantly violate the rules designed to protect critical wild stocks. Violators' names should be published in newspapers.
3. Establish an effective statewide crime reporting system based in the communities and conservation organizations that would facilitate the reporting of unlawful harvest of wild steelhead and other resources. This will increase the effectiveness and efficiency of individuals that are dedicated to conserve our fish resources. This statewide program should be modeled after a Neighborhood Watch concept, or the "Eyes in the Woods" program already begun with hunters.
4. Create a reward system similar to that in use in the big game program of the Washington Department of Fish and Wildlife (WDFW) for those who turn in the most serious violators.
5. Emphasize the accurate and timely reporting of catch data from commercial and sport fisheries.
6. Emphasize habitat protection not only by enforcing the provisions of the HPA's, but also through random patrolling of habitat sensitive wild steelhead spawning and rearing areas to locate habitat violations so that they may be corrected at the earliest possible time and/or prosecuted to the appropriate degree.
7. Establish a friendly and professional relationship with local community based conservation organizations to educate and promote a conservation ethic throughout the state.
The concept of harvest goals should be based on a conservation ethic that provides maximum protection to wild fish first, and allows a yield only when all risks of over-harvest have been minimized and all benefits of stock rebuilding have been satisfied. The existing harvest goal, Maximum Sustainable Yield (MSY), infers that the maximum harvest must be extracted from a population, based on average modeled returns of past generations. The model and run predictions do not adequately take into account the years (and especially the periods of successive generations) when poor environmental conditions drive the returning run below the expected average. The model also does not consider the impacts of hatchery production, the needs of the ecosystem, or the many other factors that can cause an over-harvest. The failure of so many runs in Puget Sound, Hood Canal, and the Strait of Juan de Fuca suggests the present MSY model is far too simplistic, is erring on the side of harvest, and is not conserving the wild steelhead stocks.
A harvest management policy for wild steelhead should never place the population(s) at risk of low spawner return or extinction. A new concept for harvest management needs to be developed by the co-managers that assures spawner escapement will: (1) have the potential to increase wild populations to historical run sizes, (2) maintain full wild steelhead juvenile carrying capacity of the watershed, and (3) meet the ecological needs of the watershed. Further, any escapement goal should always err on the side of the wild population and future spawner returns. As an example, Oregon has adopted the policy of "Maximum Spawner Escapement" through (but not limited to) catch and release only fisheries in most cases. It is Oregon's intent to totally remove any risk of extinction and to provide maximum fishing opportunity to its public. TU recommends a new conservation policy for wild steelhead in Washington waters of maintaining "Maximum Carrying Capacity." Wild steelhead should be managed to meet this policy in terms of both spawner escapement and maximum juvenile carrying capacity.
A new model, if one is used in the future by the co-managers, should include not only the existing population dynamics data of wild fish in fresh water, but also include:
1. A new evaluation of the fresh water carrying capacity of each river and all tributaries to that river. Fish runs in some rivers should be allowed to exceed the equilibrium point to test the presently accepted carrying capacity. Carrying capacity should be periodically evaluated for each river as habitat improvements are made.
2. Annual variations in the freshwater habitat of each river system including flow, flooding or drought, and man-made changes (both detrimental and improvements).
3. Annual/temporal variations in ocean conditions and smolt/juvenile fish survival in salt water.
4. Developing methods and necessary enforcement to accurately account for all the sport and commercial catch by river and fishery. Each year the co-managers should produce a standardized statewide report showing the run reconstruction for wild and hatchery steelhead in all rivers where data is available. This report should include wild steelhead total run size, escapement, and state and tribal harvest. The same information should be included for hatchery fish.
5. Improved estimates of the wild fish escapement and spawning/egg survival success.
6. The impacts of hatchery production on wild fish by river/tributary and stock.
7. Assurance that the full ecological needs of the watershed are met. This task should include information on marine derived nutrients, nutrient cycling, and the value of fish carcasses to the biota of the watershed and to increasing wild fish fresh water carrying capacity.
8. An adjustment for the unknown or unforeseen (such as poor environmental conditions) that errs on the side of the fish population(s).
9. Methods to restore genetic and life history diversity (age/size/sex structure, run timing, etc.).
Traditional management models require accurate annual run predictions for each river and its tributaries to allow for proper harvest planning. The methodology requires models or accurate estimators that incorporate the information listed above as essential for a harvest model. Incorporating information such as ocean and freshwater conditions during the spawning and out-migrating years will allow these predictions to better protect wild fish. However, all of the above mentioned information is necessary to assure accurate predictions of the annual runs in each river system. These approaches have generally failed everywhere they have been applied because the science of environmental prediction and fish ecology is not advanced enough to accurately monitor or predict all the relevant factors required to make deterministic production and harvest models work.
This situation begs the question of the value of continuing the use of deterministic harvest models. An alternative approach would accept the lack of predictability of annual fish returns, expand efforts to conduct in-season monitoring of target stocks, and simply manage stocks conservatively enough that risks to over harvest are minimized. Such an approach would be consistent with a new goal of Maximum Carrying Capacity for wild steelhead.
There has been a general decline in wild steelhead stocks throughout the Pacific Northwest in the last century that is not well understood. The run size data suggests that rivers entering or close to the Pacific Ocean have responded best to modern management practices while those entering Puget Sound and tributaries to the Columbia River have experienced the largest stock declines. The co-managers need to investigate the reasons for these declines to better understand how to recover depressed stocks. Investigators should include rivers that are not responding to intensive management such as full closures or wild steelhead release.
WC-TU believes that the use of selective fishing techniques is one of the most important components needed to achieve restoration of wild steelhead in the State of Washington. WC-TU fully respects the treaty harvest rights that are accorded the treaty tribes by the 19th century treaties between the tribes and the federal government. We recognize the co-management rights and authorities of the federal, state and tribal governments. Co-managers are strongly encouraged to establish selective gear requirements for all fisheries.
Hatcheries have often been blamed for reducing wild steelhead and salmon diversity and productivity. This is due in part to the increased fishing pressure they have generated, the concept that they would mitigate for lost wild fish production due to river diversions and impoundment systems, and the adverse impacts they have on wild fish production and survival. Conversely, we now recognize that hatchery production can have positive values in the future if administered in a scientifically sound and closely monitored program. These include broodstock programs that may be capable of re-establishing wild runs, and supplementing wild runs where they are depleted. Today, hatchery fish also help take some harvest pressure off wild fish by providing hatchery fish opportunity and catch to commercial and sport fisheries.
Because the state is improving the science and policies of hatchery steelhead use and production, WC-TU supports hatchery reform efforts which will develop scientifically appropriate maintenance and operation of the co-manager's hatchery programs. However, WC-TU believes these efforts should be applied only where they do not significantly impact the present and future production and recovery of wild fish. To assure hatchery fish can be fully utilized, to have the ability to separate them from wild fish in fisheries and to reduce their impacts on wild fish, WC-TU strongly supports the need for all co-managers to visibly mark (such as adipose fin removal) all hatchery produced steelhead.
To prevent undesirable genetic transfer and crosses, hatchery fish should be planted only in their river of origin.
To provide adequate time necessary to accomplish a thorough evaluation of the department's wild steelhead management policy and program, WC-TU suggests a minimum 8-year moratorium (a period that approximates two generations) on the harvest of wild steelhead. All wild steelhead should be released immediately without removing any body parts or inflicting any harm to the fish. The 8-year period would provide time to review and conduct new research to improve stock conservation and production. It would further allow time to study the biological and sociological effects of wild steelhead release. The moratorium should be monitored to determine its effect on rebuilding depressed stocks including summer, early and later winter, and spring runs. A fisher survey at term is recommended to determine angler interest in continuing the release of wild fish.
On rivers where escapement goals are not projected to be met, stronger fishing restrictions designed to protect recovering wild stocks need to be implemented. In planning a fishery, WDFW should consider not only the winter run (March/April/May returning spawners), but also the historical runs that returned during the summer, fall, and late spring for each river and its tributaries. The normal resiliency of low populations should not be considered a reason to open a fishery, as poor environmental conditions may drive the survival of recruits far lower than predictions of the model.
The Washington Council - Trout Unlimited recognizes, as does the scientific community, that there is a long term declining trend in wild winter steelhead populations from California to Alaska. The factors of decline are variable and complex. Many of the factors are identified in this policy document. There is tremendous need for additional information on the life histories of steelhead and the critical impacts which the 4 H's have on these Northwest treasures. It is and has been our organization's basic view that fisheries should be managed for the resource, not for harvest. It is for this reason that we submit this document to the Washington State Fish and Wildlife Commission for its consideration.
It is our hope that the Commission will use our "Wild Steelhead Policy" document as a resource tool. This document was developed to assist the commissioners in their deliberations to potentially develop a public policy which will be grounded in current scientific understanding of the status and needs of wild steelhead in Washington State. This public policy must also be validated by intensive monitoring to assess the proposed impacts to the steelhead resource. It is our hope that this document will assist the Commission in charting a new course in the management of Washington's steelhead resources.