WSC's letter to NOAA re: Col. River - Fly Fishing Forum
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Old 03-17-2004, 11:25 PM
Todd Ripley Todd Ripley is offline
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Join Date: Feb 2001
Location: Seattle, WA
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WSC's letter to NOAA re: Col. River

Here's the letter that the WSC sent to NOAA Fisheries, WDFW, and ODFW regarding the tangle net commercial spring chinook fishery on the Columbia River.

It's a pretty long read, but there's lots of good stuff in there. The addresses usually get mucked up when you post stuff like this here on the BB, but you should be able to figure out who it went to anyway. Check it out...


March 12, 2004

TO: Peter Dygart, NMFS Dr. Jeff Koenings, WDFW
Bob Lohn, NMFS Bill Tweit, WDFW
7600 Sand Pt. Way 600 Capital Way
Seattle, WA 98115-0070 Olympia, WA 98501

Lee Van Tussenbrook, WDFW Will Roehl, Chair
Cindy LeFleur, WDFW WDFW Commission
2108 Grand Blvd. 600 Capital Way
Vancouver, WA 98661 Olympia, WA 98501

Lindsay Ball, WDFW John Esler, Chair
Steve King, ODFW ODFW Commission
3406 Cherry Ave. NE 3406 Cherry Ave. NE
Salem, OR 97303 Salem, OR 97303

FROM: The Wild Steelhead Coalition
Rich Simms, President
Todd Ripley, VP Political Affairs
218 Main St., Suite 264
Kirkland, WA 98033

RE: 2004-2006 Columbia River Commercial Fishery ESA Impacts

Ladies and Gentlemen:

The states of Washington and Oregon have requested that NOAA Fisheries approve a three-fold increase in the allowable ESA impacts on listed steelhead in the Columbia River during the commercial spring Chinook fishery. This proposal is sought to provide the commercial gillnet fishery with greater access to harvestable spring Chinook in the lower Columbia River.

Last year this “tangle net” fishery proved to be extremely non-selective. Only one in three fish actually caught in the gillnets was a targeted hatchery spring Chinook. The other two were ESA listed wild steelhead and spring Chinook. Untold thousands of these ESA listed fish were both directly and indirectly killed in this fishery.

The current proposal requests an unacceptable amount of bycatch of ESA listed steelhead and spring Chinook for a relatively small increase in harvest for lower Columbia River gillnetters. It is our firm belief that there are much more sensible and profitable approaches for both increasing the commercial harvest of surplus hatchery spring Chinook and increasing the protection of ESA listed salmonids in the lower Columbia River. Specifically, selective fisheries utilizing such existing technology as the fish ladders at Bonneville Dam, fish traps or fish wheels offer a proven means for commercial fishers to obtain their full allocation of surplus hatchery fish while having minimal impact on ESA listed species. Surely the agencies and industry can see the broad suite of benefits that will come from adopting fully selective fisheries in the Lower Columbia River, and the broad suite of problems that come with clinging onto the non-selective fisheries of the past. The bottom line here is that the tangle nets have proven unable to deliver selective fisheries, and there is no justification for this request other than to threaten ESA recovery for extremely limited benefits to the commercial fishers.

If NOAA Fisheries agrees to consider this request, at the very least the Columbia River Commercial Fishery Biological Opinion must be re-opened. The short and long term effects must be examined to determine exactly what damage would be done to ESA recovery in the Columbia River. This would take several months to conduct. Contrary to Dr. Koenings’ comments at the WDFW Commission meeting in Olympia on January 17, 2004, it is clear that the states have requested that NOAA Fisheries approve this increase in ESA impacts in time to utilize them during the 2004 season, which could not be done if a thorough examination of the BiOp were to be done. This is clearly not the proper process to approve a threefold increase in ESA impacts.

In the days before the January 17 WDFW Commission meeting (of which the conservation, recreation, and sportfishing communities were give three days notice), I spoke with Dan Rawdings, WDFW Reg. 5 Biologist. When WDFW harvest managers asked him to comment on the proposed increase, Mr. Rawdings’ report stated that such an increase would jeopardize the existence of the ESA listed Toutle River wild steelhead. Mr. Rawdings supplied these comments to the harvest managers back in mid-December of last year.

By the late 1980’s and early 1990’s, Toutle River wild steelhead had rebounded from almost total decimation after the 1980 eruption of Mt. St. Helens. Subsequently, thousands of hatchery Coho and summer steelhead smolts were planted in the Toutle system, and the wild steelhead are back at a very depressed state. With the current request for increased bycatch, Columbia River harvest managers are going against their own biologists’ recommendations and are further endangering the Toutle River’s wild steelhead.

In recent years lower Columbia Basin wild steelhead populations have barely replaced themselves. Any increase in their harvest, be it targeted or as incidental commercial bycatch, would presumably drop these populations below replacement levels. This is unacceptable.

The State of Washington has just passed a recreational wild steelhead harvest moratorium in an effort to protect the wild steelhead in Washington State. Actions such as these run counter to this responsible response to dwindling steelhead populations.

In the past this tangle net fishery has greatly exceeded its allotted impacts, even overshooting the allocation by 700% in 2002. While the only way to assure that this doesn’t happen again is to have reliable observation and reporting on the commercial fisheries, recent reports show that many of the commercial fishermen are refusing to let observers even board their vessels, much less observe the amount of bycatch and use of recovery boxes that these fishermen are supposed to be using. If there is no observer data for this fishery because of the commercial fisher’s refusal to allow monitoring of their bycatch, then the chance to overharvest is not only increased, but is likely.

While it is well known that the second largest run of hatchery spring Chinook ever for the Columbia River is projected this spring, and that the commercial fishing industry and the WDFW/ODFW harvest managers want to maximize the commercial gillnetters access to those fish, ESA impacts should not be set by the amount of fish that the departments want to harvest.

Rather, harvest should be set by the amount of impact ESA listed fish can actually take while continuing and furthering ESA recovery. The Wild Steelhead Coalition submits that this impact cannot be measured without re-opening the BiOp, and further submits that any plan that includes the known extinction of a run of wild steelhead, while also threatening to push the entire lower Columbia Basin ESU below replacement levels, is a fishery plan that subverts the entire recovery process for the various ESA listed Columbia River to the relatively small benefit of a few commercial fishermen.

While specifically noting in the states’ request that they are not advocating the removal of the lower Columbia River wild steelhead from the endangered species list, the states essentially then claim that all the requirements to do so have been met, and that the commercial fishery ought to go forward as if there were no ESA restrictions upon them. If the states wish to couch their request with such strategies, then they should go through the ESA procedures to de-list “recovered” species.

Furthermore, continually referring to this fishery as an experimental fishery designed to measure the impacts of various selective fishery techniques is disingenuous. This fishery utilizes one technique, that of gillnets and recovery boxes. This is a full-fleet fishery that is being used to harvest fish, not a limited fishery used to measure impacts of various different fishing techniques to arrive at conclusions about how to effectively harvest hatchery Chinook without unnecessarily impacting ESA listed steelhead and salmon.

In effect, the states are saying that this fishery is unable to be prosecuted to the extent that the fishing industry would like without an increase in ESA impacts. Again, this is not an experimental fishery; it is a fishery that the gillnetters are asking to prosecute even though they know it cannot be done consistent with ESA recovery of listed stocks. Rather than improve their fishing techniques to have less ESA impacts, they are asking to lower the bar to make their fishery consistent with recovery.

Recovery of listed steelhead stocks should be the first priority of the Endangered Species office. In consideration that environmental conditions, including oceanic, change through time and area, the fastest recovery should be paramount to all considerations of anthromorphic impacts. As example, ocean conditions now favor wild steelhead productivity in the Columbia River and its tributaries, and hence survival, but that improved productivity should not be afforded to improve commercial fisheries through higher and unacceptable impacts.

The BA does not model or predict recovery times for the listed stocks. These periods, based on average intrinsic productivity and or S/R analysis, must be understood to evaluate any proposed fisheries impacts. The BA must be considered insufficient until these recovery periods are understood. Recovery times should be modeled and made available for each proposed impact rate. Managers, fishers, and conservations should have this information before making decisions and comments on commercial or sport fisheries and their impacts on recovery.

Impacts must be based on the weakest stock(s) and their intrinsic productivity potential and recovery times. The BA appears to base decisions on the average stock condition and omits the potential of some stocks failing or recovering too slow to be complete before the next low productive marine conditions arrive. This approach may allow some stocks to fail and/or move towards extinction when marine productivity falls. Clearly, all stocks must be treated in a "best" recovery status or we will otherwise allow one stock at a time to fail. The BA further largely ignores the 95% confidence interval of the intrinsic productivity estimates and several stocks in the Lower Columbia ESU show estimates that fall well below replacement. For recovery purposes it would be prudent to take a conservative approach and base impacts on the lower values and not on the averages.

Recommendations in the BA should therefore be based on allowing the best recovery potential for the Lower Columbia River and those specific stocks exhibiting the lowest intrinsic productivity and most likely to fail. We therefore recommend basing all impacts on the best recovery opportunities of the weakest stocks of this ESU, the NF Toutle River.

It is our understanding the impacts are based substantially on fish brought aboard and do not include a drop-out rate, nor does it evaluate the mortality due to predation from seals and sea lions on fish caught in the nets. The BA should estimate additional impact/mortality rates and include these rates with the known mortality rate. The monitors should apply special importance to this impact, and attempt to make counts and estimates during on-board sampling/monitoring. Because it is certain that the rate is higher than can be observed, the BA should apply an inflationary figure to the estimate. No fishery should be prosecuted until this estimate is added to the impact rate, unless a conservative (conservative for fish survival) estimate is included in the impacts while the actual is studied.

Escapement and mortality impacts must be determined for the listed Middle Columbia ESU. The Recovery Office should not agree to any fishery until impacts to this ESU are fully understood.

The BA does not list escapement goals for the rivers/stocks discussed. Neither managers nor reviewers can evaluate short or long term impacts to the recovery of stocks if these goals are omitted. If they have not been previously determined, they must be modeled through use of modern models before any consideration is given to increasing impacts.

Many of the present intrinsic productivity estimates fall below acceptable levels. At reduced population levels, the Ricker alpha parameter, or the intrinsic productivity as used in the BA, should equal 2.0 and higher for all populations. Stocks below this value are experiencing serious difficulty in recovery, especially during this period of higher marine productivity. Managers should investigate the reasons for productivity below the low intrinsic productivity levels and better understand the steps necessary to improve recovery. The suggestions in the BA that populations above a productivity level of 1.0 show the ability to increase at low levels is misleading for recovery purposes. Population increases should be at a high during this improved marine productivity period.
Afterwards, the intrinsic productivity may well fall below 1.0, an unacceptable situation. Populations must be allowed to fully recover and build some reservoir
numbers above escapement goals during this marine period to hedge against low productivity and decreasing populations during the next low marine productivity period. Long term/permanent recovery should be managers’ goal, not short term in-and-out of recovery status based on ocean and riverine productivity oscillations and variations.

Finally, wild steelhead have an important purpose of producing wild fish for sport fisheries. Throughout the state, most ESU’s are listed, critically under escaped, or in decline. The healthiest stocks are in the Olympic Peninsula, yet all rivers/stocks except for one are in decline since their mid-1990s peaks. Due to many factors, including listings and poor escapements in non-listed ESU’s, the sport landings of wild steelhead have fallen consistently over the years. They have been in a steady decline since the mid 50’s and have fallen from 60K to 90K per year to 3,500 last year. Further, sport fisheries on listed rivers are limited to periods of hatchery fish runs. Seasons and catches have been seriously curtailed to recover these fish. The gains in recovery of these stocks due to sportfishing sacrifices should not be given to commercial fisheries, especially when stocks are protected for recovery purposes.

The Wild Steelhead Coalition respectfully requests that WDFW and ODFW withdraw this request, and that if the states do not withdraw the request, that NOAA Fisheries reject it. The WSC further requests that if the WDFW and/or ODFW Commissions receive requests from ODFW or WDFW to adopt such a request, that the Commissions also reject it.

If this request does go forward, the Wild Steelhead Coalition further requests that an appropriate time for public comment and analysis of any requests or revised BiOps be provided, and that no actions be taken until such public comment has been provided.

Thank you to all of you for your time and consideration in this matter, and for your commitment to furthering and aiding the recovery of depressed anadromous fish runs in the Columbia River and in the states of Washington and Oregon.


Todd A. Ripley
VP Political Affairs
Wild Steelhead Coalition

Rich Simms
Wild Steelhead Coalition
Todd Ripley
VP Political Affairs
Wild Steelhead Coalition
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