Opposition Working on Wild Steelhead Moratorium - Fly Fishing Forum
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Old 07-25-2004, 11:40 PM
rich_simms's Avatar
rich_simms rich_simms is offline
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Location: Rivers of North Sound & Oly Pen
Posts: 319
Exclamation Opposition Working on Wild Steelhead Moratorium

Please send in your letters supporting the Wild Steelhead Moratorium. The opposition is working against it, your help is needed, please send in your letters to the commission supporting it as well as attend the Testimony on August 28 in Bremerton Wa. see below-


The public process for the 2004-2006 Sportsfishing Rules Proposals process, carried out by the WDFW, resulted in theCommission adoption of a 2-year, statewide, "Moratorium" on Wild Steelhead harvest, by sportspersons. The resulting public process was widely viewed, by sportspersons, City of Forks, members of the state legislature and the Boldt Case tribes, as being illegal and unethical. The Moratorium generated an immediate response, with a call for strong action from these groups and resulted in the Commission agreeing to revisit this Moratorium for further public review. This public review will provide an opportunity to inform the Commission whether the Moratorium should be rescinded, amended in some way or allowed to stand as is. Public comments may be submitted via e-mail or by letter to the Commission in Olympia. The comments must be received no later than August 25. Personal letters to a Commissioner must be received earlier. In addition, oral testimony may be given to the Commission at the Commission Hearing scheduled for August 28/04, in Bremerton, WA. A decision by the Commisson is scheduled for September 2, 2004, via a telephone conference call.


The public process for the 2004-2006 Sportsfishing Rule Proposals process began with with the WDFW letter to the public of October 23, 2003. Public comments ( letters, e-mail) to the commission had a deadline of December 5/2003. Verbal testimony was permitted at the Commission Hearing held in Port Townscend, Dec.5&6, 2003. Commission consideration and adoption of the 2-year, "Moratorium" occurred at the Commission hearing held in Olympia, Feb.2004. .

It was apparent throughout the rules process, including the adoption of the "moratorium", that it was grossly flawed. The information communicated to the public, in the Oct. 23, 2003 WDFW letter, would have a reasonable person conclude that the process would not consider changes any changes to the yearly, (5) Wild Steelhead, retention. Comments that were provided came from special interest groups that were in contact with certain commissioners. The commission vote was 5:3, in favor of a 2-year Moratorium.

Immediately following adoption by the commission of the "Moratorium", a strong backlash came from sportsmen and the City of Forks-where the rivers in the Fork’s area would be impacted by the Wild Steelhead, harvest closure (Moratorium). Agreement was quickly reached that concluded, the Commission process had deceived the public and was likely illegal. The City of Forks assumed the focal point position for action and the sportsmen assumed a supportive position to the city’s action.

Legal advice, advised Forks to submit a legal petition to the Commission, requesting what amounted to rescinding the 2-year "Moratorium" that had been adopted by the Commission. The City of Forks spent a great deal of their officials time and money to prepare and transmitt the required petition to the WDFW Commission. In June, 2004, the Commission advised Forks officials that they made a decision to revisit the so-called "Mortorium", with an accompanying public process, whereby the Commission would essentially consider either to rescind or retain the Moratorium.

Repr. Jim Buck, from the Peninsula, a stong ally of the sportsmen for many years, closely followed the 2004-2006 Sportsfishing Rule Proposal public process. Repr. Buck and Senator Jim Hargrove, also from the Peninsula, were concerned and disagreed with the Commission’s actions that resulted in the "Moratorium". Repr. Buck and Senator Hargrove, and 16 additional members of the state legislature, informed the Commission by letter that they had: violated the state’s Administrative Procedures Act ; had taken actions that were contrary to state law, expressed in "77"; furthermore, had violated their legislative directive that the commission should attempt to maximize the public recreational game fishing and hunting opportunities of all citizens, compatible with healthy fish and wildlife populations. The legislature, further stated, that the WDFW staff and tribal biologist’s position clearly stated that theWild Steelhead populations on many rivers support harvest retention.

The Boldt Case tribes stronghly criticized the Commission for their unilateral actions in adopting the Moratorium. The NWIFC( Northwest Indians Fishery Commission) criticized the Commission for carrying out a process without any consultation with, or agreement of the tribes, as required by the Federal Court Orders in U.S. vs Washington. Furthermore, the NWIFC pointed out that the Commission adopted this Moratorium as a conservation regulation, despite the fact that the WDFW staff and the tribal biologists clearly made it known that it is not necessary for conservation reasons.

The description given this rule "Moratoriuim" is simply a part of ongoing deceit for this rule that is actuallty a Wild Steelhead, harvest closure . Moratorium is defined as a temporary cessation of a dangerous or hostile activity . Obviously, this is not the case here . The WDfW staff and the tribes agree, when the Wild Steelhead populations on a stream exceed the current escapement goals, steelhead may be retained. Some (12) rivers have surplus Wild Steelhead. The reason we have this issue before us now stems from a matter of fish politics, where some Commissioners, responding to an ever increasing high-pressure, from "catch and release" groups, have been decreasing retention limits for Wild Steelhead, in spite of the conservation aspect that permits greater Wild Steelhead retention. The result from this type of fishery policy, is one of ever decreasing fishery opportunities for the average citizen. One commissioner, a leader of the Moratorium effort, said that any revenue lost by the fisherman who wants to retain some fish can readily be replaced by affluent fishers that will fill the gap.

A very large organized effort will be necessary in ordedrto generate sufficient influence that the Commision will rescind the Moratorium, now in place. What follows, are various means we must undertake,with the highest level of participation that we can muster, to favorably influence the Commisssion to rescind the current Moratorium, now in place.

Actions To Rescind Moratorium

There are a number of actions we should take in responding to to the public letter by the WDFW for this public process. The major ones are:

(1) E-mail, letters and petitions to the Commission in Olympia.

(2) Personal letters to Commissioners.

(3) Attending the Commission Hearing in Bremerton on August 28 ( 10 AM). Verbal testimony is recommended but not essential.

(4) Letters to the Editor, are good! Lots of small town papers up here in our area, as well as, sw, WA. They generally allow around 150-200 words max. Don’t overlook Tacoma and Olympia. Seattle may be tough to get one accepted.

Regarding e-mail and letters to Olympia, its fine to simply say that you support the WDFW staff position of rescinding the "Moratorium".

There is a petition being circulated. Get friends to sign it. Run copies and provide them to those that will help.You must get them mailed by Aug.18. If they do not reach the Olympia office by Aug.25, they will not be processed for the Commission.

Again, the Commission Hearing is August 28 in Bremerton at 10AM. You must sign up to testify. You have a maximum of (3) minutes. Even if you decide not to testify, your presence helps. Attend if at all possible!

Address for the letters and petitions: Washington Fish & Wildlife Commission; 600 Capitol Way North; Olympia, WA. 98501-1091

E-mail to WA. Fish & Wildlife Commission: Commission@dfw.wa.gov

Commission Hearing: Kitsap Conference Center; Bremerton, WA

Personal Letters to Commissioners: Use the same address as listed above for petitions and letters. The Commission staff will mail it on to the Commissioner of your interest. Likely takes another 5 days to reach the Commissioner.

Commissioners: There are (2) new Commissioners that have been appointed this past year. John A. Hunter 1V, of Cashmere, appointed in July of 2003 and Holly Ledgerwood, of Pomeroy, appointed April 2004. John had been associated with the fruit industry. Holly, an avid hunter and fisher is an educator.

General Information: Some reasons why this Moratorium should be rescinded:

(1) There is no Wild Steelhead conservation problem.The WDFW staff and the tribes have told the Commission this is the situation.

(2) The so called "Moratorium" simplt decreases fishing opportunities for a large number of Steelhead fisherman.

(3) The federal district court approved MSHE (Maximum Sustained Harvest Escapement), following WDFW and tribal agreement. for each of our Steelhead rivers in the Boldt Case Area. Wild Steelhead in excess of MSHE are surplus- available for harvest by the tribes and sportsmen.

The Steelhead Trout Club of Washington is considering an arrangement whereby a bus might be made available from the Seattle region to the August 28, Commission Hearing in Bremerton and return, following the Hearing. At this time, no decision has beem made. If we can sign-up 65 people, the cost could be around $15 each. Probably would leave and return from a Park & Ride station.

Repeating the deadlines:

(1) Petitions and letter responses: mail by August 18th.

(2) E-mail resonses. make by August 2.

(3) Personal letters to a Commissioner by August 13

Questions: Contact John Kelly, Steelhead Chair of the King County Outdoor Sports Council, Ph. (253) 838-6840

E-mail: jksteel1@comcast.net

-Lost poor realitive of the Simms family fishing fortune
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Old 07-26-2004, 01:02 AM
flytyer flytyer is offline
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Location: NW Washington
Posts: 3,346
Thanks for the info Rich, although it doesn't surprise me the opposition is working hard at getting it recinded. Amazing how many of those opposed to the moratorium are nowa claiming the treaty tribes need to be included in a decision by WDFW when the vast majority of them are opposed to the tribes netting whatsoever.

It also clearly shows that those of us who care about wild steelhead in WA State need to write letters (everyone has done so right?) to the commission in favor of the moratorium that also possibly mentioned if no moratorium, a limit of 1 wild steelhead/calendar year and once this single fish is bonked, no steelhead fishing during March/April like I have done.

What we can't do is sit back and assume the moratorium is a done deal and we need do nothing. If we sit back and do nothing, the opponents will get to have their way and we will continue to have the 5 wild fish/year allowed.
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Old 07-26-2004, 05:58 AM
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juro juro is offline
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Location: Steelhead country|striper coast|bonefish belt
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I have written the commission from 3,000 miles away. I hope it provides a little appreciation for how far and wide wild steelhead protection reaches. I hope they can learn to think globally on wild steelhead, not from the perspectives of their own plates and pockets.
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Old 07-26-2004, 10:04 PM
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Feiger Feiger is offline
Join Date: May 2003
Location: Deschutes, John Day, Grande Rhonde, Salmon Rivers
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my contribution.....

Letter submitted this morning to the commission, they have recieved and dsitributed to its membership...

Dear Fish and Wildlife Commission, State of Washington –

I am writing you to provide comments on the review of the Moratorium on the retention of wild steelhead in the State of Washington. This moratorium was enacted this past spring, as a result of input and request from several groups, including the Wild Steelhead Coalition, of which I am a member. The purpose of this moratorium was to end retention of wild steelhead in Washington rivers, such that all wild fish returning to those waters would be given the opportunity to return and spawn. Information provided by the Washington Department of Fish and Wildlife indicate significant declines in steelhead return rates, particularly with wild fish, in the last 3-5 years. Several groups, including the Wild Steelhead Coalition, and their memberships, are deeply concerned about the future of wild runs in the State of Washington, given these declines in populations. Indeed, Washington Department of Fish and Wildlife, on several occasions in the past 5 years, has enacted partial/full moratoriums on retention of wild steelhead in rivers feeding the Puget Sound. These were rivers once noted for their healthy stocks of wild fish, but because of a variety of reasons, have fallen to critical and unstable population levels. This trend is not only isolated in Washington, indeed, British Columbia, Oregon, California and Idaho have all seen similar trends in some or all of its wild steelhead stocks.

In my home state of Oregon, there currently exists a moratorium on the retention of wild steelhead in its waters. This is due primarily to the listing of nearly all runs as Threatened or Endangered under the Endangered Species Act. And while initially un-popular with many of the fishing public, is a situation/condition that has come to be accepted. Indeed, it’s a situation that has also shown some success. On my home waters on the John Day River in northeast Oregon, steelhead populations/redd counts have climbed every year since their population lows in the late 80’s/early 90’s (when the stock was listed and the mandatory moratorium enacted). They have climbed to the point that the Oregon Department of Fish and Wildlife and NOAA Fisheries maybe considering a limited harvest of wild fish in that system. Mind you, the John Day River system is a completely wild run, there are no hatchery fish stocked in that system. I believe it is the ONLY such system in the entire Columbia River Basin. Now I am not going to say that the requirement of release of all wild fish is the reason for this population turn around. There are many other factors that are likely more significant in the changes in populations (ocean conditions, climate conditions, etc.). But given the life cycle of these fish, and more importantly the incredibly small percentage of fish that return from a single spawning effort, the importance of each redd becomes obvious. Particularly to a population or stock that is close to extinction.

Much has been said about the “potential effects” to communities and fishing opportunities from the moratorium. The city of Forks, in particular, has been very vocal, as well as a number of anglers who desire the retention of all fish they catch. I believe such concerns are unfounded and would not materialize. Again, the John Day River is an example. I remember the “hay days” of big runs on the river, when wild fish were “keepable”, and the number of anglers who’d fish the river in the winter and early spring. Fishing effort, however, fell off even before the moratorium on wild fish retention began, because with the decline in populations, resulting in declines in success, anglers just weren’t interested. And initially, with the moratorium, there was an even further drop in effort. However, as populations have increased again, returning to populations of two decades ago, angler effort has increased, and likely returned to early 1980’s levels, due to the presence of abundant fish. People are fishing for them, in spite of the fact they cannot retain the wild fish. The occasional stray hatchery fish, along with the better than odds chance of tying into a steelhead, has brought anglers back, and has brought $$’s back to the local economies. Guide services are operating on that river, making dollars on clients that want a chance to hook into a wild fish, knowing it will go back into the water. Over the past decade, the fishing culture has changed, with less emphasis on retention, and more on opportunity.

The above description is in a river with out hatchery fish supplementing the populations. The odds of catching a stray hatchery fish are incredibly low, particularly in the upper river where the bulk of the fishing effort occurs. By comparison, many, if not most/all, of Washington’s rivers that are in contention with this moratorium, have hatchery supplements. There are hatchery fish available in good numbers (often times BETTER numbers than the wild fish) that anglers can (and should) retain. The opportunities to take home a fish for the table are numerous, and not limited by this moratorium.

More importantly, Washington is sitting on the cusp of decisions and paths it can go as far as its wild fish populations. A couple bad spawning efforts, poor ocean conditions, and other factors, could push stocks that are near that point of failure or significant declines over that edge. Welcome to the ESA, where your options go from a few tough ones to Slim and None – and Slim just left town. The short term costs of lost of retention of a smaller portion of fish caught, vs. the long term gains of a more stable and abundant populations are obvious. And I’d hope the commission would error on the side of caution. Once a wild stock is gone, it is not replaceable, certainly in our lifetimes. I ask that you error on the side of caution and work to preserve a precious and valuable resource. Allow the moratorium a chance to prove it self. Two years is but a short period of time in the history of an amazing and awe inspiring species.


Michael D. Feiger

P.S. – In April of this year, I spent a weekend on the Hoh River, fishing for steelhead. It was an experience simply termed – Priceless. That trip is a 20 hour round trip drive for me, requiring the purchase of fuel, food, room and board, and out of state fishing licenses and permits. Dollars that go into local communities, including Forks. For my 3 days of fishing effort, I hooked and lost two fish. It was worth every penny, and I will once again make that investment in time, energy and money this next spring. On that trip, I saw no fewer than 15 Oregon and Idaho license plates on vehicles, including several operating guides. Obviously there are others who feel as I do in the value of such opportunities, and are willing to make similar investments in time, energy and dollars for that amazing opportunity. It’s an opportunity that would be enhanced with the moratorium. I hope you will not discount the opinions of those of us who come from out of state, but choose to invest in the enjoyment of resources the State of Washington provides.
Tie One On, and Tie Into One!!!
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