July 30, 2014
Washington Fish and Wildlife Commission 600 Capitol Way N. Olympia, WA 98501
Dear Commissioners,
The Northwest Olympic Peninsula Sportfishing Coalition (NWOSPC) a registered non-profit corporation whose membership includes local businesses, community leaders and recreational anglers that frequent the Northwest Olympic Peninsula for recreational fishing wish to express our significant concern over fisheries management in this area. Several decisions over the last few years combined with non- responsiveness by the Washington State Department of Fish and Wildlife (WDFW) to our concerns has impacted recreational angling, our economy and wild fish conservation efforts here in our area. This has led to frustration and a belief that WDFW often ignores the needs and interests of our area far away from Olympia. As the President of this organization I am writing to you with the greatest of urgency to document our concerns and urge action by the Commission, WDFW leadership and legislators to reform management and help us move in a direction that places the needs of our community, our businesses and the recreational anglers that we depend on at a much higher priority.
Recreational angling on the Northwest Olympic Peninsula is a primary economic contributor to our many small rural communities. Without the revenue that sport fishing generates our communities and small businesses suffer immensely. Despite the overwhelming importance of recreational fishing here on the Northwest Olympic Peninsula, WDFW’s management decisions appear to be made without a full understanding of the issues, often lack transparency and very often exclude valued input from our sport fishing guides, recreational anglers and community leaders that have a vested interest in this area. WDFW decisions also tend to be heavily weighted on outside interests that have no vested interest in our community and its resources. This type of management and the resulting decisions have created a crisis in our community by constraining the success of our fisheries and inducing undue harm on the health of precious wild stocks.
We believe there is lack of understanding and non-responsiveness to our concerns that cannot continue without dire consequences to our community and small businesses here on the Northwest Olympic Peninsula. We sincerely urge the Commission and WDFW to reform fisheries management in a way that supports WDFW’s most important client, the recreational anglers, and help support the rural communities that depend on the income they generate.
Here is a summary of the key issues that are creating a crisis here on the Northwest Olympic Peninsula:
• 50% reduction in Sol Duc River Hatchery Coho Production • 78% reduction in adult hatchery Coho returning to the Sol Duc River • 40% reduction in the Quileute River System hatchery winter steelhead production • Elimination of our successful 25 year community funded and operated Snider Creek Winter Steelhead Broodstock Program on the Sol Duc River • Lack of support to move the Snider Creek Steelhead Broodstock Program to the Bogachiel River. • Closure of the Hoh River for Spring and Summer Chinook Salmon • Elimination of all summer steelhead production on the Sol Duc River, 25K smolts. • Continuing decline of wild fall Chinook populations without requested harvest restrictions • Impacts from the Puget Sound Steelhead Litigation Agreement
We are currently working with our local legislators and other key legislators to inform them of our critical issues and how our economy and way of life is being impacted. Because many of our members are also members of the Coastal Conservation Association (CCA), Puget Sound Anglers (PSA) and the Northwest Sportfishing Industry Association (NSIA) we offer our support to their on-going efforts to help reform fisheries management in this state. We share many of the same concerns that these groups have expressed regarding the need change in the way WDFW prioritizes and manages our recreational fisheries and our concerns. As such, our organization does not feel in can support legislation to increase recreational fishing license fees or reauthorize endorsements unless significant progress is made in addressing our issues. Simply put we cannot continue to support increases in fees when our resources and opportunity continue to be reduced or taken away completely.
I am including an attachment that includes a more thorough explanation of our issues. We are also outlining key recommendations that will help our community, our recreational anglers and our small businesses. Our community has endured several reductions that have created a crisis. Quite frankly we find this to be quite troubling because our area is one that has the least amount of limitations from the Endanger Species Act (ESA) and other limiting factors that affect Puget Sound and the Columbia River.
I and others from our community are very interested in meeting with Commission members and WDFW Director Anderson to determine how we can best resolve our issues. We believe there are a number of issues that could be easily resolved in the short term which would help restore trust in working with WDFW. It would also help to establish a platform to tackle the long term challenges associated with WDFW’s management of our issues here on the Northwest Olympic Peninsula.
I very much appreciate your consideration in this matter and look forward to hearing from you and Director Anderson to schedule a time to discuss our issues and develop a path forward.
Sincerely,
Robert Kratzer, President Northwest Olympic Sportfishing Coalition (360) 271-7197 Email: [email protected] cc: Phil Anderson Director Washington Department of Fish and Wildlife, Honorable Governor Jay Inslee, Representative Kevin Van De Wege, Representative Steve Tharinger, Senator James Hargrove, Senator Kirk Pearson, Senator Marko Liias, Senator Jim Honeyford, Representative Hans Dunshee, Senator Kevin Ranker, City of Forks, City Council, Board of Clallam County Commissioners, Chaz Woodruff Quileute Tribal Council Critical Issues for Fisheries Management on the Northwest Olympic Peninsula
Sol Duc Hatchery Coho Reduction
As a result of the economic downturn and WDFW’s budget cuts in 2009 and 2010, the Agency elected to substantially reduce hatchery summer and fall Coho production by 75% at the Sol Duc River Salmon Hatchery. This run of Coho salmon created a very popular fishery from September through November which provided a substantial revenue stream for our local businesses. It was also an important contributor to Quileute Tribal fisheries and our ocean sport fishery out of La Push and Neah Bay.
As a result of the reduction the Quileute Tribe graciously provided money to bump the production back to about 50% of what it was before the cuts. Our community leaders including the City of Forks, our local guide association and recreation anglers have repeatedly requested WDFW to provide information and provide an estimated cost to further restore this lost production. WDFW has been non-responsive to our requests for over 2 years. Our organization and community have already set funding aside and are prepared to work with legislators to raise funding to restore this production. However, we cannot achieve our goal without the support and cooperation of WDFW. We need a definitive response on what it will take to restore summer and fall Coho production. We also need the full support of WDFW and the Commission to implement this project.
This 50% reduction in hatchery production has resulted in a 78% reduction in the average number of adult hatchery Coho returning to the Sol Duc River. A once popular fishery where the average angler could count on harvesting a reasonable number of fish has been eliminated. This has decimated our once popular fishery and led to a direct loss of close to a million dollars from our rural community from September to the end of November.
Snider Creek Winter Steelhead Broodstock Program
Twenty five years ago The Olympic Peninsula Guide Association started a Brood Stock Program (Snider Creek) for Wild Steelhead on the Sol Duc River. This project involved key and now iconic community members, the city of Forks and WDFW. This program was funded for 25 years by the Olympic Peninsula Guide Association and the City of Forks with very little contribution from the state. Based on an outcry from wild steelhead conservation groups whose membership is primarily non-local with no vested interest in our community and speculative data on the impact to the wild steelhead stocks on the Sol Duc River WDFW eliminated our highly prized community project. Our community moral was decimated to say the least.
In eliminating this project WDFW promised our guide association and our community leaders the opportunity to move this program to the Bogachiel River where there is a hatchery influence. Needless to say this has been a very stressful and trying process to get this program up and running. We have been diligently working to collect river temperature and stream flow data and find an appropriate location for rearing these fish at the request of WDFW. However, until very recently WDFW has been very non- supportive and essentially non-responsive to our efforts to move this program to the Bogachiel River. We have provided information, researched sites for rearing and have repeatedly requested WDFW to provide us a clear path to implement this program.
We were recently informed by an outside interest group that a meeting was to be held on June 10, 2014 with the Wild Steelhead and Cutthroat Advisory Board to discuss the effort to transition the Snider Creek Project to the Bogachiel River. We were told that the Wild Steelhead and Cutthroat Advisory Board would recommend against this project.
We were not informed of nor invited to attend this important discussion. This group was given critical information regarding timelines and path forward before we were ever informed of it. This is a good example of WDFW utilizing outside interest groups to direct decisions that impact rural communities without due diligence to coordinate with the community that is to be impacted. This is our project, has been for 25 years. By excluding us from discussions and using others to direct decisions that have no vested interest in our community WDFW has failed to understand the critical importance of this project or the sense of ownership and pride we as a community have in it. We ask how can a government agency operate in this manner and expect to generate support from its most valued customer base.
Only after we called WDFW to voice our concerns did WDFW staff come and meet with our guide association to discuss a path forward. Although we appreciate this effort it seems like we are always last on the list to receive information that has been vetted with others outside of our community. The path forward is very concerning to us as it is designed to allow for a similar public process that led to the elimination of the Snider Creek project on the Sol Duc River. We were promised when the decision was made to eliminate the project from the Sol Duc we would get this project moved to the Bogachiel. Now WDFW seems to be reversing course and setting this project up to be attacked once again by outside interest groups.
We envision the commission and WDFW will get a significant amount of public input and at the end of the analysis WDFW will weight its decision to the recommendation of the Wild Steelhead and Cutthroat Advisory Group and the wild steelhead conservation groups whose membership is primarily non-local with no vested interest in our community. We feel WDFW and the Commission should fully understand the impact this decision will have on our community and recreation anglers as a whole and not weight its decision to groups that hold the threat of litigation over WDFW.
Transfer of Summer Steelhead Production from the Sol Duc River to the Bogachiel River
In designating the Sol Duc River as a wild steelhead gene bank WDFW eliminated the planting of summer steelhead in the Sol Duc River. These summer steelhead provided a valuable summer fishery for recreation anglers. As part of this decision WDFW promised our guide association and community leaders to transfer that production to the Bogachiel River. We fully understood there may be funding issues and our community offered to assist in generating funding that would be necessary.
Our community leaders including the City of Forks, our local guide association and recreation anglers have repeatedly requested WDFW to provide information and provide an estimated cost to restore this lost production. Much like our experiences with the Snider Creek Project WDFW has been non-responsive to our requests for over 2 years. We need a definitive response on what it will take to transfer this summer steelhead production and restore the opportunity that has been lost to recreational anglers that travel to our community to fish for them and spend their valued dollars that we depend on.
Wild Fall Chinook Protection
For the last five years our guide association members and community leaders have shared our concerns over the continued declined of wild Fall Chinook populations on the Sol Duc, Bogachiel and Hoh Rivers. These concerns have always been refuted by WDFW without explanation other than WDFW says the populations are healthy. In a polite way WDFW has told us our concerns are not valid although we firmly believe otherwise and wish to error on the side of conservation.
Our local sport fishing guides and private sport fisherman who frequent these rivers on a daily basis are very certain that the population of wild Chinook on these rivers are in decline, especially on the Sol Duc River. Our review of the data suggest this decline has been occurring for quite some time. We feel so strongly about this issue that we have gone so far as to request WDFW to reduce harvest limits to one wild Chinook a day with a 5 per year restriction. This has fallen on deaf ears. WDFW’s only response has been “we cannot do this because too many people want to harvest two wild Chinook”. This comment is fascinating as our members are those people. We have not talked to one angler that does not share this concern and all are willing to implement this needed restriction. If WDFW is truly trying to protect and restore wild salmon under the Commissions wild salmon policy directives why will they not listen to these concerns and error on the side of conservation? We do not want to run the risk of these populations declining to the point where ESA will be pressed upon our area. We should choose a more proactive route.
Puget Sound Hatchery Steelhead Reduction
On April 25, 2014 WDFW announced the settlement of a lawsuit with the Wild Fish Conservancy (WFC) which challenged the failure of WDFW and NOAA Fisheries to complete the Endangered Species Act- required Hatchery Genetic Management Plans (HGMPs) for Puget Sound early-winter steelhead hatchery programs. This lawsuit which was based on WDFW’s non-compliance with Endangered Species Act (ESA) requirement to develop Hatchery Genetic Management Plans poses a real risk to our fisheries here on the Northwest Olympic Peninsula by putting the hatcheries that we depend on here at risk to additional lawsuits.
The settlement agreement will result in an 80% reduction of hatchery winter steelhead smolt releases in 2014. It could lead to the permanent end to hatchery steelhead production in most Puget Sound rivers. WDFW also agreed to end all hatchery steelhead releases in the Skagit River system for at least 12 years. One might think this is a good thing for the Olympic Peninsula as it could lead to an increase in recreational anglers transiting to our area to take advantage of our opportunities. However, this is troubling in the sense that we too have experienced reduced production and there simply are not enough hatchery fish to go around for all the anglers and sport fishing guides that currently fish our waters. It will increase pressure on an already limited hatchery steelhead fishery and more importantly will increase pressure and the harvest rate on our wild steelhead stocks. This is another decision that will further concentrate anglers into a smaller area of the state resulting in harm to our resources.
We are very concerned that WDFW decided internally to reach a settlement agreement without a concerted effort to fully understand the ramifications it would have on other communities, other river systems, and wild steelhead stocks. Before any settlement agreement WDFW should be transparent and fully understand the impacts the agreement may have on its primary customer base, the rural communities that depend upon these fisheries and wilds stocks that will receive additional pressure. Based on this agreement WDFW should quickly assess the impacts to our fisheries and provide us with alternatives to increase production in other areas such as the Bogachiel River to compensate for the losses in Puget Sound.
Quileute River System Hatchery Winter Steelhead Production
Over the last 10 years hatchery winter steelhead production has been reduced by about 40%. This is based on the elimination of the Snider Creek Broodstock Program on the Sol Duc River and reductions in average number of fish planted in the Bogachiel and Calawah River systems over the 10 year period. This has led to less and less fish available for winter steelhead fisherman. As we discussed earlier in this document WDFW’s decision regarding Puget Sound Hatcher Steelhead will further exacerbate this issue. There will simply be too many people competing for too few fish. This very often generates frustration and disorderly fisheries impacting the quality of our fisheries. As stated earlier WDFW should quickly assess the impacts to our fisheries and provide us with alternatives to increase production on the Bogachiel River and other key locations to compensate for the losses in Puget Sound to ensure there is opportunity for sport fisherman to participate in good quality successful fisheries.
Closure of the Hoh River for Hatchery King Salmon in the Spring and Summer
Populations of wild spring and summer Chinook salmon on the Hoh River has been declining for the last 10 years and has been a concern for both WDFW and our community. Over the last several years members of our community and our local guide association discussed ideas on how to protect wild populations while maintaining a fishery for hatchery Chinook that are present in the system. We recommended selective gear rules and no harvest of wild stocks during the spring and summer which clearly offers necessary protection while allowing fishing opportunity. Without further discussion with our community WDFW closed the Hoh River for 2014 season for wild spring and summer Chinook salmon while leaving it open for steelhead fishing without implementing selective gear rules as requested by our community .
Now that WDFW has received numerous calls they have contacted us to ask for our input which we provided last year and which they failed to take into consideration before implementing this closure. This closure was never communicated with our community until it was in effect. This caught us totally off guard as we thought we had provided a real and reasonable solution to maintain a fishery.
Recommendations
We respectfully request consideration of the following recommendations:
• Allow for the Northwest Olympic Peninsula Sportfishing Coalition to engage in meaningful discussions with the Commission, WDFW’s director and senior management to reform fisheries management and reprioritize the importance of sport fishing on the Northwest Olympic Peninsula. We also request the Quileute Tribe be a part of these conversations so we can develop a vision that works for all of our community members who depend on our fisheries. • Restore summer Coho production to 250,000 smolts and fall Coho production to 680,000 smolts. Provide our organization with an estimate of costs to do this by September 30, 2014. • Transfer summer steelhead production from Sol Duc River to the Bogachiel River. • Increase winter hatchery steelhead production on the Boagchiel River to offset for losses in Puget Sound and the inevitable increase of fishing pressure on our rivers. • Immediately implement a reduced harvest limit for Fall Chinook on the Sol Duc, Boagchiel and Hoh River to 1 Chinook a day and 5 per year per angler. This is a much needed conservation measure needed to ensure the long term sustainability of wild Chinook in our streams.