Here are my latest comments to staff  on the latest Willapa Plan draft. Take a look feel free to agree or disagree but I think it at least allows folks to get an idea of where we are at. Here is a link to the Willapa site and the plan is linked near the bottom of the page and forgive the formatting but cut & paste can be a bear.

 Willapa Draft Plan




Mr. Scott,


I am submitting my thoughts on the latest Willapa Management Plan ( WMP ) draft. After considerable conversation with others I can say with certainty that the current WMP draft left many if not most confused. Depending on how folks read it one could draw just about any conclusion one wished dependant on the interpretation of the definition of HSRG, conservation objectives, and harvest directives.  I am submitting for your consideration the following modifications to the WMP draft.


1. Chinook Primary Stream: After review it is apparent the Willapa is the logical choice. With its close proximity to North River and Smith Creek it will enhance the ability to meet conservation objectives for all three streams. Additionally as Chinook produced at the Forks Creek hatchery stray in large numbers that cannot be removed to meet HSRG requirements due the location of the Forks Creek Hatchery and the lack of a weir that can stop the staying. It is doubtful other than a minimal number Chinook can be produced at that facility. In the choice of Willapa as Primary  it will dramatically increase the potential of meeting HSRG guidelines within the time frames identified in the WMP draft for Willapa, North River and Smith Creek.


2. Managing For Escapement:  In the WMP I see in the Chinook options you have  “ Achieve spawner goals for natural-origin Chinook “. In Coho you have “Achieve the aggregate spawner goal for natural-origin Coho” Now some are reading this as you make the individual stream goals for Willapa Chinook and the aggregate for the Willapa Estuary for Coho. So clarification of that verbiage is needed. What is meant  by goals in Chinook? All the tributary streams or Willapa & Naselle or something else?


 Additionally the aggregate Coho and Chum objectives lack what is commonly called a "floor " or minimum escapement goal for the Willapa Estuary streams that would trigger harvest protection of these streams. As written the plan would permit Willapa and Naselle to drive and make the aggregate Coho escapement goal and literally wipe out the remaining streams in the Willapa Estuary. Simply put a aggregate Coho and Chum  escapement goals minus a "floor" is not acceptable.


3. Recreational Harvest: In the harvest options recreational harvest between marine and freshwater inriver is not clearly defined.. In the Grays Harbor plan these are clearly stated. By not placing similar guidelines in the WMP it is likely creating an unbelievable confrontation between Marine and Freshwater Inriver recreational fishers at North of Falcon. It is my understanding that the Commission desired to remove confrontation between all users rather than increase the conflict which the current WMP draft does between marine and freshwater inriver recreational fishers.  I urge the addition of the following verbiage to any and all options.


  1. Marine and inriver freshwater recreational Chinook harvest impacts shall be divided equally.  Either can exceed its share as long as it does not impair a full season for the other. ( see a,b,c)


              A. Marine full season is defined as a 2T recreational opening May 31 unless                a conservation objective requires a reduction. 6 fish limit, two rods per angler from a           boat preseason forecast runsize permitting.

              B. Freshwater inriver recreational full season is defined as a August 1 opener for        the Willapa estuary streams for all reaches open to recreational anglers unless a conservation objective requires a reduction. 4 adults a day, two rods per angler from a boat, no limit on Jacks preseason forecast runsize permitting.

              C. Any and all conservation driven recreational fisher reductions shall be equally shared by marine and fresh water inriver recreational fishers.


    4. 2T Commercial Exclusion:  The lack of a clearly define 2T Commercial exclusion has many believing that commercial harvest could start as early as July and just about any week to September 15. I urge that the WMP clearly state the recreational harvest priority and suggest the following verbiage be added to the WMP and any and all options.


    No commercial fisheries shall take place in area 2T and U prior to September 16.


    5. Chum Management: The current WMP verbiage on Chum harvest and management is woefully inadequate. I  urge you to consider adding the following verbiage.


  1. Fisheries will be managed with the intent of achieving the aggregate goal for Willapa Bay naturally spawning Chum salmon.  Until the spawner goal is achieved, the maximum fishery impact shall not exceed a 10% harvest rate and no commercial fisheries will occur in the period from October 15-31. If the aggregate goal has been achieved, but the pre-season forecast of adult Chum is less than the aggregate goal, or less than 10% higher than the aggregate goal, fisheries in the Willapa Bay Basin will be scheduled to result in an impact of no more than 10% of the adult return.


    No commercial fisheries Oct. 15-31 until spawner goal achieved 2 consecutive years. If the number of natural-origin spawners was less than the goal in 3 out of the last 5 years (beginning in 2010), the Department shall implement the following measures:


              a) The predicted fishery impact for Chum in WDFW-managed fisheries in the             Willapa Harbor  & tributary streams will not exceed 10% of the adult return to Willapa Harbor.


              b) When the Chum preseason forecast is 90% or less of the escapement goal the           predicted fishery impact for Chum in WDFW-managed fisheries in the Willapa Harbor & tributary streams will not exceed 5% of the adult return to Willapa   Harbor.


    Rational: The changes are consistent to the directives of the Commission in the recently adopted Grays Harbor Management Plan. Willapa Chum have made escapement 6 out of the last 18 years and only 1 of the last 9 due to the agencies inability or unwillingness to address the failure to make Chum escapement goals.

  2. In closing I would like to thank you and Region 6 staff for your effort thus far and look to work toward the goal Willapa salmon management reform.




    Dave Hamilton



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