HARVESTING OUR WAY TO RECOVERY?
Washington Trout Submits Comments on Joint Resource Management Plan for Puget Sound Chinook

In February, WDFW and the Puget Sound Treaty Tribes submitted to Natonal Marine Fisheries Service a Joint Resource Management Plan (RMP) titled the PUGET SOUND COMPREHENSIVE CHINOOK MANAGEMENT PLAN: Harvest Management Component. The RMP will govern all harvest activities in Puget Sound and the Strait of Juan De Fuca that affect Puget Sound chinook, listed as Threatened under the Endangered Species Act. Under the 4d Rule for Puget Sound chinook, if NMFS approves the RMP, all harvest activities carried out in accordance with the plan will be exempt from take liability under the ESA.

In early March, NMFS released for public review and comment its Resource Management Plan 4(d) Rule Evaluation and Recommended Determination. Under agreement with the Tribes, NMFS did not release the actual RMP for review and comment, but merely its evaluation of the document. The RMP was made available for reference purposes, but comments were to be directed only to the Evaluation and Recommended Determination. The Evaluation concluded with the "recommended determination" that the Secretary of Commerce approve the RMP for two years. For the full text of the Evaluation and Recommended Determination, go to the NMFS website at http://www.nwr.noaa.gov/1sustfsh/limit6/lmt6sbmt.htm. The RMP itself is not available on the NMFS web site; interested parties should try contacting Susan Bishop at NMFS in Seattle at susan.bishop@noaa.gov or 206/526-4587.

On March 23, Washington Trout submitted substantive comments to NMFS regarding its Evaluation and Determination. We found both the Evaluation and the RMP lacking in technical rigor and legal merit. The RMP not only fails minimal criteria for doing no harm, but would positively impede recovery of most populations and management units in the Puget Sound ESU. We found that the Evaluation failed to acknowledge all the scientific evidence regarding the effects of harvest on chinook populations within the ESU, made no attempt to analyze or weigh the impacts of those effects, and did not adequately justify its determination to approve the proposed RMP.

As with the 4d Rule and its criteria for Fisheries Management and Evaluation Plans (applicable to RMPs) Washington Trout objected to the overall tone of NMFS's Evaluation and Recommended Determination. The co-manager's Chinook Management Plan will not adequately conserve Threatened Puget Sound chinook, and indeed could contribute to their continued decline toward extinction. Washington Trout recommended that NMFS revise its Determination, reject the submitted RMP, and request revisions from WDFW and the Puget Sound Treaty Tribes.

Our comments were submitted as a three part document; part I was prepared by WT Resource Analyst Nick Gayeski and parts II and III were prepared by WT consultant Sam Wright.

To review the complete text of Washington Trout's comments, click here.