My Comments on the Rules Proposals for 2010-2012 3

Please feel free to copy and paste any portion and send to lori.preuss@dfw.wa.gov or take a copy to the public meetings on the 4th and 5th of Dec.  I also encourage you to write your own and  comment on some of the other 100 plus rules proposals.

As an avid angler, and someone that makes at least part of my living in the sport fishing industry, I would like to take this opportunity to weigh in on some of the proposed rules for 2010-2012. 

Proposed Rules:

9.  I would like to support identical bag and slot limits for angling and spear fishing.  Further, I would like to recommend seperate seasons for each to reduce conflict.  I would also like to oppose the slot limit decrease that appears on page 145 of the rules proposals and was added September 29th well past the deadline.  The lingcod population has recovered nicely from where it was a few years ago with the slot limit as it currently is.  Lingcod are also a much faster growing bottom fish species. Lastly, the lingcod season is very short as it is, I see no reason for this proposal

10.  I do not support the depth restriction at this time.  The department has not defined how it would enforce this proposal or shown that rockfish retention in waters deeper than 120 ft has caused the problem that we currently have with rockfish populations.  Furthermore, the department refuses to either endorb se or study release techniques that would limit the mortality of these species.  I do support the closure of rockfish retention in areas 8-13 except during lincod season.  The lingcod fishery is the fishery where the most interaction with rockfish will take place and it would be ashamed to waste the resource due to post release mortality during this short 6 wk season.  I do not support allowing a spearfishing season in marine area 5.

13.  Please oppose the daily limit for dungeness crab fom 5 to 4.  The recreational crabber has been getting the short side of allocation for years despite the economic and social benefits of recreational crabbing.  I would much more prefer a more equitable allocation for the recreational crabber.  I do support the Friday to Monday open days.

32.  I would also urge that the state not pass this proposal.  The stated goal of the organization pushing this proposal is to ban lead weights in all waters.  The study that they are using is seriously flawed. This study would not stand up to any independant scientific review.  9 birds in 13 years without any toxocology reports of proof of cause of death is hardly a reason for such drastic action.  Tungsten, the replacement for lead is much more harmful on the environment and much more expensive for the American consumer.  It is made overseas and would cost jobs for Americans as well.

The proposed halibut and bottom fish closure in Neah Bay needs to be opposed as well.  This proposal was made months after the deadline and proposed by a sitting commissioner in an unprecedented way.  The proposal is purely an attempt by one user group to shut all others out.  This area is one of the top destinations in our state for recreational fisherman and has healthy populations of halibut and other bottom fish.  Additionally, it provides access to small boat anglers that would not have access to the ocean due to frequent dangerous conditions. The halibut season is already very short and the bottom fish are only targeted during select times of year due to conditions.  

Lastly, I urge the commission to say no to any proposals to have a recreational limit on albacore. There is minimal pressure from the recreational community.  The US harvest is only 15% of the entire North Pacific Catch.  The Washington recreational albacore fisherman is less than 1% of that total.  When looking at those numbers I don't see how you can manage a fishery with such a minor user group.  There is no proposal to limit the commercial catch.  The albacore stocks are healthy and I am not comfortable with limiting peoples access just because someone thinks it's a good idea.     

Thanks for taking the time to read and review my comments.

Robert Tobeck

Feel free to comment below.  I want to hear from you.