The Outdoor Line Forum

NOAA has received an approval on their Puget Sound Draft Rockfish Recovery Plan, It has gone out to the general public for comment. It’s our turn for input to help guide how the recovery plan is instrumented. Time is of the essence as we only have until Nov 14 to comment. The Puget Sound Anglers has worked throughout this process to aid in how the plan is processed. We DO NOT agree with any Marine Protected areas or "No Fishing Zones". If you agree, please feel free to use these points below and comment on their website. Also feel free to send them a letter. Directions are at the end of this notification with who you should include/cc. Puget Sound Anglers agree with most of the draft rockfish recovery plan with exception to Marine Protected Area (MPA) or no fishing zones part of the plan. We do not want to see any MPA’s installed in our waters.

Please feel free to use the any or all of the points listed, you may also draft your own. Also attached are Letters sent to NOAA from PSA leaders Ron Garner, Larry Bucklin and Karl Brackmann. We have also attached a letter sent in by Frank Haw.

1. WDFW has closed marine waters to all bottom fishing deeper than 120' in the Puget Sound other than halibut days which will be 5-6 days a year now.
2. WDFW has closed all rockfish fishing in the Puget Sound East of Marine area 5. Only 3 Blue and Black rockfish can be kept in MA 5
3. WDFW is in the process of making it law to use a rockfish descender device when bottom fishing from a boat that will protect those rockfish on open water days for halibut as well as rockfish in water caught incidentally. The Puget Sound Anglers have distributed almost 2600 descender devices. They are shown to be a very effective tool in rockfish recovery.
4. The NW Straits have removed thousands of derelict nets and crab pots that will aid in the recovery of rockfish as rockfish were getting caught in these nets.
5. Marine protected areas or fishing reserves are in the draft rockfish recovery plan. These will not be honored by the tribes as they have tribal treaty rights allowing them to fully fish their Usual and Accustomed areas. MPAs will only remove the users that are not shown to be causing the problems. Case in point: The C-Closure in LaPush is a Yelloweye Rockfish Recovery Area that the tribes fish fluently while recreational anglers do not. If installed this is going to put a major breach of trust between NOAA and the recreational public.
6. NOAAs Own studies show that rockfish cannot repopulate in a reserve with Lingcod present. A single old Yelloweye (120 years old) will have to outlive 5 generations of Lingcod trying to eat it in its lifetime if it lives to be 120. There is no known science showing that Marine Reserves will work for rockfish.
7. Pollution in Puget Sound is shown to have detrimental effects on rockfish including wreaking havoc on their gender make up. This should be dealt with
8. Vancouver Island has over 200 RCAs around it and to date there is no change to rockfish recovery
9. Pinniped management is not being dealt with at the NOAA level. Pinnipeds are opportunistic feeders and there are far more in the Salish Sea than can be supported. As food chains deplete, rockfish can be a food source for them. Between 8 and 9 out of every 10 steelhead released in 5 rivers in the Puget Sound were eaten by seals. The tracking tags were found in Seal scat.
10. Fishery Management should be used over the entire-which is being practiced by WDFW at this time with the 120' depth restriction and rockfish fishing closures.
11. PSA worked with WDFW to recover Coastal Canary Rockfish and Yelloweye. Canary is now recovered and Yelloweye are well on their way, doing quite well.
12. Having a MPA in the PS Draft Rockfish Recovery Plan leaves the door wide open for future massive fishery shutdowns and expansions by future employees or far up the NMFS/NOAA high ranking officials and/or leadership change.

Directions.
Marine Protected Areas or No Fishing Zones are included in the Draft Rockfish Recovery plan for the Puget Sound. This is the most alarming part as this can be blanket fishing closures inside of our waters. This is the time for you to comment now as your voice will make a difference.
You can write a letter and comment on their website as it is all due on Monday Nov 14, 2016. next Monday

Please respond to NOAAs draft recovery plan on the link below.
Link to Comments: https://www.regulations.gov/docket?D=NO ... -2016-0083
Website page for draft recovery plan: http://www.westcoast.fisheries.noaa.gov ... sound.html
If you have any letters you would like to send, please send them to Dan Tonnes on this email address: Dan.Tonnes@noaa.gov
Please cc these people below on the bottom of your letter and include them when sending your letter to NOAA.
cc:
Steve Copps steve.copps@noaa.gov
Barry Thom barry.thom@noaa.gov
Frank Lockhart frank.lockhart@noaa.gov
Chris Yates chris.yates@noaa.gov
Jim Unsworth WDFW Director jim.unsworth@dfw.wa.gov
Ron Warren WDFW Fish Program ron.warren@dfw.wa.gov
Senator Maria Cantwell nicole_teutschel@cantwell.senate.gov
WDFW Commission commission@dfw.wa.gov

West Coast Regional Office
National Marine Fisheries Service
Protected Resources Division
7600 Sandpoint Way NE
Seattle, WA 98115

November 10, 2016

Dan Tonnes,

Thank you for the opportunity to comment on the Draft Puget Sound Rockfish Recovery Plan. Puget Sound Anglers has been working with you, NOAA, and WDFW to recover Rockfish for many years. We were instrumental in working with WDFW on the rebuilding plan for the Coastal Yelloweye and Canary rockfish. Our hard work and efforts have paid off to rebuild these stocks. Yelloweye stocks have improved greatly and Coastal Canary stocks are now considered rebuilt. This helped in your delisting of the PS Canary which your genetic studies showed are no different than the ocean Canary. In dealing personally with these fisheries over the last 26 years, both politically and recreationally, we feel that our merit should be recognized. Both Canary and Boccacio are both known to travel over 200 miles through tagging studies. This makes it tough to determine if there is a true Puget Sound distinct Boccacio which was already ESA listed. It should have been proven genetically distinct before allowing ESA listing. Puget Sound Boccacio should be removed until enough DNA samples are received and genetic samples are tested to make this conclusion.

We have enjoyed our relationship with NOAA's Rockfish Group in working with you. We agree that Puget Sound Rockfish-especially Yelloweye need help in recovery. We support most of the PS Draft Rockfish Recovery Plan however, we oppose the installation of Marine Reserves or Marine Protected Areas (No Fishing Zones) as part of the recovery plan for PS Rockfish. The reasons are listed below:

1. We have a 120' depth restriction in the ocean and Puget Sound that restricts recreational anglers from fishing below that depth. This WDFW rule seems to be unrecognized in almost all rockfish meetings and publications including NOAA, other NGOs, and other state agencies. It is probably the largest fishing closure percentagewise in the US. Most rockfish caught in our test fisheries were quite deeper than that. Almost all commercial dragging and long lining in the Puget Sound is closed except for Tribal. A few non-tribal commercial shrimp trawlers still harvest in the San Juans and Strait.

2. When fishing for Lingcod in the Puget Sound, the 120' depth restriction was implemented to protect deep water Yelloweye and other rockfish stocks.

3. Puget Sound Anglers were the leaders in Washington State to descend rockfish. This occurred years before WDFW, NOAA, PFMC, and others knew it could be done. We learned that if rockfish were hooked incidentally, they could be brought up slowly making a huge difference in the health of the fish when descended. We bought and distributed rockfish descending devices free of charge to coastal fishers. Years later, NOAA came to us on rockfish identification to work with them. PSA added it to our rockfish descending education program. Puget Sound Anglers with support from WDFW, NOAA, and PSFMC, has given out almost 2600 rockfish descending devices to date with more to come. We feel we have done a very thorough job of decreasing the recreational impact on these fish. We appreciate the help everyone has given to help in rockfish recovery.

4. Puget Sound Anglers has submitted a proposal to WDFW to require the mandatory use of the descender device when fishing for Lingcod, Halibut, Cabezon, and Coastal Rockfish. We feel we have given away sufficient free rockfish descenders to not financially burden recreational anglers as these devices can be quite expensive. We felt it was time to make it a law, as we have made a huge difference on rockfish impacts in the coastal bottom fishery.

5. Along with the 120' depth restriction, WDFW has stopped all retention of rockfish inside the Puget Sound east of the Victoria Sill. They have also educated the public on how not to catch these fish. Additionally, through their ROV camera program many more ESA protected rockfish have been found than were previously known. WDFW's recovery plan needs time to see if it is adequate and whether future changes are needed.

6. There are over 200 Rockfish Conservation Zones around Vancouver Island and to date they have not shown any increase or decrease of rockfish populations.

7. Marine Protected Areas for rockfish have shown to be counterproductive for rockfish recovery when Lingcod are present. Lingcod are a voracious rockfish predator. We know that to be true and have pictures that show large rockfish inside the bellies of Lingcod. Lingcod are a much faster growing fish compared to Yelloweye. An old Yelloweye is 120 years old while an old Lingcod is 25 years old. You have 5 generations of lingcod feeding on one generation of Yelloweye. NOAA's own studies have stated that rockfish inside of a reserve do not recover as well as outside of a reserve. Installing an MPA for rockfish is going to be unrealistic due to the presence of Lingcod.

From the Rockfish Recovery in Salish Sea Research and Management Workshop-June 2011.

"Many species of rockfish (Sebastes spp.) have declined significantly along the U.S. West Coast in recent decades, due in part to overharvesting (Parker et al. 2000). In the San Juan Archipelago, marine reserves have been established in important habitat areas in an effort to facilitate recovery for a suite of rockfish species. Lingcod (Ophiodon elongatus) inhabit the same rocky, coastal habitats as many species of rockfish and are upper-level predators in these systems. Densities and reproductive potential of many rockfishes and lingcod have increased inside marine reserves (Palsson and Pacunski 1995); however, lingcod presence may undermine the intended effect of the reserve, as the frequency of predation events on rockfish by lingcod is greater in reserves compared to non-reserve areas (Beaudreau and Essington 2009)."

8. Tribes have Tribal Treaty Rights to fish their Usual and Accustomed areas that these MPAs would reside in. These treaties guarantee them fishing rights inside any reserves. The established C- Closure or Yelloweye Rockfish Conservation Zone out of La Push is closed to all, yet the tribes fish it exclusively. This is a very contentious issue among recreational anglers. We get calls wanting to know why tribes are fishing inside of the closure as we are prohibited. We do not want to see this duplicated in the Puget Sound. NOAA has no enforcement division to enforce it and if tribes agreed to MPAs who would pay them to not fish it due to their U&A rights? The North of Falcon Salmon Setting agreement between recreational and tribes were a disaster this year. It was very divisive and we do not need any more conflict between us. This has the potential to start that all over.

9. We believe in fishery management and not blanket closures. A quote from Ray Hilborn, a University of Washington Fisheries Scientist:

"There's this idea that the only way you can protect the ocean is by permanently closing parts of the ocean to fishing, with no-take areas," said Ray Hilborn, a professor in the UW's School of Aquatic and Fishery Sciences. "You protect biodiversity better by regulating fisheries over the country's entire economic zone."

We support Ray Hilborn's statement as he is an accomplished fisheries scientist.

10. There are 83 reserves in the San Juan Islands Wildlife Refuge imposed by the US Fish and Wildlife Service. Most are off limits to people. Will USFWS and NOAA protection areas overlap or significantly increase the size of restricted areas?

11. The NW Straits Foundation has removed most known derelict crab pots and nets down to 105 feet. The removal of derelict nets below 105', where Yelloweye Rockfish reside, should have higher priority. We believe this will be the greatest aid in ESA rockfish recovery.

Puget Sound Anglers is the largest recreational fishing organization in Washington State. We have worked on many, many fishery conservation issues for over three decades. We, as well as the WDFW Commission, support Director Jim Unsworth's letter to NOAA's Chris Yates in opposition to any Marine Protected Areas. We also support the letter from Frank Haw of the Office of Protected Resources. We work with some of the tribes that own the U and A's where the first MPAs would be installed (Eastern Straits and San Juan Islands) They are in opposition to these fishing closures as well. By including MPAs into the recovery plan it leaves the door wide open for massive future fishery closure expansions and additions. Future and higher ranking NOAA/NMFS officials and or leadership change can manipulate these closures. We do not want to bring the California Closure debacle to Washington State.

We will continue to work with the NOAA PS Rockfish Team. The marine reserve issue could breach the public's trust. We need your help to recover rockfish but it must be done in a manner that will give positive results. We believe in responsible fisheries management and not blanket closures that do nothing but add regulations. We are looking forward to the day that rockfish are recovered inside the Puget Sound. The Coastal Yelloweye rockfish are rebounding and Canary Rockfish stocks have been declared rebuilt, and PSA was part of that recovery. Please continue your efforts on ESA rockfish recovery but we urge you to consider other alternatives than ineffective MPA/RCAs. We are devoted to help in this recovery, it is important for our future generations. We believe in methods that do not exempt one user group over another.

Thank you for your time.
Sincerely,

Ron Garner
President
Puget Sound Anglers State Board-16 Chapters Statewide
President-PSA EFC Chapter
NOAA PS Rockfish Group
WDFW Halibut Ad Hoc
WDFW Bottom fish Advisor

cc:
Dan Tonnes-NOAA PS Rockfish
Steve Copps-NOAA Puget Sound
Barry Thom-NOAA West Coast Administrator
Steve Freese-NOAA West Coast Regional Administrator
Frank Lockhart-NOAA West Coast Region Director
Chris Yates-NOAA Protected Resources Division
Jim Unsworth WDFW Director
Ron Warren-WDFW Fish Program
WDFW Commission
Senator Maria Cantwell
Senator Patty Murray