if its too loud, turn it down

Wednesday, January 16, 2013

Letter to WDFW Concerning WDFW Rule Change Proposal #69 (MA4B lingcod season restriction)

Dear WDFW, I am writing to express my deep concern regarding WDFW's "# 69. Reduce lingcod season in Marine Area 4B" rule change proposal. If this rule went into effect it would have a HUGE impact on Washington's fishing community and the economy that supports it. Additionally, I believe this rule change would create a serious safety issue. Most importantly, the data behind this proposal does not justify the action.

I understand that this rule change is being considered in order to reduce the by catch of "protected" rockfish species. We anglers are very interested in conservation, because we know if we are not, we are compromising the future of the sport we love. However, as avid fishermen of area 4B for Lingcod, the by-catch issue just does not correlate for me and my colleagues at the North West Kayak Anglers (NWKA). We know from experience that very few rockfish are caught while targeting Lingcod. And, it is rare to catch Canary or Yelloweye in 4B due to the 120 foot depth restriction. If you are catching rockfish, you either change bait or move. Nobody wants to sit there and catch rockfish after rockfish that are illegal to retain.

But we didn't want to rely on our own experience alone, so we inquired to WDFW to find out what data was used to back the proposal. A WDFW representative sent us data that was from 2010 and 2011 dockside sampling. This sampling occurred throughout the entire season and has standard statistical methods for determining complete harvest from MA4B. This data, which the WDFW considers valid, shows that for each legal Lingcod caught, 1.6 “protected” rockfish were caught.

Furthermore, according to this WDFW document: http://wdfw.wa.gov/publications/00035/wdfw00035.pdf "...For rockfish found in Puget Sound, mortality rates of released rockfish from 120 feet (36 m) or less in depth ranged from 17% to 37%." During the dockside sampling period, the total number of "protected" rockfish encountered in 4B was on average 4195 rockfish per year. Considering the mortality rates above, this translates to 712-1552 rockfish that perished. Consider that there were 18,905 black rockfish retained per year on average. Now, if you considered only Yelloweye and Canary, there were 242 Yelloweye and 642 Canary encountered per year on average. The resulting mortality would be 41-90 Yelloweye and 109-238 Canary.

The 120 foot depth restriction already sufficiently protects rockfish, which is why the WDFW itself is estimating a survival rate of roughly 75%. And the average depth Lingcod are targeted (by NWKA estimation) is 70-80 feet, which gives rockfish an even better chance.

While by-catch is never great, it is a reality in both commercial and sportfishing and there is an acceptable threshold…these numbers just do not merit a 75% reduction in the Lingcod sportfishing season for 4B, from 180 to 45 days. That is the most important reason why this rule change proposal should not be passed. And if that weren't enough, here's a couple more…

The first is safety. Because of its unique geographical situation, 4B allows anglers access to rich, world-class, ocean fishing with good protection from westerly wind and swell. Naturally, 4B is fished by anglers with smaller boats that can't normally fish the ocean side (4A), and by almost ALL boats on choppy or bigger swell days. Severely restricting 4B to bottomfishing will likely result in more boats taking risks they shouldn't, by trying to fish 4A.

A scenario: A few guys with a smaller boat, an 18', plan a July weekend out at Neah Bay targeting bottomfish. Saturday's weather is great, they get out to 4A and the fishing is good. Sunday the weather is marginal...the kind of day they would in the past stay in 4B, but with the rule change they can't. Rather than cut their big fishing weekend short, they take the risk and run out to 4A...and put themselves in danger and those that have to come to their aid, be it private boats or the Coast Guard.

And for every scenario like that, there will likely be many trips that get cancelled because 4B would no longer be an option. Because of fast-changing coastal weather, planning a fishing trip where only 4A is fishable is too risky, given 4B would be illegal to bottomfish. Not to mention the many, many trips never even planned by those who ONLY fish 4B. That would add up to a lot of fishing trips that never get made.

Which leads to another important factor…economic impact. Neah Bay is a community that depends on sport fishing, of which 4B's Lingcod season is a large part. Guides, foodservice, lodging would all take a severe hit. And it's not just Neah Bay, but all the towns in the Olympic Peninsula anglers pass through on their way to Neah Bay, where they stay, eat and fill up their tanks. Then the tackle shops across Washington that won't sell the bottomfishing gear, the manufacturers who make that gear…even lost WDFW license revenue from those who come from out of state just to fish Neah Bay (it is, most definitely, a world-class fishing destination). And that's just naming a few.

The American Sportfishing Association reported that Washington State's saltwater fishing economy is worth nearly $600 million http://asafishing.org/uploads/2011_ASASportfishing_in_America_Report_January_2013.pdf. It's hard to say how much of that MA4 is responsible for, but given that area 4B's unique geographic protection from the ocean, access to world-class fish, and the fact that it's considered fishing heaven by so many anglers...I'm quite certain it's responsible for a good chunk. The economic ripple effect of this rule change would be devastating. Please consider the livelihoods that would be impacted by this single rule change.

Fishing is something I am very passionate about, and 4B is one of my favorite places to fish on this earth. It's a place myself and my fishing friends visit often throughout the 180-day season (most of those trips take place AFTER June 15, when the weather is more predictable). Marine area 4B's fishing, and it's beauty, is unparalleled. Please do not make this proposal a rule change.

Thanks for your consideration and all of your hard work,

R. O'Connor