Tuesday, December 15, 2009

Letter to the Fish and Wildlife Commission


Commissioners of the Washington State

Department of Fish & Wildlife

600 Capital Way North

Olympia, WA 98501

RE: Proposed Rules to Establish a Series of Wild Salmonid Management Areas

Dear Commissioners:

On May 31st of this year, the Steelhead Summit Alliance collectively, and the Wild Steelhead Coalition, Wild Fish Conservancy, Federation of Fly Fishers and the WA State Council of Trout Unlimited individually, proposed specific rules to create Wild Salmonid Management Areas (WSMAs) on 19 river reaches in Washington State. These proposals were submitted as part of the “major” rules proposal cycle.

It has been 18 months since the Statewide Steelhead Management Plan was adopted by the Commission and there has been no observable staff action to implement the WSMA proposals adopted in this document. Further, the Hatchery and Fishery Reform Policy passed by the Commission at its November meeting reiterates its intent in this regard and yet no progressive movement is being made on this critical item.

The WDFW staff has recommended the implementation of portions of some of the rules we proposed on several of the rivers recommended, but has refused to establish formal Wild Salmonid Management Areas on them. When our proposed rules are taken only in part, and do not specifically include the hatchery fish free zones, the intent is subverted and the results of the proposed rules are, at best, distorted. This is akin to cutting off one leg of a chair and expecting anyone to sit on it.

We strongly disagree with the staff recommendations to reject these proposals to establish uniform and formal WSMAs. As we noted in the introduction to our rules proposals, we have worked very hard to include only river reaches that would have little or no immediate impact by being formally categorized as WSMAs for the first tangible action in this regard. Yet the Department staff continues to completely reject the implementation of this policy.

We now request that the Commission direct the WDFW staff to approve the establishment of WSMAs on as many rivers as may be practicable at this time. We would be happy to consult with them on the particulars of this matter.


Sincerely,


Rich Simms

President

Wild Steelhead Coalition


Bill McMillan

President

Wild Fish Conservancy


Kurt Beardslee

Executive Director

Wild Fish Conservancy


Sam Mace

Vice-President of Conservation

WA Council of Trout Unlimited


Bill Redman

Steelhead Committee

Federation of Fly Fishers

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