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Hey Marc, no word on how it went, but this was fresh in the in box...
Carl Burke will be testifying on behalf of the industry on # 31 and 32 on Saturday. We hope you can join him or have sent in testimony already. Thank you.
December 3, 2009
Washington Fish and Wildlife Commission
600 Capitol Way N.
Olympia, WA 98501
Re: Opposition to Regulation proposal #31
Honorable Fish and Wildlife Commissioners,
The Northwest Sportfishing Industry Association appreciates this opportunity to comment on proposal #31 the use of single point, barbless hooks on all tackle when fishing in the Columbia River from Buoy 10 to McNary Dam. The NSIA represents over 300 businesses dependant on healthy fishery resources and meaningful sport fishing opportunity. NSIA’s businesses are the infrastructure for the nearly ¾ of a million Washington anglers. In 2006 our industry supplied 14,245 family wage jobs, generated over $1 billion in retail sales, while paying $88.5 million in state taxes and $117 million in federal taxes. NSIA seeks to represent economic, cultural and environmental health to the state.
Where ever conservation and economics have dictated, NSIA has led the charge for selective sport fisheries for the live release and eventual spawning of wild salmon and steelhead. Since our inception in 1993 this has been the number one goal of the association. We worked in Congress for funding of mass marking trailers, worked with Canadians, Tribes, the states of WA, OR, ID, CA and in the courtroom to make the marking of hatchery fish a reality. What currently is seen as a no brainer to mark hatchery fish has been a long effort to realize and utilize in fishery management. Without mass marking, the sport fishing industry would be a shadow of what it is today.
As ardent supporters of selective sport fisheries we are keenly interested in the release mortalities that are associated with our fisheries. Today, more than ever Endangered Species Act management is the limiting factor regardless of healthy wild and hatchery stock abundance, so limiting mortalities expands our opportunities to access abundant stocks.
In our review of the existing studies on catch and release it has been repeatedly demonstrated that it is the location of the hook, not the size, barbed or barbless, or treble hook that contributes to higher mortality rates. Hooks deeper in the mouth/throat tend to have a much higher mortality rate than hooks that are in the jaw area.
The State of Oregon rescinded barbless hook rules in 1997 during the “Simplification” attempts and following assessment of gear restrictions. It was determined, barbed or barbless was not a real biological issue but is often mandated by social or political pressures. The data presented to the Commission reaffirmed that hook placement was the major determinant. The other factor for increased mortalities can be water temperature. The fact that most of the fishable water in the Columbia River below Bonneville is in Oregon would seem to create a logistical nightmare for anglers and enforcement agents alike. We are reminded of the old adage, “Never create a bigger problem than the one you set out to solve”.
Furthermore, it appears that salmonids are less fragile in freshwater than in the Ocean. The Pacific Fishery management Council has set the release mortality for sport caught coho at 14% with an additional 5% “drop off” rate. In river, the mortality set by the Columbia River Technical Advisory Committee is 10%.
Currently there are hundreds of thousand of lures in the pipeline for Columbia River Salmon and Steelhead fisheries. Most tackle is ordered at buying shows early in the year for delivery several months later. The manufacturing part of the loop is several months ahead of the orders. A step removed from this process is hook purchases. For a manufacturer to receive the best pricing on hooks their orders are generally large enough to serve a years worth of manufacturing needs. Rendering hundreds of thousand of lures illegal to use and inconvenient to the angler should only be done under a demonstrated conservation emergency.
Annually, there are approximately 400,000 angler trips for salmon and steelhead from Buoy 10 to Bonneville Dam in fishing seasons that are generally capped by ESA mortalities. NSIA is keenly interested in reducing hooking mortalities on ESA constrained fisheries, as this can allow sport access to a larger share of hatchery fish. Given the nature of gears and active bait techniques that are used in the large Columbia River sport fisheries, solid studies may well demonstrate that release mortalities could be less than 10% in reality. We strongly support this kind of important research for use by managers to comply with their conservation obligations and to supply meaningful sport fisheries on abundant hatchery stocks. We trust that the use of this monitoring would be applied to the fishery in a time frame that would allow the industry an orderly change of tackle, should the change in hooks prove truly warranted.
Thank you again for the opportunity to participate in this discussion.
No economic impact? So a box of shells going from $5 to $20 doesn't impact my personal economy?
Posted by Tom Melowitz on September 7, 2019 at 2:45pm
Posted by Eric Urstad on April 3, 2019 at 7:38pm
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