Emergency Rule Change Proposal - Wild Steelhead Management Zones, North Fork Stillaguamish River

http://wildsteelheadcoalition.org/2014/04/tell-wdfw-to-implement-emergency-rule-change-for-wsmzs-north-fork-stillaguamish/

 Emergency Rule Change Proposal - Wild Steelhead Management Zones, North Fork Stillaguamish River

As the result of some very recent events I believe that it is both appropriate and important that the Commission adopt the two regulation changes proposed below.  While I realize that these requests are outside the normal cycle for sport fishing regulation proposals, I believe that your consideration of their immediate implementation is justified.

Gene Bank Rule Change Proposal:  With the establishment of three Wild Steelhead Gene Banks on the EF Lewis, NF Toutle/Green and Wind Rivers we are requesting an immediate change that would result in (1) the mandatory release by anglers of rainbow trout on these rivers (2) a mandatory gear change to require the use of only single barbless hooks (3) require that hooked rainbow trout not be removed from the water before release and (4) mandatory retention of hatchery steelhead.

Rationale:  In an effort to increase the success of these gene banks we should not delay in providing every reasonable opportunity for these wild steelhead populations to enjoy increased productivity. Given the modest size of resident rainbow populations in these rivers additional protection should be provided.  Also, now that these watersheds are designated Wild Steelhead Gene Banks it makes sense, for the next two years, to insure that hatchery fish caught not be released to potentially compete and spawn with wild steelhead.

Stillaguamish Rule Change Proposal: Request an immediate change that would result in the mandatory release by anglers of rainbow trout on the N.F. and S.F. Stillaguamish river and tributaries to help mitigate the future impacts resulting from the 'Oso Slide' of March 22, 2014. This would be accompanied by a mandatory gear change to require the use of only single barbless hooks on all reaches of the Stillaguamish watershed and require that hooked rainbow trout not be removed from the water prior to release.

Rationale:  Currently there is a major constriction on the NF Stillaguamish just downstream of C-Post with water pressure from upstream and significant siltation in the river.  None of us knows how Spring rains and runoff will impact this situation or what the downstream flow will be for 2014 and beyond.  What we can reasonably assume is that our ESA-threatened wild stock of Deer Creek steelhead is at significant risk due to this cataclysmic event.  As mentioned in the Gene Bank rule change proposals, our Puget Sound tributaries hold only modest resident rainbow populations which makes protecting their contribution to wild steelhead productivity that much more important.  Given the challenges these Stillaguamish fish will face it is quite probable that these fish will seek refuge in the S.F. Stillaguamish: similar to a life history strategy we saw occur after the Mt. St. Helens eruption in 1980. The NF Stillaguamish is a historic fly fishing river for steelhead and in June-November is fly fishing only with a single hook barbless fly.  The SF Stillaguamish is open to all sport angling methods with no special gear regulations.  Given the reasonable possibility of some of these ESA listed steelhead taking up residence in the SF Stillaguamish there should be new concern for protecting them through special gear regulations and enhancing their spawning productivity by providing protection for resident rainbows.

I believe that each of these requests is consistent with the Natural Production policies and strategies defined in the 2008 Statewide Steelhead Management Plan.  I request that the Commissioners consider these proposed changes in a timely fashion to support implementation and public education prior to the opening of these rivers for angling in June 2014