Wild Fish Conservancy provided comments during the State Environmental Policy Act (SEPA) review of the Washington Fish and Wildlife Commission (FWC) Draft Resident Native Trout Harvest Management Policy.
The comments highlight the following concerns: harvest should not be permitted in areas where there is no data to determine the health of trout populations. Where conservation objectives are being met and backed by data, harvest could be considered. But absent data, the benefit of the doubt must go to protecting native fish.
Beyond this core issues, our comments also highlighted:
Failure to define “sustainability” with measurable standards, leaving key terms vague and unenforceable.
Assumption that recreational harvest is always compatible with conservation, without credible scientific justification.
A hollow use of “adaptive management,” with no actual decision rules or triggers to guide management changes.
A non-credible SEPA review, WDFW issued a Determination of Nonsignificance under the State Environmental Policy Act (SEPA), claiming the policy carries no risk of environmental harm in order to avoid a full environmental review.
Systemic failure to implement past Commission policies, such as the Hatchery and Fishery Reform Policy, raising serious accountability concerns.
Public transparency failures, including inadequate notice of the SEPA process that almost certainly suppressed public participation.
Scope of the policy ignores the compounding impacts of hatchery production, harvest and hatchery management are inseparably linked — yet once again, the Department has siloed these issues, treating hatchery impacts as if they are unrelated. WFC has repeatedly called attention to this omission in comments during other policy processes, and its continuation here undermines the credibility of the Department’s conservation claims.
Resource:
WFC’s Comments on the Washington Fish and Wildlife Commission (FWC) Draft Resident Native Trout Harvest Management Policy
Wild Fish Conservancy provided comments during the State Environmental Policy Act (SEPA) review of the Washington Fish and Wildlife Commission (FWC) Draft Resident Native Trout Harvest Management Policy.
The comments highlight the following concerns: harvest should not be permitted in areas where there is no data to determine the health of trout populations. Where conservation objectives are being met and backed by data, harvest could be considered. But absent data, the benefit of the doubt must go to protecting native fish.
Beyond this core issues, our comments also highlighted:
Failure to define “sustainability” with measurable standards, leaving key terms vague and unenforceable.
Assumption that recreational harvest is always compatible with conservation, without credible scientific justification.
A hollow use of “adaptive management,” with no actual decision rules or triggers to guide management changes.
A non-credible SEPA review, WDFW issued a Determination of Nonsignificance under the State Environmental Policy Act (SEPA), claiming the policy carries no risk of environmental harm in order to avoid a full environmental review.
Systemic failure to implement past Commission policies, such as the Hatchery and Fishery Reform Policy, raising serious accountability concerns.
Public transparency failures, including inadequate notice of the SEPA process that almost certainly suppressed public participation.
Scope of the policy ignores the compounding impacts of hatchery production, harvest and hatchery management are inseparably linked — yet once again, the Department has siloed these issues, treating hatchery impacts as if they are unrelated. WFC has repeatedly called attention to this omission in comments during other policy processes, and its continuation here undermines the credibility of the Department’s conservation claims.