The Minority Report: Standing Alone for Science-based Steelhead Recovery

The Minority Report: Standing Alone for Science-based Steelhead Recovery

As a member of the Puget Sound Steelhead Advisory Group (PSSAG), Washington’s Department of Fish and Wildlife (WDFW) asked me to share my knowledge, experience, and perspectives on recovering ESA-listed Puget Sound steelhead while enhancing sustainable recreational fishing opportunities. To that end I attended meetings for three years, finding common ground with 12 fellow advisors— all passionate recreational fishermen— where I could. The advisory group recently released a set of recommendations which outline a portfolio of watershed-specific fishery, hatchery, and conservation strategies for Puget Sound Steelhead. While there are some advisory group recommendations that I do support (those addressing the acknowledged lack of data necessary for responsible management and recovery planning), there are significant recommendations in the group’s final report “QuickSilver – Restoring Puget Sound Steelhead & Fisheries” that I cannot support. To that end I wrote a minority report to accompany QuickSilver.

To be clear, I share QuickSilver’s vision for a “…future in which wild Puget Sound steelhead are no longer threatened with extinction and are healthy enough to support fishing.” There is a time and a place for responsible recreational fishing. WDFW currently provides a diversity of angling opportunities for salmon, trout, steelhead, and other sport fishes; when monitored and managed responsibly, recreational fisheries can be sustainable even as angler demand grows— but that requires conservative management in the face of uncertainty. Over the past few decades recreational fishing opportunities have suffered as wild fish are impacted by habitat loss, human population growth, climate change, and data-limited fishery and hatchery management which is slow to respond to changing conditions. As WDFW looks to increase opportunities for recreational fishing, the agency needs to be thoughtful and realistic, and may at times need to disappoint today’s recreational anglers to meet conservation obligations for future generations. Expectations established previously may no longer be appropriate. Wild fish populations threatened with extinction are not ones to target for expanded recreational fishing pressure. Instead, existing hatcheries and recreational fisheries targeting threatened or endangered wild fish populations should be critically reviewed and monitored to ensure they align with the best available science, and changed if the risks they pose to wild fish recovery don’t far exceed the benefits.
One of the primary lessons the Advisory Group learned together is that WDFW needs better information than currently available to manage wild steelhead responsibly. State and federal steelhead managers are making decisions about harvest and hatchery management with limited data, and with models that do not account for crucial aspects of wild steelhead biology and ecology. Funding is needed to obtain critical wild steelhead data, hatchery data, and fishery data, and use them to develop models that more accurately predict the effects of various management actions and enable better goal-setting. The entire advisory group accepted this as true, and that is a Quicksilver recommendation I wholeheartedly support. The fact that this is still the case 13 years after Puget Sound wild steelhead were listed as Threatened under the Endangered Species Act is indicative of a management culture whose fiscal constraints cause it to prioritize fishing today ahead of science-based fishery management that will provide fisheries for future generations.
With this observation comes the question “how then do we move forward to restore wild steelhead and the fisheries they can support?”  QuickSilver describes a diverse portfolio of new Puget Sound steelhead hatchery and fishery programs to be added on to existing ones— an experiment. An effective experiment requires specific testable hypotheses; a rigorous, repeatable, and well-funded study design built on a strong understanding of the system you’re studying; experimental controls; an evaluation of data prior to implementation (i.e. before-time period); controlled manipulation of multiple independent variables; close measurement of their effect on multiple dependent variables; an adequate sample size to provide sufficient statistical power; an understanding of cumulative impacts from other (commercial, tribal) fisheries, non-WDFW hatchery programs, ocean conditions, and climate change; and sufficient post-implementation time periods to address substantial uncertainty and natural variability in fish responses. We don’t need all those details right now, but to support this experiment I must have confidence that they are attainable. Looking at the history of fishery and hatchery management in Washington, I don’t have that confidence. It was the absence of these scientific components that thwarted WDFW’s efforts in 2019 to perform a quantitative analysis of the effectiveness of WDFW’s Hatchery and Fishery Reform Policy (c-3619), as discussed in my minority report. Learn more about this policy.
Adding new fishery and hatchery pressures on wild steelhead as an ‘experiment’ at this point in the arc of Puget Sound wild steelhead decline strikes me as irresponsible. We don’t know enough about wild steelhead to know which of their independent populations can accommodate additional impacts— if any. The risks are too high, the state’s budget too uncertain, and the state’s commitment to effectively monitor and adaptively manage its fisheries and hatchery programs is as yet unproven. Instead WDFW should employ a responsibly precautionary approach: prioritize the commitment to science stated in its existing policies and permits, collect the overdue data needed for responsible management of its existing portfolio of permitted fishery and hatchery programs, use the data to responsibly manage its programs consistent with hatchery and fishery reform science, and follow the recommendations of its own science staff.
There is a long history of policymakers selectively ignoring inconvenient science in the name of near-term economic growth, or to appease vocal constituents; the nation’s failure to responsibly transition away from fossil fuels or to manage the COVID-19 crisis exemplify this.  We won’t outsmart nature.  Wild steelhead have proven to be incredibly resilient and adaptable when we get out of their way; and when their populations are strong they will support increased recreational angling.  This science-based approach to healthy wild steelhead populations and sustainable recreational fisheries requires constraint, but is more likely to be successful.

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