TCA Comments to IDFG

To: Fr: Dt: Re:

Joe Dupont, Idaho Fish and Game Lance Hebdon, Idaho Fish and Game David Moskowitz, The Conservation Angler June 17, 2021 Wild Steelhead Conservation Measures related to Proposed Clearwater River Season Options

The Conservation Angler (TCA) submitted comments to Idaho Department of Fish and Game (IDFG) yesterday within the comment format provided on the IDFG website. TCA provided limited comments directly on the proposed changes to steelhead and fall Chinook salmon seasons in the Clearwater River basin for the next three years (2022-2024). We are sending this memorandum to supplement those comments and address a larger set of issues facing wild Snake River Summer Steelhead.

The Proposed Season Structure Options While the proposed seasons may indeed provide exceptional angling opportunity on the Clearwater River (and by default on the Snake River), the focus of these changes are mis-directed because they do not address the conservation concerns involving Federally ESA-listed wild Snake River Basin summer steelhead that are well known and remain largely unaddressed.

Effect of Excessive Bag Limits for Hatchery Steelhead The proposed seasons for 2021-2024 and the associated bag limits will result in excessive encounters by sport anglers of the wild Snake River summer steelhead. These encounters will be especially hard on wild summer steelhead due to the widespread use of bait, treble hooks, and the allowed practice of removing wild steelhead from the water when being landed – in boat fisheries and by bank anglers – all of whom are required to safely release all adipose-intact steelhead.

Encouraging High Encounter Rates The proposed steelhead season structures focus on providing a high likelihood of encounters with a small number of wild steelhead. As avid anglers, we understand the desire or anticipation of multiple hook ups with one of the most exciting fish you can fish for in fresh water. However, the collective and cumulative impact of multiple sport fishing encounters is unmonitored and unstudied but can only exceed Idaho’s current estimated post-release mortality percentages.

There is ample evidence in Washington and Oregon that most steelhead fisheries encounter more wild steelhead than the target hatchery steelhead – even when hatchery-origin steelhead greatly outnumber their wild counterparts. Wild steelhead are aggressive by virtue of their genetic lineage – something bred out of hatchery-origin steelhead. This phenomenon – well understood and confirmed by anecdotal and logbook entry evidence – even gave rise to a so-called “biter study” by the Oregon Hatchery Research Center (OHRC) to see if aggressiveness could be preserved in hatchery fish (it turns out the opposite is true).

These excessive encounters with wild steelhead will only be increased by the concurrent fall chinook and coho salmon fisheries that were implemented in 2020 and proposed for the new season regimes as well.

There was no information provided on the number of steelhead encounters in the salmon fisheries.

Collectively, Idaho’s steelhead fisheries result in excessive mortalities at a time when wild Snake River summer steelhead will return in extremely low numbers (after an unexpected one-year increase in abundance in 2020-2021).

Allowing Fishing During Spawning Idaho also continues to allow liberal winter and spring sport seasons on steelhead, which disperse into many watersheds. These winter and spring fisheries allow angling on staging and spawning wild steelhead. IDFG responses to this concern in the past have been that only streams with hatchery steelhead are open during these late season periods. This creates myriad problems for wild steelhead because IDFG has no means to ensure that wild steelhead and hatchery steelhead are segregated. Furthermore, by allowing these late season fisheries on hatchery-origin steelhead, the likelihood is that any wild steelhead returning to these hatchery steelhead sacrifice areas will be caught numerous times. The likely impact of these encounters is wild steelhead not having enough energy remaining to successfully spawn – further dampening prospects for wild steelhead recovery.

Productivity and Survival Metrics Should Come Before Fisheries IDFG’s season setting proposals under consideration are putting the cart before the horse. Idaho does not have spawning escapement criteria by river and by population. Nor does IDFG have egg deposition criteria by river or even by distinct population segment (DPS). Wild steelhead survive and thrive because of their genetic and life-history diversity – and the strategies they deploy include dispersal and return timing. Fishery management strategies designed to compartmentalize wild steelhead are destined to fail and to fail the wild fishes’ long-term survival.

The fact that IDFG can propose sport fishing seasons without addressing any of these species conservation issues further dampens prospects for their future survival and recovery.

Specific Recommendations to Future Steelhead Fishing Seasons 1. The Conservation Angler recommends that the bag limits be reduced throughout the seasons to a single hatchery steelhead to reduce the encounter rate for wild steelhead in all those fisheries.

2. TCA also would prohibit the use of bait in all anadromous fish fisheries, as well as require barbless single hooks (prohibiting use of treble hooks).

3. TCA recommends that IDFG require that all wild steelhead landed remain in the water – whether landed in a boat or from the bank.

4. IDFG should set longer catch & release seasons and shorter spring seasons to give wild steelhead the best opportunity to avoid lethal and sub-lethal encounters prior to staging and spawning.

5. IDFG should set numeric spawning escapement criteria in each river within the multiple DPSs that comprise the Major Population Groups in the Snake River Summer Steelhead ESU. 6. IDFG should set numeric egg deposition criteria in each river within the multiple DPSs that comprise the Major Population Groups in the Snake River Summer Steelhead ESU. IDFG's steelhead season proposals will hurt wild steelhead recovery because they are not collectively nor cohesively integrated in a holistic management approach for one of the world’s most diverse fish species.