Charles,
I'm pretty sure your analysis is flawed. That number might be desirable, but it is not necessary. By law, NMFS analysis must use ". . . the best available scientific and commercial information available." If a number has not been calculated at the time of application or during the review period, then it is not among that best available information. Let's take a slightly deeper dive. From experience we know that the co-managers can't or won't finish the prior season's escapement estimate and the forthcoming season's pre-season runsize forecast until some time between mid-December or early January. Arbitrarily I'll select an amount of time, say 5 months minimum (typical) for NMFS to review and approve - with public comment opportunity - an application and issue its BO and or Section 4(d) rule, NMFS has bureaucratically created a pathway where you literally can't get there from here for a fishery intended to open February 1, given when this crucial latest season escapement and runsize data will be available and when the projected season is expected to begin. You sure as hell don't see Puget Sound Chinook fishing shut down for months or years awaiting the compilation of data and NMFS' analysis and approval. No, it's because the Skagit steelhead fishery is such a small niche, unaffected by big money and political influence, so WDFW and NMFS can bureaucratically afford to just not give a shit.
Ergo, I'm back to having Occupy Skagit issue an official declaration to NMFS, cc: WDFW; that the Skagit and Sauk are hereby open under WDFW's previously proposed CNR selective regulations. Fvck it.