NATIVE FISH SOCIETY


P.O. Box 19570


Portland, Oregon 97280


(503) 977-0287


Email:  bmbakke@teleport.com


										


		


April 2, 1998





Donna Darm


Protected Species Program


National Marine Fisheries Service


Northwest Region


7600 Sand Point Way, NE


Bin C15700, Bldg. 1


Seattle, WA 98115-0070





RE:	Take permits on steelhead kelts





Dear Ms. Darm:





	The repeat spawner life history of steelhead is unique among Pacific 


anadromous salmonids.  According to Mark Chilcote, Oregon Department of Fish 


and Wildlife, ãThe advantage of such a life history strategy in an unpredictable  


environment is adults have multiple chances to breed.  Therefore, there is an 


enhanced capacity to weather adverse fluctuations in environmental conditions.ä  


Repeat spawning is a buffer against habitat degradation, overfishing, and 


environmental fluctuation.


	Unfortunately, provisions for the safe passage of kelt steelhead and the 


potential for repeat spawners in the Columbia River have not been a factor in the 


operation of most dams.  Consequently, this important life history strategy in 


steelhead cannot be expressed and is actually selected against by the operation of 


dams and even irrigation diversions.  Also, the harvest of steelhead kelts in net and 


recreational fisheries should also be taken into account as a take requiring a permit.


	Since repeat spawning is an important factor in steelhead productivity, if 


allowed to be expressed, it should be included in the take permit process under the 


Endangered Species Act.


	I have addressed this issue in my comments to NMFS regarding the 


operation of upper Columbia Steelhead ESU hatcheries, but I wanted to raise this 


issue specifically with you so that policy direction can be developed for all 


steelhead ESUs.





Sincerely,








Bill M. Bakke, Director