Portland, Oregon 97280


(503) 977-0287


Email:  bmbakke@teleport.com


                                                                             


February 4, 2000





Memorandum





TO:     Federal Caucus


FR:     Bill M. Bakke, Director


RE:     Comments on the All-H Paper





General Comments:





The All-H Conceptual Recovery Plan needs to have a preferred alternative 


identified for public review.  The Native Fish Society is looking for a 


combination of factors that will lead to recovery of native, wild 


salmonids in the Columbia Basin.  This means a preferred alternative 


must be consistent with the ESA.  The stated purpose of the ESA (Section 


2(b)) is to conserve natural populations in their native ecosystems.  


The purpose of the ESA is to recover native species in their natural 


environment.  From our point of view the most restrictive approaches in 


the array of alternatives seems to more closely match the purpose of the 


ESA and species recovery.





Hydroelectric Options:





The Native Fish Society supports option three, the removal of the four 


lower Snake River dams. We also recommend the lowering of John Day 


reservoir by 50 feet to improve rearing and spawning habitats in the 


river that is now flooded.


      Given the fact that ESA-listed salmon and steelhead are not 


replacing themselves in most years, suggests the mortality burden on 


these fish populations is too high.  In years of poor ocean productivity 


the salmon cannot cope with the mortality imposed upon them in their 


life cycle, so the only option for recovery and maintaining salmonid 


health in the Snake Basin is for dam removal.  During years of  strong 


ocean productivity, the salmon may be able to cope with the life cycle 


mortality profile that includes dams, but they will not be strong enough 


to cope when the ocean productivity cycle moves to a low productivity 


phase.  Based on this relationship between hydro dam related mortality 


and ecological productivity over the full life cycle of the ESA-listed 


species, there is no alternative but to remove the four lower Snake 


River dams and lower John Day reservoir.


       With that said, it is our belief that dam removal is but a tool 


in ESA-salmonid recovery tool kit.  Unless all other factors are 


addressed to improve the health, abundance, and productivity of native 


salmonid populations, the removal of dams will not result in the 


recovery of ESA-listed species.  Dam removal is not a silver bullet that 


by itself will fix the salmon problem of declining populations and 


continuing extinctions.





Harvest Options:





The Native Fish Society supports option number 3, which calls for 


conservation fishery management.


       As the term "management" implies, harvest management should be 


tied to biological objectives by species, especially ESA-listed 


species,that ensure stock structure, abundance, distribution, and 


adaptive diversity of native, wild populations is accomplished annually.  


Each native, wild population should have biological goals associated 


with it which harvest management is required to achieve.  If on 


evaluation, harvest management, by itself, is unable to accomplish these 


goals, all other factors should be managed to assist distressed 


populations.  A comprehensive recovery program requires that all of the 


"Hs" contribute in concert to recovery. At this time harvest management 


impacts on listed species have been reduced in some instances, but the 


ESA-listed adult salmonids continue to be harvested and that is forgiven 


by the federal government.


         In 1995 the NMFS identified 39 populations of spring and summer 


chinook in the Snake Basin and said that spawner abundance should be 


from 150 to 300 per population, and to fall below that level constitutes 


jeopardy. Well, these populations have dropped below this range and some 


populations have become zeros.  Given this situation, the NMFS and the 


fish agencies have continued to kill ESA-listed salmonids in sport and 


commercial fisheries.  This continued killing of adults needed to 


recover ESA-listed species is contributing to the decline and extinction 


of listed species.  Even though the decline in Snake River populations 


has triggered a jeopardy response by NMFS, the agency remains silent.


         Harvest management must be moved into conservation framework 


where it is expected to accomplish biological standards by population.  


Until this takes place as a function of federal sanctioned harvest 


management, there can be no recovery of listed species, even if the dams 


are removed.





Hatchery Options:





The Native Fish Society supports option three that calls for an increase 


in conservation programs and a decrease in mitigation programs.


       The Columbia River hatchery program, especially those hatcheries 


operated or funded by the federal government, should be moved into a 


conservation framework for recovery of native, wild salmonids listed 


under the ESA.


         While making this recommendation, we believe the scientific 


literature is sufficiently full of caution regarding the use of 


hatcheries for rebuilding wild populations, that specific standards for 


such hatchery operations are required.  According to the ESA (Section 


2b) artificial propagation of listed species is to be used only when 


other, less intrusive recovery methods have failed, are likely to fail, 


or are shown to be ineffective in overcoming extant limiting factors. 


(USFWS/NMFS 1996).  The ESA requires that native species in their 


habitat be recovered so that they are self-sustaining.  Populations 


dependent upon hatchery production are not self-sustaining and in most 


cases, populations that have increased under hatchery supplementation 


have declined to pre-supplementation levels once the hatchery option is 


turned off.


         In addition to spelling out specific biological standards for 


hatchery operations, the federal agencies should also develop a 


representative list of reference populations of wild, native salmonids 


in the basin to act as controls to the hatchery experiment.


         We also recommend the federal agencies adopt a native, wild 


fish conservation framework and strategy with biological goals.  Even 


though billions have been spent on salmonid recovery in the Columbia 


Basin, there is still no native fish conservation strategy for the 


basin.  There is no technical working group with the specific 


responsibility of native fish conservation.  Lacking a native fish 


conservation framework and objectives, the federal agencies cannot 


recover the ESA-listed species nor can they put a plug in the ESA 


pipeline.





Habitat Options:





The Native Fish Society supports option 3 which would increase the 


federal role under the Endangered Species Act and the Clean Water Act.


    Voluntary programs such as those proposed by Oregon under the Oregon 


Plan for Salmon and Watersheds are a failure because it is voluntary.  


It is helpful for local jurisdictions to develop actions to recover 


native salmon populations, but they are greatly encouraged to do so if 


there is a federal enforcement presence.  Initially, there was great 


interest on the part of local jurisdictions in doing the right thing for 


salmon as long as they believed in a federal response if they did not do 


their job.  But now these same local jurisdictions are relaxing as they 


realize NMFS or other federal agencies are not very interested in 


enforcement.  Will Stelle recently recommended that the NGO's enforce 


the federal regulations rather than his own agency, NMFS.


         If the federal government is going to embrace local solutions 


to salmon habitat problems, then there should be a means to evaluate 


those solutions, to determine whether they are having a cumulative 


benefit for salmon across jurisdictions, and the enforcement capacity to 


bring about compliance.  Compliance monitoring would be a helpful 


function to be included in a habitat option.


         We recommend that the federal government shift monies away from 


local projects to one of funding enforcement monitoring.  By funding the 


Oregon State Police (and their counter-parts in other states and the 


tribes) to enforce existing regulations protecting habitat, the federal 


dollars will be spent with more meaning and benefit.  If the enforcement 


program identifies problems that need funding to correct, then the 


agency, jurisdiction, or affected public could apply for a federal grant 


to solve the problem.  This would place federal funding into a category 


where it not only supports environmental protection but targets funds 


toward problems that have been identified.





Conclusion:





     I would like to reiterate that an integrated approach to salmon 


recovery involving all of the factors limiting salmonid productivity 


should be taken.  We have become diverted in the belief that removing 


dams is all that we need to do to save salmon.  The salmon problem is 


complex and it requires a comprehensive approach based on biological 


standards and compliance monitoring and evaluation of results.