Barry Thom
January 22, 2010
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January 22, 2010
Barry Thom, Acting Regional Administrator
NOAA - National Marine Fisheries Service, Northwest Region
7600 Sand Point Way N.E.
Seattle, WA98115
Subject: WRIA 8 Comments regarding the Draft Puget Sound Chinook Harvest Management Plan (HMP)
Dear Mr. Thom:
The WRIA 8 Salmon Recovery Council appreciates the opportunity to present our comments and concerns regarding the draft Puget Sound Chinook Harvest Management Plan (HMP) that was submitted to your office by the Puget Sound Indian Tribes and the State of Washington Department of Fish and Wildlife on November 25, 2009. Pat Pattillo from the Washington Department of Fish and Wildlife gave a presentation on the HMP at our Salmon Recovery Council on Oct. 15, 2009. At that meeting, we requested an opportunity to review the HMP. We will focus our comments only on the Lake Washington profile section of the HMP.
The WRIA 8 Salmon Recovery Council is responsible for the implementation and adaptive management of the Lake Washington/Cedar/Sammamish Watershed (WRIA 8) Chinook Salmon Conservation Plan that was adopted by NOAA Fisheries as a chapter in the Puget Sound Salmon Recovery Plan. The goal of the WRIA 8 Plan is “preserve, protect and restore habitat with the intent to recover listed species, including sustainable, genetically diverse, harvestable populations of naturally spawning Chinook salmon.” To that end local, state and federal governments have invested more than $90 million over the past decade in fish passage improvements, acquisition of riparian and headwater properties and restoration of habitat that benefit the Chinook in the WRIA 8 watershed and many other species of fish and wildlife. There have also been significant regulatory changes to protect habitat that have affected jurisdictions, businesses and private property. We have partnered with the co-managers to monitor Chinook populations in our watershed for over 10 years and in 2010 will conduct our second year of monitoring habitat conditions in the watershed. Our technical committee has been meeting with the co-managers to discuss integration of harvest, hatchery and habitat salmon recovery actions in WRIA 8 for the last three years. To maximize return on these investments and as partners in salmon recovery, we ask that harvest management be appropriately conservative while these stocks recover. We feel that the draft HMP as it is currently written does not provide adequate protection for Lake Washington Chinook populations.
Barry Thom
January 22, 2010
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Barry Thom
January 22, 2010
Page 1 of 4
After reviewing the Lake Washington profile in the HMP, we have a number of concerns that include:
1. The HMP appears to be inconsistent with the Puget Sound Salmon Recovery Plan because it does not recognize the Sammamish River Population as essential to the recovery of the Puget Sound Evolutionarily Significant Unit (ESU). See p. 184 of the HMP: “The co-managers believe the SammamishRiver population is not essential to recovery of the Puget Sound ESU [Ecologically Significant Unit]. Additional constraints on harvest are not warranted.” The Puget Sound Chinook Recovery Plan and NOAA’s Supplement to the Puget Sound Chinook Recovery Plan are clear that all 22 remaining populations of Chinook are needed for recovery: “To lower the risk of extinction of the Puget Sound Chinook ESU, all existing independent populations of Chinook salmon must show improvement from their current conditions, and some will need to attain low risk” (p.134, Puget Sound Salmon Recovery Plan).
2. The HMP only has management thresholds for the Cedar River population in WRIA 8. We feel that there should be management thresholds for both the Cedar River population and the Sammamish population and that those thresholds should be for natural origin (wild) Chinook rather than mixed hatchery/natural origin Chinook. Natural origin Chinook from the WRIA 8 watershed warrant protection under the Endangered Species Act. Natural origin Chinook, even though they may be descendents of hatchery fish, survive in selection pressures found only in the WRIA 8 watershed (such as migrating through the Lakes, the Ship Canal and Locks). This local adaptation makes natural origin Chinook critical to salmon recovery in the WRIA 8 watershed particularly for spatial and genetic diversity. Natural origin Chinook are also important for meeting Hatchery Scientific Review Group goals for the integrated program of the Issaquah Hatchery.
3. Recent escapement and production data do not support the proposed increase in exploitation rate for Lake Washington Chinook from the existing rate of 15% pre-terminal Southern United States rate to 20% Southern United States or a directed Chinook fishery in the terminal area (Shilshole Bay, Ballard Locks, Lake Washington) if the Upper Management Threshold (UMT) goal of 1,680 Chinook is reached. The HMP is incorrect to say that the Cedar River Chinook population “has recently been trending upward” (p. 177). 2007 was an unusually good year for Cedar River Chinook, but the return data for the 2008 and 2009 brood years are much lower and should be included in Figure 1, p. 180 (see attached technical comments on HMP for graph of Cedar River Chinook escapement data). Over all, Cedar River Chinook remain at critically low levels and are vulnerable to further decline, and should not face additional harvest pressure.
4. We think that the UMT of 1,680 (or 1,200 using the area under the curve or AUC method) Lake Washington Cedar River Chinook is too low. It is less than the long term recovery goal in the NOAA approved Puget Sound Chinook Recovery Plan of 2,000 to 8,200 (AUC). This discrepancy will not allow us to meet our recovery goals. The UMT should also be increased to reflect improved conditions and capacity in the Cedar River since the 1970s when escapement goals were developed for the Cedar River. The capacity of the Cedar River to support salmon has been increased significantly with fish passage at Landsburg opening up 12 miles of spawning habitat in 2003, an improved flow regime for both adult and juvenile salmon and other habitat protection and restoration efforts.
5. We contend that the Low Abundance Threshold (LAT) of 200 Chinook is too low to be protective of Lake Washington Chinook. The LAT (200) for Lake Washington Chinook is much lower relative to the UMT (1,680) when compared to the other Puget Sound management units (per Table 1, p. 3 of the HMP). The LAT to UMT ratio for Lake Washington Chinook expressed as a percentage is 12%. The closest any of the remaining Puget Sound management units come is 20% for the White River spring Chinook. All of the other management units have ratios greater than 30%, and range as high as 60% and 70% for the Snohomish and Stillaguamish populations.
In light of these concerns, the WRIA 8 Salmon Recovery Council requests the following:
1. A shorter, one year time frame, for the HMP rather than the proposed five years. We recognize that the co-managers need to get a harvest management plan in place in order to allow harvest in 2010, but we believe that the HMP as it is currently conceived does not provide an adequate level of protection for Lake Washington Chinook. The HMP should be updated to reflect more current information and allow for meaningful involvement with interested parties, especially the WRIA 8 Salmon Recovery Council.
2. That NOAA-NMFS and the co-managers recognize the Sammamish population as important to the recovery of the Puget Sound ESU and that all natural origin Chinook from the WRIA 8 watershed warrant protection under the Endangered Species Act.
3. That NOAA-NMFS not approve the proposed change in provisions for harvest of Lake Washington Basin Chinook. We believe that the Exploitation Rate Ceiling should be kept at 15% pre-terminal Southern United States and that no directed fisheries should be allowed on Lake Washington Chinook even if the proposed UMT of 1,680 fish is met until further studies are done justifying a change in the harvest provisions and upper management thresholds for Lake Washington Chinook populations are met on a regular basis.
4. That the UMT and LAT for Cedar River Chinook be raised to better reflect the increased capacity for salmon on the Cedar River and to be more conservative while these stocks recover and adjust to improving and expanded habitat.
5. Marked-selective fisheries need to be part of all harvest management plans for ESA listed species. Due to the Ballard Locks and the two lakes, there is a unique opportunity in WRIA 8 to have a marked-selective fishery on abundant hatchery Chinook. A marked-selective fishery would meet salmon recovery and Hatchery Science Review Group goals for WRIA 8 and provide enhanced opportunities for harvest of hatchery Chinook without putting depressed stocks of wild Chinook at greater risk. Furthermore, selective-marked fisheries could help avoid bycatch of sockeye stocks in WRIA 8 which are also depressed.
6. We ask that you consider our additional technical comments which are attached.
The WRIA 8 Salmon Recovery Council takes our role very seriously in the efforts to bring sustainable, genetically diverse, harvestable populations of natural origin Chinook back to the WRIA 8 watershed. We recognize that we do so with many partners, many competing needs and a very complex set of circumstances. We thank you in advance for considering our comments during your review of the HMP and request a meeting to discuss your response. Please contact Jean White (206) 263-6458 if you have any questions or to schedule a meeting with representatives of the WRIA 8 Salmon Recovery Council.
Sincerely,
Don Davidson, DDS
Chair, WRIA 8 Salmon Recovery Council
Mayor, City of Bellevue
cc:
Gary Locke, Secretary of Commerce
Jane Lubchenco, PhD, National Director, NOAA-NMFS
Susan Bishop, NOAA-NMFS
Norma Jean Sands, NOAA-NMFS
NOAA-NMFS Recovery Implementation Technical Team Members
Governor Chris Gregoire
Phil Anderson, Director, WDFW
Bob Everitt, WDFW
Washington Fish and Wildlife Commission Members
Isabel Tinoco, Muckleshoot Tribe
David Dicks, Puget Sound Partnership
Joe Ryan, Puget Sound Partnership
Jason Muvilhil-Kuntz, Puget Sound Partnership
WRIA 8 Salmon Recovery Council Members