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Water Users respond to CVPIA Workplan

Water Users respond to CVPIA Workplan

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Published by Cannon Michael
Water Users criticize CVPIA workplan to restore salmon
Water Users criticize CVPIA workplan to restore salmon

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Categories:Types, Letters
Published by: Cannon Michael on Apr 25, 2012
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04/25/2012

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 April 25, 2012Mr. Dan CastleberryAssistant Regional Manager - FisheriesU.S Fish and Wildlife Service2800 Cottage Way W2606Sacramento, CA 95825Mr. Don GlaserRegional DirectorMid Pacific RegionU.S Bureau of Reclamation2800 Cottage WaySacramento, CA 95825-1898Rodney McInnisRegional AdministratorNational Marine Fisheries ServiceSouthwest Regional Office501 West Ocean Boulevard, Suite 4200Long Beach, CA 90802-4213Charlton H. BonhamDirectorCalifornia Department of Fish and Game1416 Ninth Street Sacramento, CA 95814Re: CVPIA Workplan
2012Gentlemen:The undersigned entities have concerns with the Central Valley Improvement Act (CVPIA) work plan for 2012 with respect to efforts to improve salmon abundance inthe Central Valley. We assert the federal and state fishery agencies
programs toimprove the abundance of salmon in the Central Valley need to be reevaluated andradically revised.
San JoaquinTributary Association
 
CVPIA Workplan
2012Page 2April 25, 2012We have read with interest the March 22 letter from the Golden Gate SalmonAssociation (GGSA) on the CVPIA workplan and we generally agree with itscriticisms. Specifically, we support the conclusions in the first full paragraph onpage 2 of the GGSA letter that states in part 
the 2012 (CVPIA) Restoration work plans that have been prepared by USFWS and USBR are not really plans. They aresimply a collection of hundreds of projects that have been proposed by field officesof the two agencies. Many of these projects are well conceived by capable anddedicated staffs and will provide some benefits to salmon at some point. What ismissing is management oversight to see that the plans that are proposed andaccepted are focused on the reasons the salmon runs have declined and are focusedon the best investments to begin the early rebuilding process.
They go on to state
:
Many of the projects take place in the tributaries but there is no analysis made of whether or not additional enhancements in a tributary will in fact produceadditional smolts to the ocean at an early date and adults to return three years later.On the San Joaquin side, smolt losses in the South Delta are near 100%. Hundreds of thousands of additional smolts would have to be produced in the tributaries to haveany true net impact on an increase in San Joaquin populations. The plan ignores thiskind of analysis in its San Joaquin expenditures. The same kinds of problems exist on the Sacramento side. In some instances, up to 90% of the smolts perish on their
way down the river…
.
How can the CVPIA or the aggressive San Joaquin River Restoration Programpossibly improve salmon abundance and thus succeed if survival in the lower SanJoaquin River and in the South Delta is nearly zero? As summarized by the SWRCBin their March 2012 science review of the San Joaquin River (see page 3- 39) thisdrop in survival is a recent event. They noted that Independent Science Review of the Vernalis Adaptive Management Program (VAMP) data found that 
survivalestimates from Mossdale or Dos Reis to Jersey Point were just greater than 1% in2003 and 2004 and the estimate was only about 12% in the very high flow year of 2006. This compares to survival estimates that ranged between about 30% and80% in the years 1995 and 1997 to 2000.
” The likely
cause for this decrease insurvival is the marked increase in aquatic weeds that provide better habitat forinvasive predatory fish like largemouth bass and black bass. These predatory fishfeed on young salmon and they are now so numerous that catch and releasetournaments are held regularly.
The recent study entitled “Individual
-level andPopulation-level Historical Prey on Demand of San Francisco Estuary Striped Bass
Using a Bioenergetics Model” seems to support the notion that som
e of the non-native predators are an extensive source of mortality and yet, the fish agencies arenot taking any action to rectify this problem.A much more holistic approach to salmon protection, which includes all life stagesand includes ocean conditions and harvest, is needed than that currently providedby the state and federal fishery agencies. Considerable work has been conducted inupstream areas to enhance fish passage, including the construction of state of the art fish screens. Without a holistic approach, these efforts could be squandered bypredation in the Bay-Delta or other stressors that adversely affect fish during their
 
CVPIA Workplan
2012Page 3April 25, 2012various life-cycles. We have independently reviewed the salmon programs of each of the three fishery agencies and have come to the same conclusions of the GGSA. Inaddition to no single comprehensive strategic approach to salmon restoration, thereare no integrated performance measures to gauge success or failure of actions. Acomprehensive overhaul of these programs is needed.Of the three plans we reviewed, the NMFS plan is the most thoughtful from a scienceperspective. The NMFS plan attempts to lay out processes to recover listedanadromous salmonids by following a science-based approach that examines thereasons behind current problems limiting recovery, then proposing actions toaddress those problems. The lack of sufficient coordination among the threeresource agencies is a key factor that is visibly apparent when examining all theinconsistencies among plans, including the general lack of agreement amongagencies as to what actions should be implemented and by whom.
NMFS, under advisement of the Pacific Fishery Management Council (“PFMC”),
currently regulates ocean fishing of Central Valley fall-
run Chinook (“CVF”) based
solely on the Sacramento River population. The existing conservation objective forCVF was developed before the CVPIA. Unfortunately, the conservation objective hasnot been revisited since passage of the CVPIA and, as a result, was not developedwith consideration of the doubling goal. Ocean harvest regulations developed sincethe passage of the CVPIA have similarly failed to incorporate the doubling goal. As aresult, NMFS has not evaluated whether current fishery management practicesimpede doubling natural production. Current rates of ocean harvest areunsustainable without hatchery augmentation and modernization of hatcherypractices, yet neither NMFS nor the PFMC distinguish between hatchery and naturalCVF.
We support the GGSA’s call for
a review and overhaul of the CVPIA salmon programbut believe it needs to go beyond CVPIA and integrate with all the activities of thestate and federal fishery agencies related to salmon. While many of these programsfocus on natural production, specific actions are needed to make the salmonidhatchery programs more efficient in producing fish for harvest in the ocean whileminimizing impacts to natural populations, to reduce straying, and to minimizeharvest take of listed species. Hatchery production is over half of the ocean catch off 
California’s c
oast. Also, hatchery produced fish on average make up over half thenatural area escapement in the Central Valley and ranges from 22% to 96% of thetotal number of salmon returning to spawn (as documented in the March 2012report on results from the constant fractional marking program by the Department of Fish and Game). It is time to define the role of hatcheries in overall salmonmanagement and implement programs to enhance natural production whileretaining the benefits of improved ocean abundance provided by hatcheries.A new restoration strategy should be science-based, pragmatic, and candid about realistic goals and the opportunities for anadromous salmonid restoration inrecognition of the importance of salmon hatcheries. The plan should be routinely

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