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April 25, 2012 Mr. Dan Castleberry Assistant Regional Manager - Fisheries U.S Fish and Wildlife Service 2800 Cottage Way W2606 Sacramento, CA 95825 Mr. Don Glaser Regional Director Mid Pacific Region U.S Bureau of Reclamation 2800 Cottage Way Sacramento, CA 95825-1898 Rodney McInnis Regional Administrator National Marine Fisheries Service Southwest Regional Office 501 West Ocean Boulevard, Suite 4200 Long Beach, CA 90802-4213 Charlton H. Bonham Director California Department of Fish and Game 1416 Ninth Street Sacramento, CA 95814 Re: CVPIA Workplan – 2012 Gentlemen: The undersigned entities have concerns with the Central Valley Improvement Act (CVPIA) work plan for 2012 with respect to efforts to improve salmon abundance in the Central Valley. We assert the federal and state fishery agencies’ programs to improve the abundance of salmon in the Central Valley need to be reevaluated and radically revised.
CVPIA Workplan – 2012 Page 2 April 25, 2012 We have read with interest the March 22 letter from the Golden Gate Salmon Association (GGSA) on the CVPIA workplan and we generally agree with its criticisms. Specifically, we support the conclusions in the first full paragraph on page 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 are simply a collection of hundreds of projects that have been proposed by field offices of the two agencies. Many of these projects are well conceived by capable and dedicated staffs and will provide some benefits to salmon at some point. What is missing is management oversight to see that the plans that are proposed and accepted are focused on the reasons the salmon runs have declined and are focused on 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 produce additional 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 have any true net impact on an increase in San Joaquin populations. The plan ignores this kind 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 Program possibly improve salmon abundance and thus succeed if survival in the lower San Joaquin River and in the South Delta is nearly zero? As summarized by the SWRCB in their March 2012 science review of the San Joaquin River (see page 3- 39) this drop in survival is a recent event. They noted that Independent Science Review of the Vernalis Adaptive Management Program (VAMP) data found that “survival estimates from Mossdale or Dos Reis to Jersey Point were just greater than 1% in 2003 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% and 80% in the years 1995 and 1997 to 2000.” The likely cause for this decrease in survival is the marked increase in aquatic weeds that provide better habitat for invasive predatory fish like largemouth bass and black bass. These predatory fish feed on young salmon and they are now so numerous that catch and release tournaments are held regularly. The recent study entitled “Individual-level and Population-level Historical Prey on Demand of San Francisco Estuary Striped Bass Using a Bioenergetics Model” seems to support the notion that some of the nonnative predators are an extensive source of mortality and yet, the fish agencies are not taking any action to rectify this problem. A much more holistic approach to salmon protection, which includes all life stages and includes ocean conditions and harvest, is needed than that currently provided by the state and federal fishery agencies. Considerable work has been conducted in upstream areas to enhance fish passage, including the construction of state of the art fish screens. Without a holistic approach, these efforts could be squandered by predation in the Bay-Delta or other stressors that adversely affect fish during their
CVPIA Workplan – 2012 Page 3 April 25, 2012 various 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. In addition to no single comprehensive strategic approach to salmon restoration, there are no integrated performance measures to gauge success or failure of actions. A comprehensive overhaul of these programs is needed. Of the three plans we reviewed, the NMFS plan is the most thoughtful from a science perspective. The NMFS plan attempts to lay out processes to recover listed anadromous salmonids by following a science-based approach that examines the reasons behind current problems limiting recovery, then proposing actions to address those problems. The lack of sufficient coordination among the three resource agencies is a key factor that is visibly apparent when examining all the inconsistencies among plans, including the general lack of agreement among agencies 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 for CVF was developed before the CVPIA. Unfortunately, the conservation objective has not been revisited since passage of the CVPIA and, as a result, was not developed with consideration of the doubling goal. Ocean harvest regulations developed since the passage of the CVPIA have similarly failed to incorporate the doubling goal. As a result, NMFS has not evaluated whether current fishery management practices impede doubling natural production. Current rates of ocean harvest are unsustainable without hatchery augmentation and modernization of hatchery practices, yet neither NMFS nor the PFMC distinguish between hatchery and natural CVF. We support the GGSA’s call for a review and overhaul of the CVPIA salmon program but believe it needs to go beyond CVPIA and integrate with all the activities of the state and federal fishery agencies related to salmon. While many of these programs focus on natural production, specific actions are needed to make the salmonid hatchery programs more efficient in producing fish for harvest in the ocean while minimizing impacts to natural populations, to reduce straying, and to minimize harvest take of listed species. Hatchery production is over half of the ocean catch off California’s coast. Also, hatchery produced fish on average make up over half the natural area escapement in the Central Valley and ranges from 22% to 96% of the total number of salmon returning to spawn (as documented in the March 2012 report 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 salmon management and implement programs to enhance natural production while retaining 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 in recognition of the importance of salmon hatcheries. The plan should be routinely
CVPIA Workplan – 2012 Page 4 April 25, 2012 revised to reflect new information, accomplishments, and failures. If the recommended approach is not taken, it would appear that the resource agencies will continue to repeat the same debates into the future leaving the anadromous salmonid resource at risk. We intend these comments to be constructive and are truly committed to help make these programs more effective in the future. We look forward to working with you, the GGSA, and others in your ongoing efforts to improve the abundance of salmon in the Central Valley. Sincerely yours,
David Guy Northern California Water Association
Allen Short San Joaquin Tributary Association
Terry Erlewine State Water Contractors
Dan Nelson San Luis Delta Water Authority cc: Mike Conner, Commissioner John Laird, Secretary Jerry Meral, Assistant Secretary Golden Gate Salmon Association
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