July 23, 2013
Governor John Kitzhaber
900 Court St. NE
Salem, OR 97301-4047
Re: Coastal Multi-Species Conservation and Management Plan
Dear Governor Kitzhaber:
We, the undersigned, are writing to express our apprehension about the progress, pace and veracity of the above-referenced plan (the Plan) currently being developed by the Oregon Department of Fish and Wildlife. To that end, we are respectfully requesting your intervention to slow down development of this plan so that these issues might adequately be addressed.
When implemented, the Plan will establish policies intended to direct conservation and harvest on coastal rivers for decades. For a project so vital we feel the process is being needlessly rushed by ODFW. Compelling issues are being glossed over; some entirely ignored. As noted in the Plan summary, “The CMP does not represent major changes in hatchery or harvest management…”
Consequently, there is no necessity for rushing the process. None of its content appears time-sensitive. Substantive concerns we have include:
The Plan’s Goals
The Desired Future Status of the populations is the most basic element of the Plan, and was developed entirely by staff with no public input. In fact, it was specifically excluded from consideration or discussion at the Stakeholders Panel workshops. All other elements of the Plan are designed to reach this desired status. By aiming so low ODFW has effectively removed any obligation or effort to improve wild fish populations on the coast.
Kill of Wild Steelhead
Curiously, the Plan calls for expanded kill of wild steelhead. Curiously, because of the 15 Distinct Populations Segments of steelhead on the West Coast, 12 are listed as threatened, endangered, or an area of concern (Wild Steelhead Coalition). Not one of these populations has been recovered or de-listed from the ESA.
The Plan says “…given the strong biological status of winter steelhead, a very modest wild harvest is proposed…” Nowhere in the Plan does it show whether the stocks are sustainable and adequate to allow this. To the contrary, the current wild steelhead populations in coastal rivers are 83% – 90% depleted since the 1920s (Cleaver, 1951). Yet, ODFW says they are healthy. This part of the Plan has little, if any, public support.
Of the four public stakeholder groups created to provide ODFW with public input, not one is supportive of the kill of wild steelhead. Perhaps most telling, virtually every fish conservation group, including those normally diametrically opposed to each other, share unanimity in opposing this.
In view of such diverse and widespread opposition, this calls for further evaluation.
Native Fish Conservation Policy
State law mandates that the development of conservation plans such as this must adhere to the Native Fish Conservation Policy (NFCP). The NFCP says “….conservation of naturally produced native fish species…is the ODFW’s principal obligation for fish management.”
An impartial review of the Plan will conclude its primary objective is not conservation, but rather enhanced angler opportunity, defined as providing fish for harvest.
An early hint of this is the fact that the term ‘conservation’ does not appear once in the table of contents.
We insist that ODFW assure Oregonians that the Plan meets the requirements of the NFCP. The next Stakeholder’s discussions offer a sensible opportunity for ODFW to explain precisely how the Plan is in compliance.
Independent Scientific Review
State law mandates the Plan must be reviewed by an independent team of scientists. We feel that the rapid pace of the Plan development may not allow for a comprehensive independent review. The undersigned insist that a full IMST review be conducted as required by ORS 541.914.
We are aware that the future of IMST is in question. If that is true, how is this legally-mandated review going to be completed? Should it become necessary, extending the planning process ensures time sufficient for an alternative panel of independent peer-review scientists to be assembled.
Regardless, implementation of this Plan without an independent review will violate Oregon law.
Paucity of Supporting Data
Strikingly apparent in the Plan is a dearth of data, facts and explanations to support conclusions reached.
Monitoring: No data, no problem.
For plans such as this, Oregon’s Native Fish Conservation Policy mandates annual as well as long-term reporting and monitoring. However, plain and simple, monitoring is non-existent in the Plan.
This is confirmed buried in an appendix: “…the monitoring identified in the Plan largely represents on-going work…”, and, “New monitoring will require dedicated funds to implement.”
In other words, the Plan intended to direct harvest and conservation on Oregon’s coastal rivers for decades to come includes no provision to monitor results. Nor does it provide an estimate of the funds needed to implement the Plan.
The Plan pledges ODFW to adaptive management. This is simply not possible without data accumulated from an ongoing fully-funded, comprehensive monitoring plan, particularly for a proposal which admittedly increases risk for wild winter steelhead.
This is wrong. It’s bad policy. It’s bad science. If this Plan is to be legitimate, one that assures taxpayer dollars are not to be wasted, it obliges a comprehensive and science-based program of monitoring.
For without monitoring and ongoing data collection, ODFW can neither confirm the successes nor refute the failures of the Plan. Likewise, neither can the public refute the Plan’s successes nor confirm its failures.
The citizens of Oregon have a right to know if their tax dollars are effectively and efficiently spent. Without data the public has no way to assess this.
We feel no ODFW project should be approved that does not have a monitoring component integral to it.
ODFW says habitat is not their responsibility and, so, gives only cursory reference of it. We accept that this does not fall under the agency’s purview. However, science indicates that good quality and high functioning habitat is essential to salmon and steelhead production capacity.
What we cannot accept is a Plan lacking an attendant and committed effort to restore habitat. State and federal land and water management agencies must be an integral part of the Plan and elaborate what they will contribute to make it a success.
Although the undersigned may disagree with individual components of the Plan, we are in steadfast unison on the above. The collective concern we wish to convey to you, Governor Kitzhaber, is the imprudent swiftness with which the Plan is being pushed forward by ODFW. Public input so far has been limited to peripheral issues. It is needlessly moving too quickly to allow the public adequate time to address issues of vital concern.
We respectfully encourage you to slow the development of this Plan and require that it be prudent, legal and science-based. At minimum, we request that the above issues be given more comprehensive and transparent analysis.
In advance, thank you for your consideration.
Native Fish Society
Board of Directors