NFS Comments on Klamath Spring Chinook Listing Petition

In response to a petition for listing submitted by the Karuk Tribe and Salmon River Restoration Council, the National Marine Fisheries Service initiated a process to solicit comments and review whether to list as threatened or endangered the Upper Klamath and Trinity River Chinook Salmon Evolutionary Significant Unit (ESU), or alternatively to create and list a new ESU to describe Klamath Spring Chinook Salmon.

Below are our comments into National Marine Fisheries Service requesting a new ESU to describe Klamath Spring Chinook Salmon.

“Endangered and Threatened Wildlife; 90-Day Finding on a Petition to List Chinook Salmon in the Upper Klamath-Trinity Rivers Basin as Threatened or Endangered Under the Endangered Species Act”

Re: Docket No: 171128999-8169-01 – ID: NOAA-NMFS-2018-0001

Mr. Rule,

Native Fish Society is a grassroots, regional non-profit organization that utilizes the best available science to advocate for the protection and recovery of wild, native fish and promote stewardship over the habitats that sustain them. We have 3,500 members and supporters across the Northwest, and 90 place-based River Stewards who safeguard their homewaters in Oregon, California, Washington, and Idaho. Through our cornerstone River Steward Program, we support local advocates who safeguard the Klamath, Lost, Sprague, Sycan, Williamson, and Wood Rivers and 7 Mile Creek in the Klamath basin, and they have personal, business, and cultural identities tied to the health of the watershed and it’s wild, native fish. Similarly, our membership derives personal, commercial, and spiritual value from the wild, native fish present in the Klamath watershed, and they support our efforts to prevent the serious depletion of wild spring Chinook and ensure that they remain viable for current and future generations.

We respectfully request that you create a new ESU to describe Klamath Spring Chinook salmon and list the new ESU as threatened or endangered under the Endangered Species Act.

Spring Chinook salmon are an important link in the life history diversity and resiliency of Pacific salmon. In the Klamath Basin, historical records indicate that spring Chinook salmon dominated the river and traveled all throughout the watershed, from the mouth in northern California to the headwaters in Oregon where they spawned in major tributaries of Klamath Lake including the Sprague, Williamson, and Wood Rivers. For tribal communities, spring Chinook were an important spiritual and cultural resource by initiating the salmon ceremonies for the year and sustaining their food stocks through the summer. They are a prized food commodity because of their high fat content, and are an important commercial and recreational fish.

• See Hamilton et al., 2016, "The Persistence and Characteristics of Chinook Salmon Migrations to the Upper Klamath River Prior to Exclusion by Dams."
• See more discussion in Salmon River Restoration Council Fisheries Report on Spring Chinook, 2015.

However, for all they bring to these communities, the Klamath Basin’s spring Chinook have experienced serious and continued decline, and human-caused stressors jeopardize their long-term survival that make them in danger of extinction. These anthropogenic issues include a century of dams that block access to historic habitat, the persistence of low, warm flows that exacerbate the outbreak of parasite C. Shasta, and the lack of a management framework for protecting this unique life history diversity in Klamath Chinook salmon.

Klamath Spring Chinook Lack an Adequate Management Plan

The different life history requirements for spring Chinook and fall Chinook require discrete management frameworks. Despite the decades of downward trajectory in abundance for wild spring Chinook, there is no management or harvest plan that meets the specific spring Chinook life history requirements and manages them separately from fall Chinook.In particular, the state and federal fish agencies have recognized the deleterious condition of wild spring Chinook, but the Pacific Fisheries Management Council has failed to implement the intended management recommendations identified in 2003 aimed as conserving the life history of spring Chinook in the Klamath River. Similarly, there have been no harvest management or conservation objectives developed to date.

• See "Klamath Fishery Management Council Report and Recommendations to the Pacific Fishery Management Council." (2003)

Comparatively, the Rogue River in southern Oregon has experienced similar major declines in wild spring Chinook abundance due to human caused stressors, from an average of 28,000 wild spring Chinook in the 1970s to just 7,600 wild spring Chinook 20 years after the construction of William Jess Dam/Lost Creek Lake eliminated a significant amount of historical spawning and rearing habitat for spring Chinook. In response, the Oregon Department of Fish and Wildlife (ODFW) convened a public advisory committee to create a conservation plan in 2004, which was adopted by the Oregon Fish and Wildlife Commission in 2007.

Similar to the Klamath River, the Rogue River is home to both spring and fall Chinook. However, in the Rogue watershed, ODFW’s foremost management priority is to protect and enhance wild spring Chinook populations. After the advisory committee helped the state agency develop a Conservation and Management Plan, the commission made a series of modifications to sport fishing regulations and dam operations to give preferential treatment of early-run spring Chinook.In spite of drought, El Nino, and three of the hottest years on record, wild spring Chinook abundance in the Rogue River continues to trend upwards, and reached an 10 year average in 2016 of 9,573 spawners.

• See ODFW’s “Rogue Spring Chinook SMU Conservation Plan” and corresponding Annual Progress Reports (2007 – 2016) available on the ODFW Rogue Spring Chinook Webpage.

Advances in animal genetics suggest further protections are warranted for spring Chinook

Recent advances in animal genetic technology have also identified that the spring-run Chinook and their fall-run counterparts likely diverged from a single evolutionary event, raising serious conservation concerns that if the spring-run gene is lost -- it is unlikely to re-evolve on a human timeframe relevant for conservation. More recent analysis of the Klamath spring Chinook changes suggest the consequences of losing these important genetic heritages will be deleterious without immediate actions to conserve the species.

• See Prince et al., 2017, "The evolutionary basis of premature migration in Pacific salmon highlights the utility of genomics for informing conservation."
• See more in Thompson et al., “Anthropogenic habitat alteration leads to rapid loss of adaptive variation and restoration potential in wild salmon populations.” (Pre-print).

Finally, while it is important to celebrate the glimmer of hope with an increased PFMC forecast as a positive sign for Chinook in the Klamath Basin, the long-term trajectory and deleterious condition demonstrate wild spring Chinook are closer towards extirpation. Immediate action is warranted, and managing the spring-run life history as a separate ESU from fall Chinook will provide fisheries managers with the tools necessary to respond to their unique life needs and protect this important cultural and economic resource.

Thank you for the opportunity to comment in support of creating a new ESU to describe Klamath Spring Chinook salmon and list the new ESU as threatened or endangered under the Endangered Species Act.

Respectfully,

Jake Crawford, River Steward Program Director

Mark Sherwood, Executive Director