Re: Coastal Multi-Species Conservation and Management Plan
Governor John Kitzhaber
900 Court St. NE
Salem, OR 97301-4047
Re: Coastal Multi-Species Conservation and Management Plan Dear Governor Kitzhaber:
As you know, the Oregon Dept. of Fish & Wildlife has been working to complete its Coastal Multi-Species Conservation and Management Plan (CMP). It was developed by staff with limited public input. Stakeholder Panel meetings were held but ODFW allowed comments only on hatchery programs and harvest regulations. All ‘science’ was off the table.
The Steamboaters and the Native Fish Society felt the most credible approach to addressing the CMP was by creating an independent, objective and science-based review (enclosed) produced by a team of respected aquatic and fisheries biologists: Dr. Chris Frissell, Chuck Huntington, and Steve Cramer. They each have extensive careers addressing issues related to the conservation and management of native salmonids in Oregon.
We identified topics we wanted them to address, including the plan’s sufficiency in meeting the intent of Oregon’s Native Fish Conservation Policy. You have our assurance we in no way influenced their conclusions or outcomes. The enclosed report is an ‘arms-length’ body of work in their own words.
In summary, the independent science panel found there is little, if any, serious conservation merit to the CMP. Among their conclusions: it....
....is primarily a business-as-usual hatchery and harvest management plan. If that is ODFW’s intent, the plan should not be promoted as a fulfillment of ODFW’s commitment to produce conservation plans for wild native fish.
....lacks fundamental elements expected by scientific convention from a comprehensive conservation plan....should not be considered an adequate conservation plan for any species.
....will be difficult for ODFW to argue that the CMP proposes or incorporates management and regulatory mechanisms adequate to ensure that the requirements of the Native Fish Conservation Policy and various environmental laws are being met, including the Clean Water Act, the Coastal Zone Management Act, and the Endangered Species Act.
....appears there is at best weak alignment between proposed wild fish emphasis areas and watersheds previously recognized by ODFW and other authorities as having high habitat integrity and priority for habitat protection and restoration.
...An effective, explicit and integrated monitoring and evaluation protocol is probably the most important single product of any conservation plan, and it is entirely absent in the CMP.
On December 9th the science panel’s report was provided to Director Roy Elicker, Ed Bowles and Tom Stahl at ODFW (enclosed). And while there are conclusions and assumptions in the CMP with which the science panel respectfully disagrees, it was sent in a positive and cooperative spirit. They suggest:
ODFW’s planning exercise and the critical reviews it has solicited have revealed opportunities for the Department to make important improvements to the CMP. We strongly recommend that ODFW revise and strengthen this plan now.
We have condensed the science panel’s conclusions into a list of Key Findings, enclosed. We also produced a comparison of comments and conclusions shared by both the science panel and by the Independent Multidisciplinary Science Team (IMST), enclosed.
Governor Kitzhaber, there is nothing time-sensitive about the CMP. So, there should be no rush to produce a flawed plan that is not based upon the conservation needs of the fish in question. Shouldn’t the state take the time necessary to produce a conservation plan that actually addresses the habitat, hatchery and harvest problems facing the state as we attempt to restore coastal wild fish populations?
Specifically, we ask you to suspend further development of the plan while ODFW carefully considers the concerns and recommendations both from the IMST review and the independent science team.
In advance, thank you for your consideration. If you have questions please don’t hesitate to contact us.
Native Fish Society firstname.lastname@example.org (503) 496-0807
Leonard A. Volland
Board of Directors Steamboaters email@example.com (541) 673-2246