Options for Responding to the two NOAA-National Marine Fisheries Service Announcements with Comments Due Jan. 28th, 2011

  • Evaluation and Pending Determination on the Proposed Puget Sound Resource Management Plan (RMP) - also known as the Puget Sound Chinook Harvest Management Plan
  • Draft Technical Framework for Ranking the Relative Recovery Potential of Populations of Puget Sound Chinook Salmon and the Watersheds Supporting Them –also called the Puget Sound Chinook Salmon Population Recovery Approach (PRA)

Steps Already Taken: WRIA 8 already wrote a letter requesting a 60-day comment extension. The WRIA 8 Technical Committee and King County technical staff will attend a briefing with Matt Longenbaugh from NOAA on the PRA on Jan. 26th at 2:30PM at King Street Center. WRIA 8 staff is sharing information and analysis with staff from other watersheds and jurisdictions regarding the PRA.

Potential Comments Regarding NOAA’s Pending Determination on the RMP:

  • Reference WRIA 8’s previous letter regarding the RMP
  • Acknowledge the improvements in the RMP from the draft WRIA 8 reviewed previously
  • State that we are still concerned that the RMP as written will not provide adequate harvest protection for WRIA 8’s naturally spawning Chinook
  • State that we are concerned that the PRA was used by NOAA in reviewing the RMP when it has not yet been publically or peer reviewed
  • State that we are concerned that Cedar River Chinook are one of the individual populations being put at risk by NOAA’s proposed finding: “Though NOAA Fisheries concludes implementation of the resource plan will result in a range of risks to individual populations, it determines that range to be consistent with survival and recovery objectives for the broader Puget Sound Chinook species.”

Potential Comment Regarding the Framework for Ranking Populations of Puget Sound Chinook Populations:

  • Express concern about the poor process used in making this announcement
  • contrary to the collaborative, bottoms-up approach used in developing and implementing the Puget Sound Chinook Conservation Plan
  • did not go through Recovery Implementation Technical Team or Puget Sound Salmon Recovery Council who oversee implementation of the PS Chinook Plan
  • short time line for commenting on very technical material issued over holiday period with background information missing
  • Express concern that this is poor policy and sends the wrong message to the public and watersheds working to implement Chinook Recovery Plans
  • Refer to previous decision against this “triage” approach to salmon recovery by the Puget Sound Salmon Recovery Council
  • Mixed messages in document about implications: states that it is just for ESA permit decisions, but implies could be used for funding allocations and harvest
  • Highlight the many technical weaknesses with the PRA’s Framework and data
  • VSPpopulation attributes are used inappropriately in this assessment. The variable number of criteria under each of the four VSP attributes means that some attributes are weighted disproportionately, but NMFS does not explain the reasoning for this determination nor how it is consistent with recovery under the VSP paradigm
  • VSP data are outdated (2006 and earlier)
  • Hatchery-dependent populations receive higher scores in some criteria than hatchery-free natural populations (such as the Cedar); hatchery-free populations then lose points for the effects of strays from hatchery systems
  • Habitat information is based on grossly outdated (pre-1999) data from an inappropriate source, in which coarse-scale, WRIA-wide assessments are used even if a WRIA includes more than one spatially distinct population (such as the Sammamish and Cedar)
  • The rating scheme for assessing habitat condition is convoluted and flawed
  • Assessment of juvenile Chinook use of nearshore areas relies on outdated data and assumptions that more recent research has shown to be flawed

Options:

1) Do not comment at this time, with the expectation that the request for an extension of the comment period will be granted; continue to evaluate the documents, but do not rush to submit comments.

2) Write separate letters regarding the RMP and the PRA

3) Write one letter regarding both the RMP and the PRA