Dear Sirs,
These comments are in response to the proposed listing as "threatened" of 3 contiguous ESU's of Coho Salmon ranging from Oregon through .Central California.
I have prepared these comments on behalf of the Willits and Mendocino Environmental Centers, both of which are non-profit corporations dedicated to the protection of the natural environment in Mendocino County and Northern California. Each of our organizations has members who value and enjoy the existence of Coho Salmon as a fellow creature on this planet.
As noted in your Federal Register notice of July 25, 1995, the California Department of Fish and Game has concluded that Coho Salmon in California had declined 94% since 1940 with 70% of that decline since the 1960's. Other estimates put the Coho population in California at 5,000, a decline to less than 1% of its former population size. Coho Salmon populations of many streams are already extinct.
Therefore, it would not be accurate to list the Coho as "threatened." Coho are "endangered" right now, and should be given that listing. Because of its complex life history and short (3 year) life span, this remnant population could approach zero at any time.
The following watersheds still have supported Coho in recent times but all populations are "endangered" by destructive short-sighted land use practices:
1. Marin County Streams - Lagunitas Creek contains Coho but requires replenishment of gravels at the base of upstream dams to allow continued reproductive success. Salmon Creek, which drains into Bolinas Lagoon has tremendous grazing-caused degradation.
2. Russian River Streams - Willow Creek is endangered by logging, sediment, high temperatures and destruction of riparian canopy. Mayacama Creek is in trouble from agricultural diversions. Scott and Wadell Creeks have a few Coho.
3. Mendocino Coastal Streams - The Garcia has potential for recovery of its Coho population. The South Fork Garcia was severely damaged by L.P.'s poor logging.
The Navarro River is in terible shape with Coho at or virtually extinct due to logging. Flynn Creek might have some Coho, and the North Fork of Indian Creek has cold water and needs protection. The North Fork Navarro could still have Coho along with the headwaters of Rancheria Creek, though lower Rancheria and Anderson Valley Creek have lethal temperatures in the summer.
Big Salmon Creek has a remnant population. Though it has some large woody debris in the creek to help maintain the habitat, it has been degraded by logging, road problems and destruction of riparian zones. It may contain the most southern extent of the Tailed Frog.
The Noyo and the Albion have been destroyed by logging, fine sediment, loss of riparian cover, warm water and coarse bedloads.
Caspar Creek has been damaged by logging, as has the North Fork of Big River, but still contains remnant populations.
Ten Mile River may have a few Coho in the vicinity of Rainbow Creek but has been devastated by logging.
The Mattole has a struggling population which is trying to recover from past and ongoing road-and logging caused degradation. The upper Mattole and Bear Creek might still support Coho but are in trouble because of logging. Mill Creek is a good candidate to support a population of Coho.
4. The Eel River has been hammered by logging, grazing and road problems but the upper South Fork Eel, including Hollow Tree, Redwood and Elder Creeks probably has remnant Coho. The Lower South Fork including Sproul Creek has been destroyed by logging. The Lower Eel and the Van Duzen has been given the same treatment. Yaeger Creek. which contains Coho, is threatened by logging of the Headwaters Forest.
Outlet Creek on the Mainstream Eel may have lost its Coho due to flow diversions by Willits, wetlands disturbances, sediment and street runoff, poor grazing and agricultural activities and sewage dumping by Willitts. Ten Mile Creek through Laytonville might still have a few Coho.
5. Humboldt and Del Norte Streams - Mill Creek, a tributary of the Smith, is partly in state park but is damaged by logging. Prairie Creek, a tributary of Redwood Creek is in a state park but has been damaged by the 101 bypass. Little River south of Trinidad has been 80% logged in the last decade and is at risk. Elk River, Freshwater River and Salmon Creek, which empty into Humboldt Bay, are also in trouble due to logging and could be further damaged by logging in Headwaters Forest.
In the face of this accelerating process of extinction, your suggestion that "the Natural Communities Conservation Planning process envisioned by the Resources Agency is the best approach for developing and implementing a successful conservation and recovery strategy for Coho salmon in California," is irresponsible and misinformed. The Resources Agency is the agency least likely to have any impact on the ongoing extinction of Coho.
It is well known that the Forest Practices Act, administered by the Resources Agency and designed to protect fisheries, including Coho, has been routinely violated by the Resources Agency, and its Department of Forestry, over the more than two decades of that law's existence. The Board of Forestry, Water Quality Boards and the Department of Fish and
Game have resisted (in the case of the Dept. of Fish and Game, been ineffective) any changes which are needed to protect the Coho and all species of salmon from extinction in any area subjected to logging and roadbuilding.
The Wilson administration personally intervened to derail a legal effort by Mendocino County to control the present epidemic of extinction logging in that county. It is this state-sanctioned liquidation of conifers and now the hardwoods, with no real protection of fishery or wildlife habitat that is mainly to blame for the approaching extinction of Coho, with Chinook not far behind.
This unenforced regulatory - defacto voluntary - approach has already been tried with tragic results. Given the Resources Agencys' well-known hostility to any meaningful restrictions on land use activities, which are at the heart of Coho's approaching extinction, the National Marine Fishery Service cannot rely on the Resources Agency and its smoke and mirrors NCCP process.
The NMFS must design its own recovery plan based on good information, both scientific and site-specific, and in consultation with those organizations whose interests, unlike those of the Resources Agency, include actually wanting to reverse the present trend toward total extinction for Coho.
It is clear that for a credible recovery plan to succeed the State of California and local government will need to be educated and required to change existing legislation and the rules and practices of a variety of boards and regulatory agencies in ways which give priority to the needs of Coho salmon.
A bare-bones recovery plan needs to include the following elements in order to give Coho salmon a chance for survival:
1. The strategy developed by the Federal government for protection of fisheries in connection with protection of old-growth forests and the northern Spotted Owl is a good model for the NMFS to follow. Refugia reserves need to be set up which will include every stream and watershed known to contain Coho or likely to support Coho in the near future. Those watersheds need to be nanaged according to the standards and guidlines for Tier I watersheds in the President's Forest Plan. These refuges or reserves need to be storm-proofed with roads put to bed, undersized culverts removed and otherwise protected from sediment pulses which could damage spawning habitat. Roads ned to be outsloped and scrupulously maintained to minimize impact of sediment to streams. Logging should not occur in reserves.
2. Riparian zones need to be restored in the reserves as well as in any stream thought to have contained Coho at some time in the past. These Riparian Reserves, which are in addition to the Refugia or total watershed reserves, should extend two site potential tree heights (maybe more depending on the stream) on each side of the stream. This would amount to 600 feet on each side in the Redwood biome and 400-500 in areas with mixed conifers and hardwoods. Logging should not be allowed in these riparian reserves. Restoration of hardwoods, conifers and other plants in these riparian reserves is critical to ensuring viable stream temperatures.
3. Large woody debris needs to be placed back in streams as well as recruited from the riparian reserves. Large wood chunks are needed to provide fish habitat, to sort and trap gravel and to create scour pools.
However, watershed stability needs to be addressed via logging regulations so that efforts to restore large woody debris are not cancelled by erosion and unnatural flows which blow logs in creeks out of the system.
4. End new water diversions from streams known to be used by Coho or Chinook salmon until Coho poulations begin to recover. Establish mandated instream flows in these streams which are needed to benefit fish and then divide any excess among the existing diverters of water.
The efficiency in the use of diverted water needs to b e improved with the use of drip irrigation and the replacement of ditches with pipes. Groundwater extraction can impact stream flows and needs to be equitably controlled.
5. The EPA should re-assign responsibility for enforcing the non-point source statutes of the Clean Water Act from the Dept. of Forestry and the Water Resources Control Board to the Dept. of Fish and Game. EPA needs to insist that functional best management practices be certified and periodically updated so as to provide stream conditions which are healthy for fish.
6. There must be a tangible mechanism for accountability so that recovery or continued habitat loss can be detected and dealt with accordingly.
There needs to be a system of broad-based groups set up including government and local community groups who will work together to ensure compliance with the recovery plan. All information needs to be available so that the public can monitor progress toward recovery; This should include on both public and private land.
7. There needs to be a mechanism set up to monitor the factors known to be limiting for Coho salmon survival. These factors will include but not be limited to sediment, temperature, bed composition, dissolved oxygen and fish surveys including downstream migrant trapping, adult counts and carcass counts. The monitoring can be accomplished by well-trained volunteers in cooperation with agency biologists. Longitudinal and cross-sectional profiles of streams also need to be tracked for evidence of recovery or further degradation.
Water temperature needs to be monitored using Hobo temp-type monitors. Riparian canopies need to be measured and progress needs to be made toward returning riparian zones to conditions that can be identified from historical records made prior to disturbances due to logging, grazing and roadbuilding.
There needs to be a complete road inventory including the condition and potential for failures of each road segment. Funding to repair such problems would be based on a priority rating based on such an inventory. Problems on private lands will be funded by the landowner.
Diversions and flows need to be monitored since flows relate to temperature - i.e., less flow = higher temperature = equals dead fish. Ground water needs to be measured to prevent ground water extractions from damaging instream flows.
8. Require counties to pass road and homesite grading ordinances to protect habitat for salmon. Encourage, via a sediment tax - the repair of erosion-causing roads and driveways.
9. End commercial gravel extraction from streams known to have been used by Coho, Chinook or Steelhead.
10. Organize workshops for landowners to promote and demonstrate grazing, logging and development practices that avoid impacts on fish and wildlife.
11. Initiate legislation to set aside funds for use by Caltrans and counties to correct fish passage problems created by state and county roads.
12. Develop a flow recommendation for the Potter Valley Diversion that optimizes conditions for salmon and steelhead in the Eel River.
13, Initiate legislation that grants tax or other incentives for private landowners interested in improving habitat for Coho and other native fish species.
14. The ocean fishery and the stream fishery should be closed to taking any wild fish until the recovery of the wild population is well under way.
15. Hatcheries have the potential to create more problems than they solve. By collecting a selected number of fish for propagation, you can cause inbreeding leading to an increased incidence of diseases, low fertility and fecundity.
If captive breeding to protect gene resources seems absolutely necessary, the program must have adequate funds to achieve complete control over brood stock management to prevent inbreeding and to ensure the strictest possible hygiene in the facility to make sure the fish are healthy when they are released.
When considering transplanting fish into watersheds where Coho are now thought to be extinct, care needs to be taken that small remnant populations are not still persisting. Detailed and complete surveys need to be completed before undertaking such transplantation.
Finally, the bulk of the recovery plan must concentrate on allowing recovery of the ocean and instream habitat. Dumping hatchery fish in the streams does not equal recovery, but could speed up extinction.
Copyright Mendocino Environmental Center 2004
Permission granted to excerpt or use this article if source is cited