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Washington Trout Submits Comments on New Puget Sound Salmon-Harvest Plan
The public comment period ended on May 17, 2004 for the Proposed Evaluation and Pending Determination on a Resource Management Plan (RMP), Pursuant to the Salmon and Steelhead 4(d) Rule (PEPD) prepared by NOAA Fisheries. The PEPD analyses the Puget Sound Comprehensive Chinook Management Plan: Harvest Management Component (RMP), submitted to NOAA by the Puget Sound Treaty Tribes and Washington Department of Fish and Wildlife. If approved, the RMP would govern all fishing in Puget Sound until 2010, in order to protect Puget Sound chinook, listed as Threatened under the Endangered Species Act since 1999. Fishing carried out under the terms of the RMP would be exempt from ESA enforcement. Washington Trout reviewed the PEPD, the RMP, and relevant fisheries-management records and scientific literature and submitted our review to NOAA Fisheries.
Washington Trout did not concur with NOAA’s Recommended Determination to grant take authorization to fisheries implemented in accordance with the RMP. The PEPD fails to make a compelling case for accepting the levels of risk and uncertainty associated with the RMP. It uncritically and in many cases inappropriately accepts and endorses several controversial assertions by the co-managers, without any documented support and in many cases without any discussion whatsoever. Most notably, the PEPD explicitly sanctions a “minimum fisheries regime,” a “base level” that fisheries will not drop below, even under conditions when the co-managers expect these populations to be at critically low levels of abundance.
Washington Trout respectfully recommended that NOAA Fisheries substantively revise the PEPD and request additional information and appropriate changes in the RMP from the co-managers before a final determination on take authorization is developed.