Secretary of Commerce
Secretary Carlos M. Gutierrez

Office of the Secretary Room 5516
U.S. Department of Commerce
14th & Constitution Ave. NW
Washington, DC 20230
Phone: 202-482-2000
Fax: 202-482-2741
Email: CGutierrez@doc.gov

 

          This letter is in reference to Season Options for the Sport Salmon fishery of the pacific coast. I along with millions of fishermen and thousands of business’s want to voice our concern at what NOAA is proposing for the 2006 Salmon season. There is also great concern about the proposals to close down Salmon and other hatchery programs.
         

In 2002 there was a massive fish kill that resulted in the loss of between 60-70 thousand adult fall-run Chinook (King Salmon). These fish did not get the opportunity to spawn. The fish kill was a result of a decision by the administration to drastically reduce river flows in order to give the farmers that use Klamath water more irrigation. The low water not only killed the run of fish before they spawned, but a parasite bloom occurred due to the continued low water flow.

 

The salmon population in this river has been affected by this tragedy; however, the King Salmon population in total for the Pacific coast is not. The reason for the Klamath stock being low is not because of over fishing, but because of poor water management. Moreover, 2006 shows good potential for the river, as there are high flows and a good snow-pack. Therefore continuing the normal salmon season should not adversely affect the number of salmon or affect the population negatively.

 

 We need to keep our hatcheries open to manage this shift in fish stock. I know the reasons for closing the hatcheries being proposed are due to a worry that fish raised in captivity do not have to survive the perils of nature and this will cause a shift in stock and create an artificial natural selection, which might weaken the fish line over time. This problem is addressed below. There is also the consideration that this idea with the modern hatcheries programs is no longer true. In the 70’s hatcheries fish did tend to be smaller and weaker than wild fish. Now with modern hatchery programs, in the last few years the largest Salmon caught have been hatcheries fish.

                  
As you know there already are 3 plans on the table for the 2006 season. There are threats of a lawsuit from the environmental groups regarding the ESA. Please be advised that closing of our salmon season will cause huge losses for all the business in our state and country. There has been talk of a class action lawsuit among business and boat owners as well. I think we all will be better off without a big court battle.

The simple answer is to manage the Klamath salmon eggs in hatcheries than release the fry back in the Klamath near where the wild parents were captured. Releasing the fry at 2 inches long is best. This will eliminate the high water washout of eggs and the low water kill of eggs as well. If we do this right it will also allow for the natural selection process.
Explained: 

Natural selection of wild Salmon is done by the fish having to swim both up stream and down stream along with finding their own food and avoiding predators.

Chance selection is when the river conditions are right for the eggs to hatch.  Chance salmon kills are when the river is to low or to high.

Since 90% of the eggs die in the riverbed, raising the eggs in a controlled environment will result in 90 times more fry surviving. The need for the high floor of spawning Salmon will no longer be required. We will achieve a much higher amount of return salmon in a few short years without closing the ocean fishing season.

Since only the wild fish that make it up the river will be used for stock, only the strong wild strain will be used. Since the fry will be released in hundreds of spots along the river, they will have to fight the elements just like the wild fish and will return as a strong wild strain to natural spawning in the area where released.

Looking at the Santa Cruz harbor project can prove return of the Salmon to where they grew up. These Salmon are raised in a netted area in the harbor and return to the harbor to spawn but cannot so they die there. Worse yet, it is against the law to fish for Salmon in the harbor when they return to die without spawning. Because the environmental groups have banned the local hatcheries and forced this program to the harbor, this is a good example of poor management to keep the environmental groups happy.

The practice of closing the hatcheries on the San Lorenzo River has not helped the wild Salmon at all. The wild Salmon must swim through a battery of Sea Lions in the river mouth. Since there are no hatchery fish to distract and feed the Sea Lions, instead they now wipe out the wild Salmon before the Salmon make it to the spawning areas. This has resulted in less not more wild Salmon

With the Salmon issue resolved with proper hatchery management, the farmers, environmental groups, private business, Boat manufactures and state and federal tax bases will all be allowed to continue operating without the impending disaster that closing of the Salmon season will create. Besides the reason we pay such high fishing license fees was originally intended to support these hatchery programs.

 

There is no reason to destroy our rich tradition of salmon fishing and cause a cascading economic catastrophe in light of the data available. What we are talking about is shutting down an entire industry - both sport and commercial.

Closing Salmon will affect both our state and federal economy greatly. The losses won’t be limited to just fishing. This will cause thousands of small business to go bankrupt. Since California supports 20% of boat sales nationwide, this could result in the loss of 50,000 jobs nation wide. The tax revenue loss for the state of California alone has been calculated to be somewhere in excess of 100 million dollars.

 

Sincerely,

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