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April 25, 2012

Mr. Dan Castleberry

Assistant Regional Manager - Fisheries

U.S Fish and Wildlife Service

2800 Cottage Way W2606

Sacramento, CA 95825

Mr. Don Glaser

Regional Director

Mid Pacific Region

U.S Bureau of Reclamation

2800 Cottage Way

Sacramento, CA 95825-1898

Rodney McInnis

Regional Administrator

National Marine Fisheries Service

Southwest Regional Office

501 West Ocean Boulevard, Suite 4200

Long Beach, CA 90802-4213

Charlton H. Bonham

Director

California Department of Fish and Game

1416 Ninth Street

Sacramento, CA 95814

Re: CVPIA Workplan 2012

Gentlemen:

The undersigned entities have concerns with the Central Valley Improvement Act

(CVPIA) work plan for 2012 with respect to efforts to improve salmon abundance in

the Central Valley. We assert the federal and state fishery agencies programs to

improve the abundance of salmon in the Central Valley need to be reevaluated and

radically revised.

San Joaquin

Tributary Association

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We have read with interest the March 22 letter from the Golden Gate Salmon

Association (GGSA) on the CVPIA workplan and we generally agree with its

criticisms. Specifically, we support the conclusions in the first full paragraph on

page 2 of the GGSA letter that states in partthe 2012 (CVPIA) Restoration work

plans that have been prepared by USFWS and USBR are not really plans. They aresimply a collection of hundreds of projects that have been proposed by field offices

of the two agencies. Many of these projects are well conceived by capable and

dedicated staffs and will provide some benefits to salmon at some point. What is

missing is management oversight to see that the plans that are proposed and

accepted are focused on the reasons the salmon runs have declined and are focused

on the best investments to begin the early rebuilding process. They go on to state:

Many of the projects take place in the tributaries but there is no analysis made of

whether or not additional enhancements in a tributary will in fact produce

additional smolts to the ocean at an early date and adults to return three years later.

On the San Joaquin side, smolt losses in the South Delta are near 100%. Hundreds of

thousands of additional smolts would have to be produced in the tributaries to have

any true net impact on an increase in San Joaquin populations. The plan ignores this

kind of analysis in its San Joaquin expenditures. The same kinds of problems exist

on the Sacramento side. In some instances, up to 90% of the smolts perish on their

way down the river.

How can the CVPIA or the aggressive San Joaquin River Restoration Program

possibly improve salmon abundance and thus succeed if survival in the lower San

Joaquin River and in the South Delta is nearly zero? As summarized by the SWRCB

in their March 2012 science review of the San Joaquin River (see page 3- 39) this

drop in survival is a recent event. They noted that Independent Science Review of

the Vernalis Adaptive Management Program (VAMP) data found thatsurvival

estimates from Mossdale or Dos Reis to Jersey Point were just greater than 1% in

2003 and 2004 and the estimate was only about 12% in the very high flow year of

2006. This compares to survival estimates that ranged between about 30% and

80% in the years 1995 and 1997 to 2000. The likely cause for this decrease in

survival is the marked increase in aquatic weeds that provide better habitat for

invasive predatory fish like largemouth bass and black bass. These predatory fish

feed on young salmon and they are now so numerous that catch and release

tournaments are held regularly. The recent study entitled Individual-level and

Population-level Historical Prey on Demand of San Francisco Estuary Striped Bass

Using a Bioenergetics Model seems to support the notion that some of the non-native predators are an extensive source of mortality and yet, the fish agencies are

not taking any action to rectify this problem.

A much more holistic approach to salmon protection, which includes all life stages

and includes ocean conditions and harvest, is needed than that currently provided

by the state and federal fishery agencies. Considerable work has been conducted in

upstream areas to enhance fish passage, including the construction of state of the art

fish screens. Without a holistic approach, these efforts could be squandered by

predation in the Bay-Delta or other stressors that adversely affect fish during their

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various life-cycles. We have independently reviewed the salmon programs of each of

the three fishery agencies and have come to the same conclusions of the GGSA. In

addition to no single comprehensive strategic approach to salmon restoration, there

are no integrated performance measures to gauge success or failure of actions. A

comprehensive overhaul of these programs is needed.

Of the three plans we reviewed, the NMFS plan is the most thoughtful from a science

perspective. The NMFS plan attempts to lay out processes to recover listed

anadromous salmonids by following a science-based approach that examines the

reasons behind current problems limiting recovery, then proposing actions to

address those problems. The lack of sufficient coordination among the three

resource agencies is a key factor that is visibly apparent when examining all the

inconsistencies among plans, including the general lack of agreement among

agencies as to what actions should be implemented and by whom.

NMFS, under advisement of the Pacific Fishery Management Council (PFMC),

currently regulates ocean fishing of Central Valley fall-run Chinook (CVF) based

solely on the Sacramento River population. The existing conservation objective for

CVF was developed before the CVPIA. Unfortunately, the conservation objective has

not been revisited since passage of the CVPIA and, as a result, was not developed

with consideration of the doubling goal. Ocean harvest regulations developed since

the passage of the CVPIA have similarly failed to incorporate the doubling goal. As a

result, NMFS has not evaluated whether current fishery management practices

impede doubling natural production. Current rates of ocean harvest are

unsustainable without hatchery augmentation and modernization of hatchery

practices, yet neither NMFS nor the PFMC distinguish between hatchery and natural

CVF.

We support the GGSAs call for a review and overhaul of the CVPIA salmon program

but believe it needs to go beyond CVPIA and integrate with all the activities of the

state and federal fishery agencies related to salmon. While many of these programs

focus on natural production, specific actions are needed to make the salmonid

hatchery programs more efficient in producing fish for harvest in the ocean while

minimizing impacts to natural populations, to reduce straying, and to minimize

harvest take of listed species. Hatchery production is over half of the ocean catch off

Californias coast. Also, hatchery produced fish on average make up over half the

natural area escapement in the Central Valley and ranges from 22% to 96% of thetotal number of salmon returning to spawn (as documented in the March 2012

report on results from the constant fractional marking program by the Department

of Fish and Game). It is time to define the role of hatcheries in overall salmon

management and implement programs to enhance natural production while

retaining the benefits of improved ocean abundance provided by hatcheries.

A new restoration strategy should be science-based, pragmatic, and candid about

realistic goals and the opportunities for anadromous salmonid restoration in

recognition of the importance of salmon hatcheries. The plan should be routinely

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revised to reflect new information, accomplishments, and failures. If the

recommended approach is not taken, it would appear that the resource agencies will

continue to repeat the same debates into the future leaving the anadromous

salmonid resource at risk.

We intend these comments to be constructive and are truly committed to help make

these programs more effective in the future. We look forward to working with you,

the GGSA, and others in your ongoing efforts to improve the abundance of salmon in

the Central Valley.

Sincerely yours,

David Guy

Northern California Water Association

Allen Short

San Joaquin Tributary Association

Terry Erlewine

State Water Contractors

Dan Nelson

San Luis Delta Water Authority

cc: Mike Conner, Commissioner

John Laird, Secretary

Jerry Meral, Assistant Secretary

Golden Gate Salmon Association