[Fishlink] ~~>FISHLINK SUBLEGALS 11/30/02<~~

[bit-bucket@straylight.primelogic.com]

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                    ~~>FISHLINK SUBLEGALS 11/30/02<~~
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       A WEEKLY QUOTA OF FISHERY SHORTS CAUGHT AND
     LANDED BY THE INSTITUTE FOR FISHERIES RESOURCES 
     AND THE PACIFIC COAST FEDERATION OF FISHERMEN'S
                                   ASSOCIATIONS

VOL. 06, NO. 22                                     30 NOVEMBER 2002
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"I think the environment should be put in the category of our national
security. Defense of our resources is just as important as defense abroad.
Otherwise what is there to defend?" ........... Robert Redford
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IN THIS ISSUE.......

U.S. Adminstration Attack On Salmon In National Forests.  6:22/01

California Names Coho Recovery Team.  6:22/04

Proposed "South Delta Improvement Plan" Threatens 
Salmon and Health of San Francisco Bay.  6:22/07

Even Westlands Land Fallowing Proposal Laden With Pork.  6:22/09

Fish & Game Commission Meeting In Monterey - Coho, 
Nearshore, Transgenics on Agenda.  6:22/11

AND MORE......
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     6:22/01. U.S. ADMINISTRATION ATTACK ON SALMON IN
NATIONAL FORESTS; PROPOSALS TO UNDERCUT
NORTHWEST FOREST PLAN AQUATIC PROTECTIONS:  In a
two-pronged assault on salmon and wildlife preservation on public
forestlands, the Administration of U.S. President George W. Bush is
proposing to: 1) significantly reduce species and habitat protection
standards in all national forests; and 2) undercut the aquatic conservation
strategy of the Northwest Forest Plan.  The standards and the strategy are
both essential to protect and restore damaged salmon runs within streams
flowing through badly over-logged federal lands throughout the western
U.S.  These changes are being made by the Administration in an effort to
turn more federal timber over to logging companies that had supported
the Bush campaign.  Under the proposals, the role of the public
(including the fishing industry) and of science in managing these
publicly owned forests would be reduced.

     The proposed changes to federal regulations implementing the
National Forest Management Act (NFMA) were announced on 27
November by the Administration. NFMA rules manage 155 national
forests and 20 national grasslands. Among the problems with the
proposed new regulations is that they would make the current federal
requirements to "provide for a diversity of plant and animal
communities..." and "provide for adequate fish and wildlife habitat to
maintain viable populations..." and most other wildlife protection (see 36
CFR 219.19; 219.26; 219.27) optional instead of mandatory.  U.S. Forest
Service (USFS) timber operations would no longer have to protect native
species or preserve aquatic habitat for species such as salmon in any of
their operations. 

     The new rules would also "streamline" the federal timber sales
program by eliminating many of the agency's current survey and
monitoring requirements, thereby reducing the role of science in
decision-making. They also limit the opportunities for public comment. 
These federal timber sales (which are essentially transfers of federally
grown trees to private logging companies - usually at a large loss to
taxpayers) can be highly destructive to salmon spawning and rearing
habitat.  

     Destruction of spawning and rearing habitat on both private and
federal lands has been a leading cause of salmon losses, with 26
salmonid stocks currently listed as either "threatened" or "endangered"
under the U.S. Endangered Species Act (ESA).  Many ESA-listed
salmon species, such as coho, depend heavily on federal forestlands for
their most important spawning and rearing habitat. Roughly one-third of
all coho habitat is on federal forestlands. The Forest Service's new
NMFA rule proposal can be found at:
www.fs.fed.us/news/2002/11/2002-11-27-Planning%20Rule.rtf.   More
information on the proposed rules can be found at:
www.fs.fed.us/emc/nfma/index3.html.

     In response to the proposal to weaken standards for the protection of
salmon and wildlife, a dozen members of Congress, including U.S.
Senators Barbara Boxer (D-CA) and Maria Cantwell (D-WA), and
Representatives Nancy Pelosi (D-CA), George Miller (D-CA), Earl
Blumenauer (D-OR) and Jay Inslee (D-WA), fired off a letter on the 27th
to USFS Chief Dale Bosworth, stating that "the Forest Service's draft
planning rule fails in five critical areas: protection of habitat for fish 
and
wildlife, monitoring, environmental analysis, public participation, and
independent scientific review."  A copy of the three-page letter is
available from Senator Boxer's office at: senator@boxer.senate.gov. 

     Two days before announcing its proposed weakening of fish and
wildlife protection in national forests, the Bush Administration, on 25
November, published notice of its intent to change some of the key
aquatic species protection provisions of the Northwest Forest Plan
(NFP). The NFP was adopted in April 1994 under the previous
administration as a way to settle the "timber wars" that had wracked the
Northwest and Northern California several years before.  A fundamental
part of that Plan was the "Aquatic Conservation Strategy (ACS)," which
was intended to help protect and restore damaged salmon habitat on
federal lands.  ESA protections for damaged salmon runs on the west
coast have come into being since the ACS was adopted, and the ACS has
now become the federal government's primary salmon restoration
strategy on federal forestlands. 

     The Northwest Forest Plan changes, although characterized by the
Administration as mere technical changes to clarify language and
"restore the original intent" of the Northwest Forest Plan, would
eliminate current requirements under the ACS to protect or prevent
damage to salmon habitat at any particular place in a watershed. By
eliminating any requirement for site-specific protections, as well as any
monitoring to ascertain cumulative effects of site specific timber
operations, there would be no way of ascertaining whether the ACS was
really working, nor of preventing further salmon habitat degradation. 
Since every watershed is made up of "particular places," eliminating
site-specific protection requirements gives a blank check for forest
managers to destroy salmon habitat piecemeal, wherever they thought it
expedient to boost timber sales.  

     The proposed changes to the ACS are specifically intended to
overturn a decision by the Ninth Circuit Court of Appeals in a case
brought by commercial fishermen and others, PCFFA, et al. v. National
Marine Fisheries Service, 265 F.3d 1028 (9th Cir. 2001). The Court of
Appeals in that case blasted the USFS and National Marine Fisheries
Service (NMFS) for systematically ignoring site-specific impacts on
salmon, and for rubber-stamping Biological Opinions (BiOps) approving
timber operations which agency biologists considered too risky for
salmon.  The case resulted in an injunction against more than 100
pending federal timber sales and invalided 24 NMFS BiOps until they
are redone properly.  The Bush Administration position now is that,
instead of following the rules and doing it right, it will simply change the
rules themselves, through these "clarifying amendments" to eliminate all
requirements for site-specific analysis of impacts. 


     The Administration's published its notice in the 25 November Federal
Register (Vol. 67, No. 227, pp. 70575-70576) requesting public
comments on its plan to prepare a Supplemental Environmental Impact
Statement (SEIS) on the new rule changes. It is available at:
http://a257.g.akamaitech.net/7/257/2422/14mar20010800/edocket.access
.gpo.gov/2002/02-29951.htm. Written comments concerning the scope
of the analysis should be received in writing by 26 December, and sent
to: Comments, SEIS for Aquatic Conservation Strategy, P.O. Box 2965,
Portland, OR 97208. Copies of the original Northwest Forest Plan
Record of Decision (ROD) and Attachment A to the ROD as referred to
in the notice are at: http://www.reo.gov/library/reports/newsandga.pdf. 
There will be no public hearings and no other opportunity for public
comment.

     For more information on the Administration's proposed forest rules,
see the 27 November Seattle Times at:
http://seattlepi.nwsource.com/local/97460_logs27.shtml.  Additional
information is in the 27 November San Francisco Chronicle on the
Administration's efforts to speed logging at:
http://www.sfgate.com/cgi-bin/article.cgi?f=/chronicle/archive/2002/11/
27/MN244302.DTL.  Also see the 27 November Environment New
Service at: http://ens-news.com/ens/nov2002/2002-11-26-10.asp.

     6:22/02. YUROKS TO HOST SALMON SUMMIT: The Yurok
Tribe is hosting a "Salmon Summit" scheduled for Saturday, 7
December, at the Tribal headquarters in Klamath, California.  The
purpose of the meeting is to review this past year's fish kill on the
Klamath River (see Sublegals  6:20/04, 6:17/06; 6:16/01; 6:15/01;
6:14/01; 6:13/01; 6:12/07; 6:02/09; 5:23/08; 5:21/03; 5:20/09; 5:18/01;
5:17/02) and "to develop strategies in an effort to protect our vital North
Coast water and fishery resources...to avoid another disaster like the one
caused by the Bureau of Reclamation's water flow reductions this past
year."  For more information, contact Cindee Carlson with the Klamath
Tribal office at: (707) 482-1350, Ext. 314.

     6:22/03. ADDITIONAL PROTECTIONS FROM PESTICIDES
SOUGHT FOR SALMON STREAMS:  On Wednesday, 27 November,
PCFFA, IFR, Washington Toxics Coalition and the Northwest Coalition
for Alternatives to Pesticides filed for an injunction, in U.S. District
Court in Seattle, to limit pesticide uses that harm salmon. This is a
request by plaintiffs in their ongoing litigation for additional interim
protections from 54 pesticides for salmon-bearing rivers and streams in
California and the Pacific Northwest.  Following up on a July 2002 court
victory, the parties are asking the court to require mandatory protective
buffer zones until the U.S. Environmental Protection Agency (EPA)
completes its court-ordered formal consultation process with the
National Marine Fisheries Service (NMFS) over the impact of these 54
pesticides on endangered and threatened salmonids (see Sublegals
6:01/05). The basis for the request is that the formal consultation process
between EPA and NMFS that the court ruled earlier is required under the
Endangered Species Act (ESA) is not expected to be completed until
sometime after December 2004.  Until that time, plaintiffs argue,
reasonable restrictions should be in place to prevent any more of these
54 highly toxic compounds from entering streams and rivers in which
federally protected salmon exist.  The consultation process may also
result in additional restrictions but on a case-by-case basis.

     Plaintiffs, represented by Earthjustice, are asking for an interim
100-yard protective stream buffer zone for aerial applications of
pesticides, and a 20-yard "no spray" stream buffer zone for ground
applications, but also asking that some of these more toxic compounds
also be banned for sale for home use except by a licensed professional
chemical applicator.  For more information and a copy of the injunction
brief, go to: www.pesticide.org/SalmonInjunctionNews.html.   Also see
the 28 November Eugene Register-Guard at:
www.registerguard.com/news/2002/11/28/1d.cr.pesticides.1128.html.
     
      6:22/04. CALIFORNIA NAMES COHO RECOVERY TEAM: The
California Department of Fish & Game (CDFG) announced 27
November the composition of its Coho Recovery Team to assist the
Department in the development of a recovery strategy for coho salmon
north of San Francisco. Coho in California are currently listed under the
federal Endangered Species Act (ESA) and have been listed since 1994
south of San Francisco under the California Endangered Species Act
(CESA).  In August of this year, as a result of a petition brought by a
coalition of conservation and fishing groups, including PCFFA, the
California Fish & Game Commission extended the CESA listing to coho
populations north of San Francisco Bay (see Sublegals 6:09/07; 6:03/11;
5:22/01; 3:14/02; 3:05/11; 2:13/11).  The Fish & Game Commission will
take up the coho issue at its 5 December meeting in Monterey (see
6:22/10 below), including consideration of emergency regulations (to
amend Section 749.1, Title 14, CCR) regarding the incidental take of
coho (Agenda Item 9).
     
     The team includes the various "stakeholders," including fishing and
conservation groups, the tribes, landowners, agencies and academia. 
Humboldt County Supervisor Jimmy Smith has been named to represent
commercial fishermen, while Tom Weseloh of California Trout will
represent recreational fishing interests, Craig Bell will represent the
Sierra Club and Larry Moss will represent the Smith River Alliance.
Tribal representatives are Dan Gale (Yurok Tribe) and George Kautsky
(Hupa Tribe).  Other representatives include Randy Poole (Sonoma
County Water Agency), Miles Croom (NMFS), Walt Duffy (USGS),
Kallie Kull (FishNet 4C) and Deborah McKee (CalTrans), along with
representatives from the Farm Bureau, timber, the State Water Resources
Control Board, California Department of Forestry & Fire Protection,
counties and CDFG staff.  For more information, call Stephanie Tom
Coupe at (916) 654-3821 or e-mail: smartara@dfg.ca.gov.

     6:22/05.  OREGON FISH & WILDLIFE COMMISSION ADOPTS
NATIVE FISH CONSERVATION POLICY:  The Oregon Fish &
Wildlife Commission, at its 8 November meeting, adopted its "Native
Fish Conservation Policy" intended to provide guidance to the
Department of Fish & Wildlife (ODFW) on the conservation role it
should play in protecting the State's native fish populations.  Crafting a
compromise between over-dependence on hatcheries as a conservation
tool while ignoring habitat, versus "wild fish only" advocates, the policy
defines "native fish" as including both naturally produced and hatchery
produced stocks. The policy, however, states a strong preference for
conserving naturally produced fish in the wild and concentrates on
addressing the primary factors which cause fish declines in the first
place, allowing hatchery supplementation to be used "responsibly" as a
conservation or reintroduction tool when appropriate.  The policy also
calls for written "conservation plans" for specific species that would be
adopted by the Commission.  Also, when faced with uncertainty the
policy requires state agencies to "err on the side of conservation."  For
information, see the Fish & Wildlife Commission's agenda, containing
links to key documents on the Native Fish Conservation Policy, at:
http://www.dfw.state.or.us/ODFWhtml/meeting_schedule/november/nov
ember8.htm.  For a copy of the new Native Fish Policy as presented to
the Commission meeting, go to:
http://www.dfw.state.or.us/ODFWhtml/meeting_schedule/november/NO
VB4.pdf.

     6:21/06. BPA SET TO CUT FUNDS FOR SALMON
RESTORATION ON THE COLUMBIA: The Bonneville Power
Administration (BPA), which provides about half of the electricity used
in the Pacific Northwest, is preparing to announce cuts of over $300
million in expenses through 2006.  In addition to this amount, $150 -
$200 million will be cut from salmon restoration programs, according to
Save Our Wild Salmon. This decision has been made despite BPA's own
analyses which projects that spending for salmon restoration and other
fish and wildlife projects will be around $20 million under-budget over
the next four years.  On the other end of the accounting spreadsheet are
general power business operations with an expected $150 million in
over-budget expenses.  However, rather than trim the programs that are
forecasted to go over-budget or look to power users for compensation,
BPA has decided to glean some funds by reneging on its obligations to
mitigate the damage done by its Columbia River hydropower dam
operations to salmon populations.   BPA sources have said that the
coming cuts will reduce the agency's funding of the federal Salmon
Recovery Plan by 20-25 percent.  "BPA and the federal government are
committed to restoration - by law and by moral contract - for lower-river
and coastal communities," said PCFFA Northwest Regional Director
Glen Spain.  "BPA backing away from those obligations will solve no
problems in the Columbia River basin, but will make every problem
worse."  For more information, go to:
http://www.wildsalmon.org/info/searchdetail.cfm?docID=233

     6:21/07. PROPOSED "SOUTH DELTA IMPROVEMENT PLAN"
WOULD INCREASE DIVERSIONS THREATENING SALMON AND
HEALTH OF SAN FRANCISCO BAY:  A proposal by the U.S. Bureau
of Reclamation (BOR) and the California Department of Water
Resources (CDWR) to increase the capacity of pumps to export water
from the Sacramento-San Joaquin Delta seriously threatens migrating
salmon populations, including the Endangered Species Act (ESA) listed
winter-run chinook, as well as the health of the San Francisco Bay by
further reducing freshwater inflows critical to estuarine health. The
"South Delta Improvement Program" (SDIP), the term the agencies
euphemistically call the increased diversion, would, as originally
outlined by the CALFED Record of Decision (ROD), include increasing
State Water Project (SWP) export capability to 10,300
cubic-feet-per-second (cfs), installation of new fish screens and dredging
of diversion canals.  

     So far the agencies involved have offered three possible alternatives,
all of which focus on the Clifton Court Forebay near the town of Tracy. 
By increasing the diversion potential at this location the agencies say
they will be able to offset diversion demands from other locations.  The
problem is that the SDIP is likely to cause a higher kill of endangered
fish than occurred historically. This could also increase the take of
Sacramento fall-run chinook, the mainstay of the ocean commercial and
sport salmon fisheries offshore California, Oregon and Washington.
CALFED's own studies show that increasing exports even to 8,500 cfs
would dramatically increase take, especially in wetter years. Going to the
full 10,300 capacity without further increasing take would also require
that more efficient screening approaches be fully tested, adopted and
funded.   More data is needed on the probable redirected impacts of
increased pumping on the estuary and fishery resources.                       
     

     Comments on the proposed South Delta Improvement Plan (SDIP)
Environmental Impact Statement/ Environmental Impact Report
(EIS/EIR) scoping period closed 31 October and a draft document is
expected in the spring of 2003. PCFFA along with recreational fishing
and conservation groups belonging to the Environmental Water Caucus
commented formally on the plan by pointing out that CALFED has, to
date, failed to provide many of the basic water allocations for fish and
wildlife.  These include the flows associated with the Environmental
Water Account, the Central Valley Project Improvement Act (CVPIA)
Sec. (b)(2) flows and the Ecosystem Restoration Program.  Without the
flows guaranteed under those plans, "state-of-the-art fish screens are
merely band-aids on the broken leg of the Bay-Delta ecosystem." 
PCFFA contends that any program authorized under CALFED to reduce
conflicts among beneficial users should be developed in light of the
current programmatic failures.    For more information about the SDIP
go to DCWR's SDIP homepage at: http://sdelta.water.ca.gov.  For more
information regarding the concerns raised by the Environmental Water
Caucus, contact David Nesmith at: c@davidnesmith.com. 

     6:22/08.  ANOTHER SALMON DELISTING CASE ARGUED,
THIS TIME IN DC FEDERAL COURT: On 25 November, arguments
were heard in U.S. District Court for the District of Columbia in a case
brought by a coalition of industry and agribusiness organizations arguing
that Pacific salmon should never have been protected under the
Endangered Species Act (ESA) at all. The plaintiffs, euphemistically
calling themselves "Common Sense Salmon Recovery," are seeking to
reverse the ESA listings of Puget Sound, Columbia River and
Willamette River chinook salmon, all now classified as "threatened with
extinction" under the ESA because of factors including dewatering of
rivers by agriculture, water pollution by industry, and excessive
sediments in salmon-bearing streams caused by excessive logging. 
PCFFA and IFR both intervened in that case in favor of maintaining
ESA protections, and supporting the National Marine Fisheries Service
(NMFS) decision to list. The case, Common Sense Salmon Solutions v.
Evans (Dist. of DC, Case No. 1:99CV01093), is yet another try to
expand the ruling of the earlier Alsea Valley Alliance case from
September 2001, where an Oregon federal judge invalidated the ESA
listing of coho salmon along the Oregon coast.  That ruling was
subsequently suspended by the U.S. Ninth Circuit Court on appeal, and
appeal is still pending (see Sublegals 6:04/08; 4:24/19; 4:20/08; 4:18/02;
4:11/02).  

     The basis of the plaintiffs' claim is that "hatchery fish and wild fish
are identical," and since there are so many hatchery fish (and more could
be produced at will) the populations of salmon as a whole are so large
that they are "nowhere near ESA listing thresholds."  Their argument is a
ruse to eliminate any obligations to protect salmon habitat, requirements
that may force them to modify salmon-destructive but highly profitable
industrial practices.  For more, see the case summary by Larry Swisher
in the Eugene Register-Guard at:
http://www.registerguard.com/news/2002/12/03/9a.ed.col.swisher.1203.
html. "Common Sense Salmon Recovery (CSSR)" includes
organizations such as the Building Industry Associations of Washington,
the Washington Associations of Realtors, Washington State Farm
Bureau, Washington Cattlemen's Association, American Land Rights
Association, League of Private Property Voters, Citizens for a Sound
Economy, American Farm Bureau Federation, California Farm Bureau,
the Washington Construction Industry Council, and former Washington
Senator Slade Gorton. A full CSSR membership list is at:
www.salmonjustice.com/CSSR/membership.htm.  A copy of their
original complaint is at:
http://www.salmonjustice.com/CSSR/NMFSLawsuit.htm.  Among other
relief asked for, CSSR also has asked for a complete closure of all west
coast commercial salmon fisheries, claiming that fishery closures, and
not ESA remedies, are the sole salmon conservation measures that
NMFS can legally take.  A decision on the case is due in January 2003.

     6:22/09. EVEN WESTLANDS LAND FALLOWING PROPOSAL
LADEN WITH PORK:  There may be no hog farms within the
Westlands Water District, located on the west side of California's San
Joaquin Valley, but that has never stopped this junior water district's
swine from living high on federal pork.  Stymied by the cost of a drain to
take away selenium and pesticide-laden waste water from the District,
the U.S. Department of Interior is proposing to spend $100 million to
fallow 33,000 acres of irrigated lands. The deal eventually could lay
fallow as much as a third of the nation's largest irrigation district,
according to a 16 November Associated Press report.
                         
     Under Interior's plan, the U.S. Government would eventually buy as
many as 200,000 acres of the Westlands Water District for as much as
$500 million, which could still be cheaper than meeting a court order to
provide a new drainage network for irrigation water. On the surface that
sounds good, since it would halt plans to dump the polluted water into
the Sacramento-San Joaquin Delta and San Francisco Bay, threatening
salmon and other fish, and potentially reduce agricultural water demand
in the State. The problem is that under the plan the District keeps the
water.  An even bigger problem is the size of the subsidy of an already
heavily subsidized district.  U.S. Representative George Miller (D-CA),
for one, has been highly critical of the Interior-Westlands plan. Others
have also chimed in. "The taxpayers paid for 95 percent of the water for
them to farm, and now they're trying to get the taxpayer to pay them not
to farm," the Natural Resources Defense Council's Barry Nelson, a water
policy analyst, told the Contra Costa Times. "Westlands is farming the
taxpayers far more than they're farming the land in the Central Valley."
For more information on the proposed Westlands land fallowing, see the
16 November Fresno Bee at:
http://www.fresnobee.com/state_wire/story/5219395p-6227760c.html.
Also see the Contra Costa Times at:
http://www.bayarea.com/mld/cctimes/4535224.htm. 

     6:22/10. CALIFORNIA SALMON COUNCIL TO MEET,
CONSIDER MSC CERTIFICATION: The California Salmon Council
will meet Tuesday, 10 December, at the California Farm Bureau
Federation offices in Sacramento. One of the main agenda items for the
commodity council's first fall meeting is the matter of seeking Marine
Stewardship Council (MSC) certification of California chinook (king)
salmon.  The Salmon Council was awarded a $125,000 grant from the
California Department of Food & Agriculture to pursue MSC
certification (as sustainably-harvested) of their fish.  For more
information, go to the Salmon Council website at:
www.calkingsalmon.org. 

     6:22/11. CALIFORNIA FISH & GAME COMMISSION TO MEET
IN MONTEREY; COHO, NEARSHORE, TRANSGENICS ON
AGENDA: The California Fish & Game Commission will meet
Thursday and Friday, 5-6 November, at the Monterey Beach Resort
Hotel, 2600 San Dunes Drive in Monterey. Thursday's meeting schedule
includes the public testimony on the request by the Natural Resource
Defense Council, Center for Marine Conservation, IFR and PCFFA to
have transgenic fish listed as a restricted species and defined in State
regulations (add section 1.92 and amend section 671, Title 14 CCR). The
adoption hearing for the transgenic addition/amendments is scheduled
for the Commission's 7 February meeting in Los Angeles/ San Pedro.
Also on the agenda is the status report on the preparation of the Coho
Recovery Plan and the consideration of adoption of emergency
regulations to decide what sort of interim measures will be taken in
between possible listing and the Recovery Plan implementation. There
will also be testimony taken on the cowcod closure area and the
nearshore fishery restricted access (limited entry) program.  On Thursday
evening, the California Department of Fish & Game will hold a hearing
on State conformance with the federal commercial groundfish
regulations.  For more information on the agenda:
www.dfg.ca.gov/fg_comm/12-05-02agd.html.  

NEWS, COMMENTS, CORRECTIONS: Submit your news items,
comments or any corrections to Editor at: sublegals@ifrfish.org, or call
the IFR/PCFFA office with the news and a source at either: (415)
561-FISH (Southwest Office) or (541) 689-2000 (Northwest Office).  
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