[Fishlink] ~~>SUBLEGALS 27June03<~~
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~~>SUBLEGALS 27June03<~~
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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. 07, NO. 26 27 JUNE 2003
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"These are the times that try men's souls."..............Thomas Paine
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IN THIS ISSUE.......
Judge Sends Columbia River Biological Opinion Back to
NMFS for Major Revisions. 7:26/01
Columbia River Dredging Approved by Two States. 7:26/02
The Move for Offshore Oil Drilling Gains Momentum. 7:26/05, 7:25/06
WTO Ministerial is Met by Thousands of Protesters in
Sacramento. 7:26/07
Radioactive Waste Found in British Farmed Salmon. 7:26/10
AND MORE......
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7:26/01. COURT RULING PUTS COLUMBIA RIVER SALMON
PLAN REVIEW ON FAST TRACK, WITH CURRENT PLAN IN
PLACE IN INTERIM: On 23 June, U.S. District Court Judge James
Redden issued his ruling on the fate of the Columbia River Biological
Opinion that his earlier court ruling of 7 May 2003 had invalided as
"arbitrary and capricious," (see Sublegals, 7:19/04). His ruling sent the
Columbia salmon plan back to the National Marine Fisheries Service
(NMFS) for major revisions to be completed within one year, under
stringent court guidance, but maintaining its current standards in the
interim. The Judge is expected to issue a more comprehensive ruling,
with specific remand guidelines and strict timetables, on or about 3 July.
For more on the ruling, see the 27 June Oregonian at:
http://www.oregonlive.com/morenews/oregonian/index.ssf?/base/news/
1056715992252560.xml.
In a Congressional hearing before the Subcommittee on Fisheries,
Wildlife and Public Works of the Senate Committee on Environment
and Public Works, held in Washington, DC on 24 June, Administration
officials said that the Salmon Recovery Plan is "on track," and
characterized the problems that resulted in its being thrown out by the
Court as "technical in nature." Critics of the plan disagreed, noting that
not only was the current plan based on highly optimistic or even false
assumptions, but that it has also been poorly funded by the Bush
Administration, with fewer than 30 percent of its measures yet
implemented even after several years.
For the witness list and testimony from the Congressional Hearing on
24 June, refer to the Subcommittee's site at:
http://epw.senate.gov/stm1_108.htm#06-24-03. For more information
on the 23 June ruling and its implications, refer to Steve Mashuda,
Earthjustice, (206)343-7340 x. 27 or email to:
smashuda@earthjustice.org. For the testimony of Save Our Wild
Salmon, which has been critical of Administration efforts in the
Columbia to date, see: http://epw.senate.gov/108th/SOWS_062403.htm,
and also its web site at: http://www.wildsalmon.org.
7:26/02. CONTROVERSIAL COLUMBIA RIVER DREDGING
PLAN APPROVED BY TWO STATES, BUT WITH CONDITIONS
FOR PROTECTION OF SALMON AND CRABS: On 24 June, the
States of Oregon and Washington issued state permits that approved, but
are intended to strictly control impacts from, a controversial Army Corps
of Engineers plan to deepen 103 miles of the Columbia River shipping
channel from Portland, Oregon to the ocean. Oregon's Department of
Environmental Quality (DEQ) heavily conditioned its own approval of
water quality permits for the project, largely in response to many
concerns raised by the public about the environmental impacts of this
project on lower river salmon and Dungeness crab nurseries.
The DEQ findings and reports can be downloaded from:
http://www.deq.state.or.us/wq/401Cert/401CertHome.htm#ColRiv.
Additional rulings from Oregon's Department of Land Conservation and
Development (DLCD) (http://www.lcd.state.or.us) and from Washington
State's Department of Ecology
(http://www.ecy.wa.gov/programs/sea/cr-channel.html) were also
handed down on 24 June. These documents can also be viewed at
https://www.nwp.usace.army.mil/issues/CRCIP/pubs.htm through the
Corps "Application for Water Quality Certification" and "Coastal Zone
Management Act Consistency" links.
Crab fishermen, led by the Columbia River Crab Fishermen's
Association (CRCFA) and joined by PCFFA, have strongly opposed the
massive channel dredging program because of plans to dispose of dredge
spoils on top of prime Columbia River Dungeness crab nursery grounds,
jeopardizing a $50 million crab fishery. Additionally, mounding of
dredge spoils in the estuary causes wave amplification, which can cost
fishermen's lives (see Sublegals, 6:23/08; 4:15/01; 4:13/05; 4:09/15;
4:04/12; 2:08/05; 2:06/10; 1:07/01). Columbia River salmon fishermen,
including PCFFA associate member Salmon for All, as well as salmon
conservation groups generally, also oppose the channel deepening
project because it would ruin more lower river salmon spawning and
rearing habitat, which is already 90 percent destroyed (see Sublegals,
6:06/14; 5:21/01; 5:07/12; 5:2/17), making salmon recovery just that
much harder.
DEQ's permit conditions require timing of dredging to avoid
migrating salmon, and also requires monitoring for turbidity and
dissolved oxygen, with parameters that could stop work if exceeded.
DEQ and Ecology both mandated testing for chemical contaminants in
the project area outside the main 600-foot wide channel, including
turning basins, berths and over-width dredging sites. Specific mitigation
plans were also required to prevent damage to crab and sturgeon. Both
states set guidelines for in-water disposal and provided additional timing
restrictions to protect Columbia River smelt, a major food source for
salmon. Washington's Department of Ecology also authorized ocean
disposal of dredge spoils at a proposed dumpsite about five miles off the
mouth of the Columbia River, and required the Corps to "develop and
adhere to a crab mitigation strategy designed to avoid and minimize the
entrainment and burial of Dungeness crab."
For the 25 June Oregonian story on the state approvals and permit
conditions, see:
http://www.oregonlive.com/morenews/oregonian/index.ssf?/base/news/
1056543021226390.xml. For more information on the problems with the
deepening project contact: Columbia Deepening Opposition Group
(CDOG), Peter Huhtala, (503) 791-7028, or email to:
huhtala@teleport.com. For issues raised by commercial crab fishermen
contact: Dale Beasley, CRCFA Commissioner, (360)642-3942, or email
to: crabby@willapabay.org.
7:26/03. DRAFT KLAMATH FERC RELICENSING
APPLICATION OUT FOR REVIEW, NO FISH PASSAGE
PROPOSED FOR IRON GATE DAM: Iron Gate Dam, which has no
fish passage and which sits astride the Klamath River at river mile 190,
has become the end of the line for salmon migration in the Klamath
since its construction in 1962. All salmon runs above that dam have
been extirpated, though several could potentially be restored.
Iron Gate Dam and several other small hydropower dams that
comprise the Klamath Hydroelectric Project are now coming up for
federal relicensing through the Federal Energy Regulatory Commission
(FERC). The Project's license (FERC License No. 2028) expires on 1
March 2006. The Klamath River was once the third most productive
salmon river system in the U.S.
PacifiCorps (a division of Scottish Power), which owns and operates
the Klamath Hydroelectric Project, is preparing to submit a relicensing
application to FERC by early 2004. To that end, on 24 June the
company released its "Draft Application for Relicensing," available on
the Internet at: http://www.pacificorp.com/Article/Article28613.html.
Written comments on the Draft Application must be submitted within 90
days from that date (i.e., until 22 September 2003) to: Todd Olson,
PacifiCorp, 825 NE Multnomah Street, Suite 1500, Portland, OR 97232.
The current "Exhibit C: Construction History and Proposed
Construction" does not include any planned construction of fish passage
facilities at Iron Gate Dam.
Restoring fish passage, and potentially decommissioning some of
these dams to do it, has become a major issue in FERC relicensing
negotiations. PacifiCorps has to date refused to seriously consider
decommissioning of any portion of the Klamath Hydroelectric Project.
The State of California, however, plans to ask that FERC include
decommissioning as one of the options for serious study. In a recent
report by the California Energy Commission, "Preliminary Assessment
of Energy Issued Associated with the Klamath Hydroelectric Project,"
dated 28 April, the Commission noted: "Energy Commission staff's
assessment indicates that, in terms of the potential impact to electricity
resource adequacy, decommissioning one or more of the dams is a viable
alternative that should be examined during the proceedings on the
possible renewal of the FERC hydroelectric license." For a copy of this
report contact the California Energy Commission, Public Relations,
1516 Ninth Street, MS-29, Sacramento, CA 95814-5512, or call Kevin
Kennedy, (916)651-8836 or by email to: Kkennedy@energy.state.ca.us.
The report will soon be posted on the CEC website. CEC's Home Page
is at: http://www.energy.ca.gov.
7:26/04. SAVAGE RAPIDS DAM DECOMMISSIONING BILL IN
CONGRESS: On 20 June, Oregon Senators Ron Wyden and Gordon
Smith introduced a bill in Congress (S. 1308) to authorize funding to
decommission and replace the aging Savage Rapids Dam, which blocks
Southern Oregon's once great Rogue River, with modern screened
pumps that would restore full fish passage. The bill would provide
authorization authority for "such sums as may be necessary to carry out
provisions" of the Act, which formally ratifies a lawsuit settlement
agreement reached on 27 August 2001 (U.S. Federal District Court of
Oregon, U.S. vs. Grants Pass Irrigation District, Civil No. 98-3034-HO)
that will eventually lead to dam decommissioning, but which requires
federal funding to help implement. PCFFA and IFR, along with
Waterwatch of Oregon and others, were Intervenors in the suit,
originally brought by the National Marine Fisheries Service. (see
Sublegals, 5:03/13; 4:15/06; 4:04/09; 2:17/11). The bill is now in the
Senate Energy and Natural Resources Committee but not yet scheduled
for a hearing.
Savage Rapids Dam is an 82-year-old water diversion dam that
blocks more than 500 river miles of suitable upstream steelhead and
salmon habitat, destroying a fishery worth at least $5 million to the
Oregon economy, according to U.S. Army Corps of Engineers economic
studies. The two Oregon Senator's co-authored a similar Savage Rapid
Dam removal bill in the 106th Congress (S. 3227), but prior to the
settlement. For more information about Savage Rapids Dam, contact:
Waterwatch of Oregon, Steve Pedery, (503)295-4039 x 26, or by email
to: steve@waterwatch.org. The bills can be found by searching at:
http://thomas.loc.gov.
7:26/05. OFFSHORE DRILLING FINDS RENEWED SUPPORT
DURING RECESSION: Mounting economic pressures appear to be the
driving force behind reports of new possibilities for offshore oil drilling
in both the United States and Canada. In Bristol Bay, Alaska the Bristol
Bay Native Corporation (BBNC) has announced its support for the
exploration and extraction of oil resources on the outer continental shelf
of the North Aleutian Basin. The BBNC is a private corporation
working to provide for the needs of native peoples. Salmon has long
been the primary sustenance for native people in Bristol Bay, but those
days may be gone according to some BBNC leaders.
Paul Roehl, BBNC vice-president, points out that wholesale salmon
prices are currently down to about 40 cents per pound compared to
roughly 30 dollars per barrel for oil. Roehl said the BBNC intends to
protect the region's salmon populations by ensuring that any drilling or
exploration is done in an environmentally responsible manner. With this
announcement and future efforts the BBNC hopes to hasten the end of a
current moratorium on offshore drilling while attracting oil companies to
Bristol Bay. For more see the 15 June Fairbanks Daily News-Miner
article at:
http://www.news-miner.com/Stories/0,1413,113%257E7244%257E1457
127,00.html?search=filter.
Meanwhile, officials in British Columbia's government have
announced plans to begin seismic testing for offshore oil and gas
reserves around the Queen Charlotte Islands by 2005. This plan comes
despite several major obstacles. Opposition from native peoples and
conservationists has been swift and strong since the government decided
to reconsider drilling earlier this year. Conservationists argue that the
seismic testing required for exploration would be fatal to many fish and
marine mammals in the area. The Haida Tribe has also filled a lawsuit
in British Columbia's Supreme Court challenging the government's claim
of ownership of the oil reserves. For the Provincial government's 30
May press release on the issue see: http://www2.news.gov.bc.ca/
nrm_news_releases/2003EM0008-000536.htm.
Down East in the great state of Maine, the U.S. Senate's recent
agreement to allow oil exploration in coastal areas, including around
Georges Bank, has led many to fear for the future of this lucrative
fishery. The public fears that if oil is indeed found and drilling then
permitted, oil spills could ruin one of the best fishing grounds on the
continent, not to mention the negative effects it could have on tourism
and public health. To see more on this issue, see the 22 June article in
the Portland Press Herald at:
http://www.pressherald.com/news/state/030622explore.shtml.
7:26/06. WHO SAID IT'S ONLY ABOUT SURVEYS? NOAA
CZMA PROPOSALS WOULD PAVE THE WAY FOR NEW
DRILLING PERMITS: Last week much was said and written regarding
the implications of a recent U.S. Senate vote to allow surveys of coastal
oil and natural gas reserves (see Sublegals, 7:24/24). Those in favor of
exploration generally cited the need to know for the sake of managing
national energy supply and demand, and also pointed out that
authorization of any future surveys would do nothing to change the
overarching moratorium on offshore drilling or reduce state's rights to
block such plans.
However, on 11 June, just one day prior to the Senate vote, the
National Oceanic and Atmospheric Administration (NOAA) proposed
twenty-three changes to the Coastal Zone Management Act (CZMA),
which governs the permitting process for offshore drilling. Passed in
1972, the CMZA gave states the authority to review and potentially veto
proposed coastal and offshore drilling projects that were "inconsistent"
with state coastal protections. The twenty-three proposed changes
originated from Vice President Dick Cheney's closed-door energy policy
meetings held in 2001 with representatives from Enron and other
prominent energy corporations. "It's a power grab by the federal
government", said Mark Ferrulo, Director of the Florida Public Interest
Research Group. Energy industry representatives counter that the
proposals are still too weak to help them meet the nation's energy needs.
For more on the implications of these proposed changes, see the 23 June
Gainesville Sun article at:
http://gainesvillesun.com/apps/pbcs.dll/article?AID=/20030623/LOCAL
/306220011/1007.
The proposed new weakened "consistency determination" rules were
printed in the Federal Register at 68 Fed. Reg. 34851-34874 (11 June
2003). Comments on this document must be received by July 11, 2003.
Please send comments as an attachment to an email in either
WordPerfect or MSWord, or in the body of an email, to:
CZMAFC.ProposedRule@noaa.gov. Address all comments regarding
this notice to David Kaiser, Federal Consistency Coordinator, Coastal
Programs Division, Office of Ocean and Coastal Resource Management,
NOAA, 1305 East-West Highway, 11th Floor, Silver Spring, MD 20910.
Written comments may also be sent to this address. For further
information contact: David Kaiser, Federal Consistency Coordinator,
OCRM/NOAA, 301-713-3155 ext. 144, or email to:
david.kaiser@noaa.gov. To search the Federal Register go to:
http://www.gpoaccess.gov/fr/index.html.
7:26/07. WTO MINISTERIAL IS MET BY PROTESTERS IN
SACRAMENTO: The meeting of the U.S. Department of Agriculture
(USDA) sponsored World Trade Organization (WTO) Ministerial
Convention and Expo on Agricultural Technology took place in
Sacramento 23-25 June.
The meeting was billed as a showcase of high tech farming methods
that could help stop global hunger, but many saw it as a way for U.S.
agribusiness and biotechnology to bully developing nations into
lowering trade barriers against genetically modified (GM) foods. The
U.S. biotechnology industry spends two hundred and fifty million dollars
a year on promoting GM food. The agricultural ministers from one
hundred and fifteen nations were greeted in Sacramento by thousands of
protesters, who in turn were greeted by hundreds of cops dressed in full
riot gear, as well as circling police helicopters. The reaction to the
Ministerial meeting actually began three days prior, with a number of
events designed to educate and inform people of the global implications
of the meeting. The Institute for Fisheries Resources' (IFR) own Natasha
Benjamin taught people about the importance of buying wild salmon and
the impending patent for the transgenic salmon at the 21 June Teach-In
at California State University Sacramento.
The 23 June peaceful march was met by a large contingent of police,
horses, helicopters, and armored vehicles, but for the most part the local
and state police were content to peacefully guard government buildings
and the local Starbucks. The city of Sacramento spent about $750,000 on
policing the Ministerial, and the California Highway Patrol spent over
one million dollars, while forty people were arrested. The Ministerial
meeting is a precursor to the WTO 10-14 September 2003 meeting in
Cancun. The general public was not allowed into the Ministerial. For
more information see the 23 June articles in the San Francisco Chronicle
at:
http://sfgate.com/cgi-bin/article.cgi?f=/c/a/2003/06/23/MN309485.DTL,
and also at:
http://www.sfgate.com/cgi-bin/article.cgi?file=/c/a/2003/06/23/
MN52068.DTL or see the Pesticides Action Network's Report at:
http://www.panna.org/resources/panups/panup_20030630.dv.html.
7:26/08. ENVIRONMENTAL MINISTER ACCUSES UK OF
IGNORING GMO RISKS: The United Kingdom's recently ousted
Environmental Minister, Micheal Meacher, has accused the U.K.
government of systematically ignoring evidence that GM food could be a
hazard to human health and the environment. This comes as the British
government is preparing to release two reports claiming that it's in the
nation's best interest to embrace GM technology. In an article written in
The Independent on 22 June, Meacher lists a series of reports and
findings that suggest the GM food is unsafe.
This also comes as top-secret memos have been leaked detailing the
U.K. Cabinet's secret campaign to block European Union rules on the
labeling of GM foods because Cabinet officials fear that the rules may
alienate the U.S. This fall, Britain's Royal Society will release the results
of controversial scientific trials testing the effects of GM crops on
wildlife, and the government is expected to point to these results as it
pushes for Britain to grow GM crops, import GM food and maintain a
friendly relationship with the U.S. To see information on the Cabinet's
secret documents, go to:
http://news.scotsman.com/politics.cfm?id=610962003. To see
information on Michael Meachers statements on this issue, go to:
http://news.independent.co.uk/uk/environment/story.jsp?story=417828.
7:26/09. REPORT FINDS THAT COD FARMING MAY BE
WORSE THAN SALMON FARMING ON THE ENVIRONMENT:
Based upon finding a previously unseen report, The Scotsman
newspaper recently reported that plans for an expansion of the Scottish
fish farming industry to include cod, halibut and haddock could lead to a
serious increase in pollution of Scottish sea lochs and rivers. The report,
originally produced for the Convention for the Protection of the Marine
Environment of the North East Atlantic, found that cod farming would
bring about at least fifty percent more discharge and waste than that
generated by salmon farming per ton of produce. The nitrogen rich fecal
matter and food waste creates harmful algal blooms and depletes water
oxygen levels. With the Atlantic cod fishery recently shut down in
Canada, and Atlantic stocks dwindling to record lows (see Sublegals,
7:18/08), the notion of farming cod has become economically viable.
The report states that the Scottish aquaculture industry plans to produce
forty thousand tons of cod and whitefish annually in ten years. This
means that by 2030, farmed whitefish could be more prevalent than
farmed salmon. For more information see the 23 June issue of The
Scotsman at: http://www.thescotsman.co.uk/index.cfm?id=686232003.
7:26/10. RADIOACTIVE WASTE FOUND IN BRITISH FARMED
SALMON; SOME COUNTRIES RECONSIDERING
AQUACULTURE: Fresh and smoked farmed salmon taken from Great
Britain's six major supermarket chains have all tested positive for the
presence of a radioactive isotope, Technetium-99 (Tc-99), traced to a
particular Scottish nuclear facility. The study, published by the
conservation group Greenpeace, shows that every sample tested
registered some level of the radioactive by-product. The United
Kingdom's Food Standards Agency has been quick to point out that none
of the levels detected surpass the government's limits for the
contaminant. Previous tests have revealed Tc-99 in species of lobster
and shellfish as far away as Norway, which is also home to one of the
world's largest salmon farming industries. For more see the 24 June
BBC report on the findings at:
http://news.bbc.co.uk/2/hi/uk_news/scotland/3015994.stm, or the 23
June Daily Telegraph article at:
http://www.telegraph.co.uk/news/main.jhtml?xml=%2Fnews%2F2003%
2F06%2F23%2Fnsalm23.xml.
Meanwhile, lawmakers in New Zealand are struggling to meet a
self-imposed deadline for the adoption of revised aquaculture standards
before allowing any further development. The two-year moratorium set
to expire next March was intended to allow the government enough time
to establish "aquaculture management areas" and centralize control of
the aquaculture industry under one piece of legislation, the "Resource
Management Act." However, with mounting environmental and public
health concerns and increasing disputes over the lifespan of the permits
granted to aquaculture operations, it is unlikely that any legislation will
pass before the moratorium expires. For more, see the 22 June New
Zealand Herald article at: http://www.nzherald.co.nz/
storydisplay.cfm?storyID=3508558&msg=emaillink.
*********
Paying Attention?: What did Judge Redden recently decide about the
fate of the Columbia River Biological Opinion?
A) That it be sent back to NMFS for revision, to be completed in no
longer than four years, with enough time so that the Columbia River
Salmon become nearly extirpated.
B) That it be sent back to NMFS for revisions to be completed in one
year, meanwhile the old guidelines stay in place.
C) That it be sent back to NMFS for revision, and in the interim
Congressman Wally Herger writes the new guidelines.
D) That the Biological Opinion is completely valid and that the only
errors or false scientific statements come in the form of simple
grammatical and spelling mistakes.
E-Mail your answer to "Editor" at: sublegals@ifrfish.org. One winner is
drawn each week from a list of those submitting the correct answer.
And the Winner is......LIBBY EARTHMAN, who correctly answered,
"D) Claiming the KFMC overstepped its authority, he inserted language
in the Interior Appropriations bill to defund the KFMC," to the question,
"What did Wally Herger do to retaliate against the Klamath Fishery
Management Council?" She will receive an "Order of the Fringehead"
certificate and a handsome gray shirt with the cuddly Sarcastic
Fringehead Sublegals logo.
NEWS, COMMENTS, CORRECTIONS: Submit your news items,
comments or any corrections to Sara Randall, 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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&nbs=
p; &n=
bsp; ~~>SUBLEGALS 27June03<~~<BR>
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A WEEKLY QUOTA OF FISHERY SHORTS CAUGHT=
AND<BR>
LANDED BY THE INSTITUTE FOR FISHERIES RESOURCES <BR=
>
AND THE PACIFIC COAST FEDERATION OF FISHERMEN'S<BR>
&nbs=
p; &n=
bsp; =
ASSOCIATIONS<BR>
<BR>
VOL. 07, NO. 26 =
&nbs=
p; &n=
bsp; 27 JUNE 2003<BR>
##########################################################<BR>
"These are the times that try men's souls."..............Thomas Paine<BR>
##########################################################<BR>
IN THIS ISSUE.......<BR>
<BR>
Judge Sends Columbia River Biological Opinion Back to <BR>
NMFS for Major Revisions. 7:26/01<BR>
<BR>
Columbia River Dredging Approved by Two States. 7:26/02<BR>
<BR>
The Move for Offshore Oil Drilling Gains Momentum. 7:26/05, 7:25/06<BR>
<BR>
WTO Ministerial is Met by Thousands of Protesters in <BR>
Sacramento. 7:26/07 <BR>
<BR>
Radioactive Waste Found in British Farmed Salmon. 7:26/10<BR>
<BR>
AND MORE......<BR>
##########################################################<BR>
<BR>
7:26/01. COURT RULING PUTS COLUMBIA RIVER SAL=
MON<BR>
PLAN REVIEW ON FAST TRACK, WITH CURRENT PLAN IN<BR>
PLACE IN INTERIM: On 23 June, U.S. District Court Judge James<BR>
Redden issued his ruling on the fate of the Columbia River Biological<BR>
Opinion that his earlier court ruling of 7 May 2003 had invalided as<BR>
"arbitrary and capricious," (see Sublegals, 7:19/04). His ruling sent the<BR=
>
Columbia salmon plan back to the National Marine Fisheries Service<BR>
(NMFS) for major revisions to be completed within one year, under<BR>
stringent court guidance, but maintaining its current standards in the<BR>
interim. The Judge is expected to issue a more comprehensive ruling,<B=
R>
with specific remand guidelines and strict timetables, on or about 3 July. <=
BR>
For more on the ruling, see the 27 June Oregonian at:<BR>
http://www.oregonlive.com/morenews/oregonian/index.ssf?/base/news/<BR>
1056715992252560.xml.<BR>
<BR>
In a Congressional hearing before the Subcommittee=20=
on Fisheries,<BR>
Wildlife and Public Works of the Senate Committee on Environment<BR>
and Public Works, held in Washington, DC on 24 June, Administration<BR>
officials said that the Salmon Recovery Plan is "on track," and<BR>
characterized the problems that resulted in its being thrown out by the<BR>
Court as "technical in nature." Critics of the plan disagreed, noting=20=
that<BR>
not only was the current plan based on highly optimistic or even false<BR>
assumptions, but that it has also been poorly funded by the Bush<BR>
Administration, with fewer than 30 percent of its measures yet<BR>
implemented even after several years.<BR>
<BR>
For the witness list and testimony from the Congres=
sional Hearing on<BR>
24 June, refer to the Subcommittee's site at:<BR>
http://epw.senate.gov/stm1_108.htm#06-24-03. For more information<BR>
on the 23 June ruling and its implications, refer to Steve Mashuda,<BR>
Earthjustice, (206)343-7340 x. 27 or email to:<BR>
smashuda@earthjustice.org. For the testimony of Save Our Wild<BR>
Salmon, which has been critical of Administration efforts in the<BR>
Columbia to date, see: http://epw.senate.gov/108th/SOWS_062403.htm,<BR>
and also its web site at: http://www.wildsalmon.org.<BR>
<BR>
7:26/02. CONTROVERSIAL COLUMBIA RIVER DREDGING<BR>
PLAN APPROVED BY TWO STATES, BUT WITH CONDITIONS<BR>
FOR PROTECTION OF SALMON AND CRABS: On 24 June, the<BR>
States of Oregon and Washington issued state permits that approved, but<BR>
are intended to strictly control impacts from, a controversial Army Corps<BR=
>
of Engineers plan to deepen 103 miles of the Columbia River shipping<BR>
channel from Portland, Oregon to the ocean. Oregon's Department of<BR>
Environmental Quality (DEQ) heavily conditioned its own approval of<BR>
water quality permits for the project, largely in response to many<BR>
concerns raised by the public about the environmental impacts of this<BR>
project on lower river salmon and Dungeness crab nurseries. <BR>
<BR>
The DEQ findings and reports can be downloaded from=
:<BR>
http://www.deq.state.or.us/wq/401Cert/401CertHome.htm#ColRiv. <BR>
Additional rulings from Oregon's Department of Land Conservation and<BR>
Development (DLCD) (http://www.lcd.state.or.us) and from Washington<BR>
State's Department of Ecology<BR>
(http://www.ecy.wa.gov/programs/sea/cr-channel.html) were also<BR>
handed down on 24 June. These documents can also be viewed at<BR=
>
https://www.nwp.usace.army.mil/issues/CRCIP/pubs.htm through the<BR>
Corps "Application for Water Quality Certification" and "Coastal Zone<BR>
Management Act Consistency" links.<BR>
<BR>
Crab fishermen, led by the Columbia River Crab Fish=
ermen's<BR>
Association (CRCFA) and joined by PCFFA, have strongly opposed the<BR>
massive channel dredging program because of plans to dispose of dredge<BR>
spoils on top of prime Columbia River Dungeness crab nursery grounds,<BR>
jeopardizing a $50 million crab fishery. Additionally, mounding of<BR>
dredge spoils in the estuary causes wave amplification, which can cost<BR>
fishermen's lives (see Sublegals, 6:23/08; 4:15/01; 4:13/05; 4:09/15;<BR>
4:04/12; 2:08/05; 2:06/10; 1:07/01). Columbia River salmon fishermen,<=
BR>
including PCFFA associate member Salmon for All, as well as salmon<BR>
conservation groups generally, also oppose the channel deepening<BR>
project because it would ruin more lower river salmon spawning and<BR>
rearing habitat, which is already 90 percent destroyed (see Sublegals,<BR>
6:06/14; 5:21/01; 5:07/12; 5:2/17), making salmon recovery just that<BR>
much harder.<BR>
<BR>
DEQ's permit conditions require timing of dredging=20=
to avoid<BR>
migrating salmon, and also requires monitoring for turbidity and<BR>
dissolved oxygen, with parameters that could stop work if exceeded. <BR>
DEQ and Ecology both mandated testing for chemical contaminants in<BR>
the project area outside the main 600-foot wide channel, including<BR>
turning basins, berths and over-width dredging sites. Specific mitigat=
ion<BR>
plans were also required to prevent damage to crab and sturgeon. Both<BR>
states set guidelines for in-water disposal and provided additional timing<B=
R>
restrictions to protect Columbia River smelt, a major food source for<BR>
salmon. Washington's Department of Ecology also authorized ocean<BR>
disposal of dredge spoils at a proposed dumpsite about five miles off the<BR=
>
mouth of the Columbia River, and required the Corps to "develop and<BR>
adhere to a crab mitigation strategy designed to avoid and minimize the<BR>
entrainment and burial of Dungeness crab." <BR>
<BR>
For the 25 June Oregonian story on the state approv=
als and permit<BR>
conditions, see:<BR>
http://www.oregonlive.com/morenews/oregonian/index.ssf?/base/news/<BR>
1056543021226390.xml. For more information on the problems with the<BR>
deepening project contact: Columbia Deepening Opposition Group<BR>
(CDOG), Peter Huhtala, (503) 791-7028, or email to:<BR>
huhtala@teleport.com. For issues raised by commercial crab fishermen<B=
R>
contact: Dale Beasley, CRCFA Commissioner, (360)642-3942, or email<BR>
to: crabby@willapabay.org.<BR>
<BR>
7:26/03. DRAFT KLAMATH FERC RELICENSING<BR>
APPLICATION OUT FOR REVIEW, NO FISH PASSAGE<BR>
PROPOSED FOR IRON GATE DAM: Iron Gate Dam, which has no<BR>
fish passage and which sits astride the Klamath River at river mile 190,<BR>
has become the end of the line for salmon migration in the Klamath<BR>
since its construction in 1962. All salmon runs above that dam have<BR=
>
been extirpated, though several could potentially be restored. <BR>
<BR>
Iron Gate Dam and several other small hydropower da=
ms that<BR>
comprise the Klamath Hydroelectric Project are now coming up for<BR>
federal relicensing through the Federal Energy Regulatory Commission<BR>
(FERC). The Project's license (FERC License No. 2028) expires on 1<BR>
March 2006. The Klamath River was once the third most productive<BR>
salmon river system in the U.S. <BR>
<BR>
PacifiCorps (a division of Scottish Power), which o=
wns and operates<BR>
the Klamath Hydroelectric Project, is preparing to submit a relicensing<BR>
application to FERC by early 2004. To that end, on 24 June the<BR>
company released its "Draft Application for Relicensing," available on<BR>
the Internet at: http://www.pacificorp.com/Article/Article28613.html. <BR>
Written comments on the Draft Application must be submitted within 90<BR>
days from that date (i.e., until 22 September 2003) to: Todd Olson,<BR>
PacifiCorp, 825 NE Multnomah Street, Suite 1500, Portland, OR 97232. <=
BR>
The current "Exhibit C: Construction History and Proposed<BR>
Construction" does not include any planned construction of fish passage<BR>
facilities at Iron Gate Dam.<BR>
<BR>
Restoring fish passage, and potentially decommissioning s=
ome of<BR>
these dams to do it, has become a major issue in FERC relicensing<BR>
negotiations. PacifiCorps has to date refused to seriously consider<BR>
decommissioning of any portion of the Klamath Hydroelectric Project. <BR>
The State of California, however, plans to ask that FERC include<BR>
decommissioning as one of the options for serious study. In a recent<B=
R>
report by the California Energy Commission, "Preliminary Assessment<BR>
of Energy Issued Associated with the Klamath Hydroelectric Project,"<BR>
dated 28 April, the Commission noted: "Energy Commission staff's<BR>
assessment indicates that, in terms of the potential impact to electricity<B=
R>
resource adequacy, decommissioning one or more of the dams is a viable<BR>
alternative that should be examined during the proceedings on the<BR>
possible renewal of the FERC hydroelectric license." For a copy of thi=
s<BR>
report contact the California Energy Commission, Public Relations,<BR>
1516 Ninth Street, MS-29, Sacramento, CA 95814-5512, or call Kevin<BR>
Kennedy, (916)651-8836 or by email to: Kkennedy@energy.state.ca.us. <BR>
The report will soon be posted on the CEC website. CEC's Home Page<BR>
is at: http://www.energy.ca.gov.<BR>
<BR>
7:26/04. SAVAGE RAPIDS DAM DECOMMISSIONING BILL IN<=
BR>
CONGRESS: On 20 June, Oregon Senators Ron Wyden and Gordon<BR>
Smith introduced a bill in Congress (S. 1308) to authorize funding to<BR>
decommission and replace the aging Savage Rapids Dam, which blocks<BR>
Southern Oregon's once great Rogue River, with modern screened<BR>
pumps that would restore full fish passage. The bill would provide<BR>
authorization authority for "such sums as may be necessary to carry out<BR>
provisions" of the Act, which formally ratifies a lawsuit settlement<BR>
agreement reached on 27 August 2001 (U.S. Federal District Court of<BR>
Oregon, U.S. vs. Grants Pass Irrigation District, Civil No. 98-3034-HO)<BR>
that will eventually lead to dam decommissioning, but which requires<BR>
federal funding to help implement. PCFFA and IFR, along with<BR>
Waterwatch of Oregon and others, were Intervenors in the suit,<BR>
originally brought by the National Marine Fisheries Service. (see<BR>
Sublegals, 5:03/13; 4:15/06; 4:04/09; 2:17/11). The bill is now in the=
<BR>
Senate Energy and Natural Resources Committee but not yet scheduled<BR>
for a hearing.<BR>
<BR>
Savage Rapids Dam is an 82-year-old water diversion=
dam that<BR>
blocks more than 500 river miles of suitable upstream steelhead and<BR>
salmon habitat, destroying a fishery worth at least $5 million to the<BR>
Oregon economy, according to U.S. Army Corps of Engineers economic<BR>
studies. The two Oregon Senator's co-authored a similar Savage Rapid<BR>
Dam removal bill in the 106th Congress (S. 3227), but prior to the<BR>
settlement. For more information about Savage Rapids Dam, contact:<BR>
Waterwatch of Oregon, Steve Pedery, (503)295-4039 x 26, or by email<BR>
to: steve@waterwatch.org. The bills can be found by searching at:<BR>
http://thomas.loc.gov.<BR>
<BR>
7:26/05. OFFSHORE DRILLING FINDS RENEWED SUPPORT<BR=
>
DURING RECESSION: Mounting economic pressures appear to be the<BR>
driving force behind reports of new possibilities for offshore oil drilling<=
BR>
in both the United States and Canada. In Bristol Bay, Alaska the Brist=
ol<BR>
Bay Native Corporation (BBNC) has announced its support for the<BR>
exploration and extraction of oil resources on the outer continental shelf<B=
R>
of the North Aleutian Basin. The BBNC is a private corporation<BR>
working to provide for the needs of native peoples. Salmon has long<BR=
>
been the primary sustenance for native people in Bristol Bay, but those<BR>
days may be gone according to some BBNC leaders.<BR>
<BR>
Paul Roehl, BBNC vice-president, points out that wh=
olesale salmon<BR>
prices are currently down to about 40 cents per pound compared to<BR>
roughly 30 dollars per barrel for oil. Roehl said the BBNC intends to<=
BR>
protect the region's salmon populations by ensuring that any drilling or<BR>
exploration is done in an environmentally responsible manner. With thi=
s<BR>
announcement and future efforts the BBNC hopes to hasten the end of a<BR>
current moratorium on offshore drilling while attracting oil companies to<BR=
>
Bristol Bay. For more see the 15 June Fairbanks Daily News-Miner<BR>
article at:<BR>
http://www.news-miner.com/Stories/0,1413,113%257E7244%257E1457<BR>
127,00.html?search=3Dfilter.<BR>
<BR>
Meanwhile, officials in British Columbia's governme=
nt have<BR>
announced plans to begin seismic testing for offshore oil and gas<BR>
reserves around the Queen Charlotte Islands by 2005. This plan comes<B=
R>
despite several major obstacles. Opposition from native peoples and<BR=
>
conservationists has been swift and strong since the government decided<BR>
to reconsider drilling earlier this year. Conservationists argue that=20=
the<BR>
seismic testing required for exploration would be fatal to many fish and<BR>
marine mammals in the area. The Haida Tribe has also filled a lawsuit<=
BR>
in British Columbia's Supreme Court challenging the government's claim<BR>
of ownership of the oil reserves. For the Provincial government's 30<B=
R>
May press release on the issue see: http://www2.news.gov.bc.ca/<BR>
nrm_news_releases/2003EM0008-000536.htm.<BR>
<BR>
Down East in the great state of Maine, the U.=
S. Senate's recent<BR>
agreement to allow oil exploration in coastal areas, including around<BR>
Georges Bank, has led many to fear for the future of this lucrative<BR>
fishery. The public fears that if oil is indeed found and drilling then<BR>
permitted, oil spills could ruin one of the best fishing grounds on the<BR>
continent, not to mention the negative effects it could have on tourism<BR>
and public health. To see more on this issue, see the 22 June article in<BR>
the Portland Press Herald at:<BR>
http://www.pressherald.com/news/state/030622explore.shtml.<BR>
<BR>
7:26/06. WHO SAID IT'S ONLY ABOUT SURVEYS? NOAA<BR>
CZMA PROPOSALS WOULD PAVE THE WAY FOR NEW<BR>
DRILLING PERMITS: Last week much was said and written regarding<BR>
the implications of a recent U.S. Senate vote to allow surveys of coastal<BR=
>
oil and natural gas reserves (see Sublegals, 7:24/24). Those in favor of<BR>
exploration generally cited the need to know for the sake of managing<BR>
national energy supply and demand, and also pointed out that<BR>
authorization of any future surveys would do nothing to change the<BR>
overarching moratorium on offshore drilling or reduce state's rights to<BR>
block such plans. <BR>
<BR>
However, on 11 June, just one day prior to the Sena=
te vote, the<BR>
National Oceanic and Atmospheric Administration (NOAA) proposed<BR>
twenty-three changes to the Coastal Zone Management Act (CZMA),<BR>
which governs the permitting process for offshore drilling. Passed in<=
BR>
1972, the CMZA gave states the authority to review and potentially veto<BR>
proposed coastal and offshore drilling projects that were "inconsistent"<BR>
with state coastal protections. The twenty-three proposed changes<BR>
originated from Vice President Dick Cheney's closed-door energy policy<BR>
meetings held in 2001 with representatives from Enron and other<BR>
prominent energy corporations. "It's a power grab by the federal<BR>
government", said Mark Ferrulo, Director of the Florida Public Interest<BR>
Research Group. Energy industry representatives counter that the<BR>
proposals are still too weak to help them meet the nation's energy needs. <B=
R>
For more on the implications of these proposed changes, see the 23 June<BR>
Gainesville Sun article at:<BR>
http://gainesvillesun.com/apps/pbcs.dll/article?AID=3D/20030623/LOCAL<BR>
/306220011/1007.<BR>
<BR>
The proposed new weakened "consistency determinatio=
n" rules were<BR>
printed in the Federal Register at 68 Fed. Reg. 34851-34874 (11 June<BR>
2003). Comments on this document must be received by July 11, 2003.<BR=
>
Please send comments as an attachment to an email in either<BR>
WordPerfect or MSWord, or in the body of an email, to:<BR>
CZMAFC.ProposedRule@noaa.gov. Address all comments regardi=
ng<BR>
this notice to David Kaiser, Federal Consistency Coordinator, Coastal<BR>
Programs Division, Office of Ocean and Coastal Resource Management,<BR>
NOAA, 1305 East-West Highway, 11th Floor, Silver Spring, MD 20910.<BR>
Written comments may also be sent to this address. For further<BR>
information contact: David Kaiser, Federal Consistency Coordinator,<BR>
OCRM/NOAA, 301-713-3155 ext. 144, or email to:<BR>
david.kaiser@noaa.gov. To search the Federal Register go to:<BR>
http://www.gpoaccess.gov/fr/index.html.<BR>
<BR>
7:26/07. WTO MINISTERIAL IS MET BY PROTESTERS=
IN<BR>
SACRAMENTO: The meeting of the U.S. Department of Agriculture<BR>
(USDA) sponsored World Trade Organization (WTO) Ministerial<BR>
Convention and Expo on Agricultural Technology took place in<BR>
Sacramento 23-25 June. <BR>
<BR>
The meeting was billed as a showcase of high=20=
tech farming methods<BR>
that could help stop global hunger, but many saw it as a way for U.S.<BR>
agribusiness and biotechnology to bully developing nations into<BR>
lowering trade barriers against genetically modified (GM) foods. The<BR>
U.S. biotechnology industry spends two hundred and fifty million dollars<BR>
a year on promoting GM food. The agricultural ministers from one<BR>
hundred and fifteen nations were greeted in Sacramento by thousands of<BR>
protesters, who in turn were greeted by hundreds of cops dressed in full<BR>
riot gear, as well as circling police helicopters. The reaction to the<BR>
Ministerial meeting actually began three days prior, with a number of<BR>
events designed to educate and inform people of the global implications<BR>
of the meeting. The Institute for Fisheries Resources' (IFR) own Natasha<BR>
Benjamin taught people about the importance of buying wild salmon and<BR>
the impending patent for the transgenic salmon at the 21 June Teach-In<BR>
at California State University Sacramento. <BR>
<BR>
The 23 June peaceful march was met by a large conti=
ngent of police,<BR>
horses, helicopters, and armored vehicles, but for the most part the local<B=
R>
and state police were content to peacefully guard government buildings<BR>
and the local Starbucks. The city of Sacramento spent about $750,000 on<BR>
policing the Ministerial, and the California Highway Patrol spent over<BR>
one million dollars, while forty people were arrested. The Ministerial<BR>
meeting is a precursor to the WTO 10-14 September 2003 meeting in<BR>
Cancun. The general public was not allowed into the Ministerial. For<BR>
more information see the 23 June articles in the San Francisco Chronicle<BR>
at:<BR>
http://sfgate.com/cgi-bin/article.cgi?f=3D/c/a/2003/06/23/MN309485.DTL,<BR>
and also at:<BR>
http://www.sfgate.com/cgi-bin/article.cgi?file=3D/c/a/2003/06/23/<BR>
MN52068.DTL or see the Pesticides Action Network's Report at:<BR=
>
http://www.panna.org/resources/panups/panup_20030630.dv.html. <BR>
<BR>
7:26/08. ENVIRONMENTAL MINISTER ACCUSES UK OF<BR>
IGNORING GMO RISKS: The United Kingdom's recently ousted<BR>
Environmental Minister, Micheal Meacher, has accused the U.K.<BR>
government of systematically ignoring evidence that GM food could be a<BR>
hazard to human health and the environment. This comes as the British<BR>
government is preparing to release two reports claiming that it's in the<BR>
nation's best interest to embrace GM technology. In an article written=
in<BR>
The Independent on 22 June, Meacher lists a series of reports and<BR>
findings that suggest the GM food is unsafe. <BR>
<BR>
This also comes as top-secret memos have been leake=
d detailing the<BR>
U.K. Cabinet's secret campaign to block European Union rules on the<BR>
labeling of GM foods because Cabinet officials fear that the rules may<BR>
alienate the U.S. This fall, Britain's Royal Society will release the result=
s<BR>
of controversial scientific trials testing the effects of GM crops on<BR>
wildlife, and the government is expected to point to these results as it<BR>
pushes for Britain to grow GM crops, import GM food and maintain a<BR>
friendly relationship with the U.S. To see information on the Cabinet'=
s<BR>
secret documents, go to:<BR>
http://news.scotsman.com/politics.cfm?id=3D610962003. To see<BR>
information on Michael Meachers statements on this issue, go to:<BR>
http://news.independent.co.uk/uk/environment/story.jsp?story=3D417828. <BR>
<BR>
7:26/09. REPORT FINDS THAT COD FARMING MAY BE=
<BR>
WORSE THAN SALMON FARMING ON THE ENVIRONMENT: <BR>
Based upon finding a previously unseen report, The Scotsman<BR>
newspaper recently reported that plans for an expansion of the Scottish<BR>
fish farming industry to include cod, halibut and haddock could lead to a<BR=
>
serious increase in pollution of Scottish sea lochs and rivers. The report,<=
BR>
originally produced for the Convention for the Protection of the Marine<BR>
Environment of the North East Atlantic, found that cod farming would<BR>
bring about at least fifty percent more discharge and waste than that<BR>
generated by salmon farming per ton of produce. The nitrogen rich fecal<BR>
matter and food waste creates harmful algal blooms and depletes water<BR>
oxygen levels. With the Atlantic cod fishery recently shut down in<BR>
Canada, and Atlantic stocks dwindling to record lows (see Sublegals,<BR>
7:18/08), the notion of farming cod has become economically viable.<BR>
The report states that the Scottish aquaculture industry plans to produce<BR=
>
forty thousand tons of cod and whitefish annually in ten years. This<BR>
means that by 2030, farmed whitefish could be more prevalent than<BR>
farmed salmon. For more information see the 23 June issue of The<BR>
Scotsman at: http://www.thescotsman.co.uk/index.cfm?id=3D686232003.<BR>
&nbs=
p; <BR>
7:26/10. RADIOACTIVE WASTE FOUND IN BRITISH F=
ARMED<BR>
SALMON; SOME COUNTRIES RECONSIDERING<BR>
AQUACULTURE: Fresh and smoked farmed salmon taken from Great<BR>
Britain's six major supermarket chains have all tested positive for the<BR>
presence of a radioactive isotope, Technetium-99 (Tc-99), traced to a<BR>
particular Scottish nuclear facility. The study, published by the<BR>
conservation group Greenpeace, shows that every sample tested<BR>
registered some level of the radioactive by-product. The United<BR>
Kingdom's Food Standards Agency has been quick to point out that none<BR>
of the levels detected surpass the government's limits for the<BR>
contaminant. Previous tests have revealed Tc-99 in species of lobster<=
BR>
and shellfish as far away as Norway, which is also home to one of the<BR>
world's largest salmon farming industries. For more see the 24 June<BR=
>
BBC report on the findings at:<BR>
http://news.bbc.co.uk/2/hi/uk_news/scotland/3015994.stm, or the 23<BR>
June Daily Telegraph article at:<BR>
http://www.telegraph.co.uk/news/main.jhtml?xml=3D%2Fnews%2F2003%<BR>
2F06%2F23%2Fnsalm23.xml. <BR>
<BR>
Meanwhile, lawmakers in New Zealand are strug=
gling to meet a<BR>
self-imposed deadline for the adoption of revised aquaculture standards<BR>
before allowing any further development. The two-year moratorium set<B=
R>
to expire next March was intended to allow the government enough time<BR>
to establish "aquaculture management areas" and centralize control of<BR>
the aquaculture industry under one piece of legislation, the "Resource<BR>
Management Act." However, with mounting environmental and public<BR>
health concerns and increasing disputes over the lifespan of the permits<BR>
granted to aquaculture operations, it is unlikely that any legislation will<=
BR>
pass before the moratorium expires. For more, see the 22 June New<BR>
Zealand Herald article at: http://www.nzherald.co.nz/<BR>
storydisplay.cfm?storyID=3D3508558&msg=3Demaillink. <BR>
&nbs=
p; &n=
bsp; =
*********<BR>
Paying Attention?: What did Judge Redden recently decide about the<BR>
fate of the Columbia River Biological Opinion?<BR>
<BR>
A) That it be sent back to NMFS for revision, to be completed in no<BR>
longer than four years, with enough time so that the Columbia River<BR>
Salmon become nearly extirpated.<BR>
B) That it be sent back to NMFS for revisions to be completed in one<BR>
year, meanwhile the old guidelines stay in place.<BR>
C) That it be sent back to NMFS for revision, and in the interim<BR>
Congressman Wally Herger writes the new guidelines.<BR>
D) That the Biological Opinion is completely valid and that the only<BR>
errors or false scientific statements come in the form of simple<BR>
grammatical and spelling mistakes. <BR>
<BR>
E-Mail your answer to "Editor" at: sublegals@ifrfish.org. One winner is<BR>
drawn each week from a list of those submitting the correct answer. <BR>
<BR>
And the Winner is......LIBBY EARTHMAN, who correctly answered,<BR>
"D) Claiming the KFMC overstepped its authority, he inserted language<BR>
in the Interior Appropriations bill to defund the KFMC," to the question,<BR=
>
"What did Wally Herger do to retaliate against the Klamath Fishery<BR>
Management Council?" She will receive an "Order of the Fringehead"<BR>
certificate and a handsome gray shirt with the cuddly Sarcastic<BR>
Fringehead Sublegals logo.<BR>
<BR>
NEWS, COMMENTS, CORRECTIONS: Submit your news items,<BR>
comments or any corrections to Sara Randall, editor at:<BR>
sublegals@ifrfish.org, or call the IFR/PCFFA office with the news and a<BR>
source at either: (415) 561-FISH (Southwest Office) or (541) 689-2000<BR>
(Northwest Office). <BR>
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<BR>
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<BR>
If you have any trouble subscribing or unsubscribing, contact<BR>
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R>
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reserved to IFR. This publication, however, may be freely reproduced <BR>
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s <BR>
as a subscriber, please feel free to pass this on to your colleagues. =20=
<BR>
Subscribers who wish to post or circulate hard copy of Sublegals or <BR>
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