24 June 1997
William Stelle, Jr.
Regional Administrator
NMFS/Northwest Region
7600 Sand Point Way N.E.
Seattle, Washington 98115-0070

Re: "Report to Congress - Recommendations for Addressing the Impacts of California Sea Lions and Pacific Harbor Seals on Salmonids and West Coast Ecosystems."

Dear Mr. Stelle:

The undersigned represent a diverse group of environmentalists, many of whom are activists working to protect harbor seal populations. Some of us have backgrounds in marine mammal science, others are generalists. We are particularly familiar with our bioregions, the Russian River and the Sonoma coast, both north and south of the river. Since 1985, the harbor seal haulout at the mouth of the Russian River has been protected by Seal Watch, a group working in cooperation with the State Department of Parks and Recreation. Members of Seal Watch have contributed to this response. Also represented in CCSS are the seventy members of a group who guard the harbor seal rookery at The Sea Ranch.

We believe that this proposal will do nothing to improve or enhance the salmon population but will further its demise by diverting attention from the actual causes - habitat loss and mismanagement of the fishery. Pinnipeds and salmon have co-existed on the west coast for millions of years. It is the recent human impact of clearcutting, dredging, damming, and pollution that have caused the decline of the fishery. This proposal is unable to cite any scientific studies to support its thesis because there are none. Therefore, it is irrelevant and should be abandoned in favor of meaningful solutions based on solid scientific evidence.

Following are a few examples of the inadequacy of NMFS' proposal:

Linda Hanson's 1993 foraging study of the harbor seal haulout at the mouth of the Russian River is quoted at p. 31 of the Technical Memorandum. Unfortunately, her summary was not included. That summary is as follows:

"The scat analysis portion of the foraging study supported the conclusion that harbor seals at this site do not utilize salmon as a major prey species. Salmon remains, mostly of juvenile-sized fish, were found in only a small number of scat."

"The observations suggested that there is minimal predation by harbor seals on salmonids, because, among other reasons, the capture rates are low. The major component of diet represented prey outside the estuary. In conclusion, salmonids are an incidental part of harbor seal diet."

"There have been no specific studies that demonstrate pinniped numbers and declines in salmonid populations and no direct relationship is implied here."

Later, the Report states:

"While time and resources are expended attempting to fully assess the effects of predation, depressed salmonid populations at some sites could continue to decline due to pinnipeds, even if other sources have been curtailed."

The loss of the salmonid populations began in the forest and that is where recovery should begin. In W. Park Steiner's major work on the Russian River, "A History of the Salmonid Decline in the Russian River" (1996), it is stated on p. iii:

"Over 500 small dams, mostly private, trap sediment, limiting recruitment of downstream spawning gravel. Most tributary dams also block dams and agricultural water diversions reduce downstream flows and increase water temperatures."

"Consensus is growing that hatchery supplementation has had major negative impacts on the native or naturally reproducing salmonid populations. Russian River hatchery stocks, a melange of many different origins, are likely to be genetically less fit for survival in streams with wild fish."

"Timber harvest has had a major impact on the Russian River basin. Logging practices accelerated erosion which silted spawning riffles, diminished food availability, and reduced both spawning and rearing habitat."

Scientific evidence, (glaringly absent in the Draft Report) as well as common sense, clearly show that pinnipeds have caused neither the decline of the salmonid population and will not prevent its recovery. Human impact and human practices, on the other hand, have caused the decline and must be decisively addressed if the salmon are to be saved.

We ask National Marine Fishery Service to continue the protection of marine mammals and work toward the restoration of the salmon runs by improving habitat through such urgently needed measures as limiting erosion, reestablishing streamside forest canopy, limiting the diversion of water for development and reengineering flawed fish ladders. To insist that the recovery of salmonid populations depends on the removal of marine mammals is sheer scapegoating and reflects poorly on the mandate given NMFS.

Sincerely,

________________________

DIAN HARDY

for Restoration First/

Committee to Conserve Seals and Salmon

__________________________

DAVID BANNISTER

Chair, Sonoma Group, Sierra Club

___________________________

LAWRENCE WEISS

for Sonoma People for Animal Rights