On October 31, 1996, the Central Coast coho salmon was listed as threatened under the Federal Endangered Species Act.
Big Creek Lumber began investigations into the validity of the data under which it was listed, since it does not match historical field observations of generations of the McCrary family. Big Creek Lumber hired Fabian Alvarado as a researcher to sift through the historical and scientific records. CCFA’s Robert O. Briggs joined the investigation, which resulted in a petition by CCFA to the National Marine Fisheries Service to delist the coho salmon south of San Francisco because the coho could be demonstrated to be an introduced species which is naturally incompatible with the Central California terrain and climate.
Below is a summary of the petition written by co-researcher Robert O. Briggs, followed by a link to the full text of the petition.
Summary of the CCFA 2002 Petition to the National Marine Fisheries Service to Correct the Southern Boundary of the California Central Coast Coho Salmon
By Robert O. Briggs
Since October 31, 1996, Central Coast coho salmon have been listed as threatened under the Federal Endangered Species Act. CCFA believes in real environmental protection but multi-disciplinary research reveals a preponderance of evidence that coho salmon are not native to this location. Restoration of native coho salmon habitat is therefore not a valid reason for abridging property rights of farmers, fishermen, builders, timber growers and others using or enjoying Central Coast natural resources.
On September 11, 2002, with the advice and help of the Pacific Legal Foundation, we filed a petition (based on documented, local, scientific and historic findings) to redraw the southern boundary of the Central Coast Coho ESU to San Francisco Bay rather than southern Santa Cruz County. This petition lays out the facts showing that coho salmon are not native to the Santa Cruz Mountains streams and hence, could not be “ an important component in the evolutionary legacy of the species” as required for listing under the Endangered Species Act. Below, in highly abbreviated form, is the essence of our petition.
- Early scientific fish surveys in the Central Coast prior to heavy hatchery stocking beginning a century ago report no coho salmon south of San Francisco. Stanford Scientist, David Starr Jordan, in 1898, states that coho are found from San Francisco north. A second scientific study in 1912 confirms the absence of coho from Santa Cruz Mountains streams at that time. No credible scientific or historic evidence other than occasional, isolated anecdotal stories refutes this record.
- Massive numbers of hatchery coho have been continuously planted in Santa Cruz Mountains streams since the early 1900s making subsequent population reports meaningless and contributing to the myth of large, native populations. The laymen’s difficulty in distinguishing between steelhead and coho also probably contributed to misinformation.
- Geomorphologists, climatologists, and hydrologists believe that Santa Cruz Mountains streams are very hostile to permanent colonies of coho salmon. Due to their rigid life cycle (unlike steelhead and other salmonids), coho cannot interbreed between generations. This, and the lack of other adaptive options make the survival of each generation an important element for permanent populations. Droughts, floods, sand bar opening failure and other natural events will frequently extirpate a generation and makes permanent colonies of coho, with their very limited survival options, improbable.
- Since coho occasionally stray to non-natal streams, it is possible that occasional transient coho colonies existed prior to recent artificial stocking but the high probability of extirpation by frequent, natural, stochastic events makes permanent colonies unlikely.
- An extensive survey of archeological excavations of Central Coast Native American kitchen middens (refuse dumps) spanning the period from 6000 BC to the time of European settlement produced tens of thousands of fish remains, but no coho salmon remains appear in the Native’s dietary refuse. Steelhead remains are plentiful in the middens south of San Francisco and coho remains are found in middens from Contra Costa County northward. The archeologists and fish fossil experts conclude that coho were probably not present in these streams prior to recent artificial introduction.
Thus, history, archeology and physical sciences support the conclusion that coho are not native to the Santa Cruz Mountains streams and could not survive unless they were continuously restocked by artificial methods (as has been the case for nearly a century).
The Federal Endangered Species Act sets two criteria for listing a species as threatened.
- It must be substantially reproductively isolated from other conspecific population units.
- It must represent an important component in the evolutionary legacy of the species.
Our petition concludes: The best available scientific information shows that Santa Cruz Mountains streams have never supported and are incapable of supporting permanent, natural populations of coho salmon and that hatchery coho that are and/or have been present could not comprise an important component in the evolutionary legacy of the species. We therefore request that the California Coast from San Francisco Bay south be withdrawn from the Central Coast Coho ESU.
Here is the full text of the petition to NMFS to delist the coho south of San Francisco: