In September 2012, NMFS released the “Recovery Plan for the Evolutionary Significant Unit of Central California Coast Coho Salmon”. This is a massive four-volume document that lays out the measures that NMFS recommends as the prescription for recovering coho salmon south of San Francisco.
CCFA learned of the document’s release through a Santa Cruz Sentinel article (“Feds announce Central Coast Coho salmon recovery plan” Jason Hoppin, 9/5/2012). Neither CCFA nor any landowner group to our knowledge was notified or consulted in the formation of this document.
A CCFA task force spent several days combing through the document. The first volume provides a broad overview of the plan and is the most readable of the documents. The subsequent volumes go through the recommended prescriptions watershed by watershed. CCFA suggests reader look up their own particular watershed to learn what is proposed for that area.
The resultant document is a property rights and public resources disaster. The only economic impacts of the recovery plan assessed are the government expenditures. Nothing is discussed about the damage that will be done to local businesses, private landowners and public resource services like water suppliers as a result of the actions.
Our major bullet points are:
- the ocean portion of the fish’s lifecycle is unaddressed and may be a very significant factor in its difficulties
- despite NMFS’s admission that the narrow valleys and steep gradients of central coast streams are poor habitat, they persist in forcing the salmon into them
- the NMFS prescriptions have no safe-harbor agreements attached; private landowners will lose use of their property if the fish colonizes their lands
- the woody debris placement programs have no attached liability coverage
- there is a plan of large setbacks around streams but no plan for where the displaced people and businesses are to go
- the public safety aspect of decommissioning roads is unaddressed.
- NMFS advocates removing dams and does not address how water supplies to the people served by these dams is to be replaced.
- the NMFS plan does not include any discussion about how the other threatened and endangered species of the central coast are to be managed concurrently with the coho salmon. Coho salmon and steelhead in particular require different features in their streams, and NMFS insists on cramming them together.
- the streams flowing into the San Francisco bay are not included
CCFA wrote to our federal legislators (Dianne Feinstein, Barbara Boxer, Anna Eshoo, Sam Farr and Jackie Spiere) laying out the problems we found in the recovery plan. This lengthy letter is included here:
There is no real answer provided to the well-documented problem of the incompatibility of the central coast environment and the coho life cycle. The coho absolutely requires access to its natal stream within a narrow time-window on the third year of its life. There are no other options. The central coast streams don’t work like that and NMFS does not have an active plan in place to open the channels during that time period, even assuming the rains have come in such a way as to ensure there is enough water in the streams in the first place.
Pescadero State Beach Steelhead Fish Kill Solution
One of the darlings of the coho recovery plan, ranking second after introducing woody debris into streams, is estuaries. Nearly every stream includes proposed estuary regulations that stipulate penalties for the illegal or casual breeching of sandbars. The Pescadero watershed is one of these locations.
It has now been shown that not all lagoons are created equal and not all sandbars are a good thing. The Coastal Alliance for Species Enhancement was forced to sue to gain permission to breach the sandbar that forms across Pescadero Marsh every fall, which results in a steelhead fish kill every winter when the first rains stirs up oxygen-depleted water and hydrogen sulfide are stirred up from the bottom of the marsh into the main body of water.
In September, 2012, permission was finally gained to breach the sandbar and allow an interchange of water between the marsh and the ocean (“Trout near beach to get help”, Aaron Kinney, San Jose Mercury News, 9/13/2012).
In January, the experiment was declared a success in another article, “Pilot Project prevents ‘fish kills’”, Aaron Kinney, San Jose Mercury News, 12/31/12.
We certainly hope it will not require a lawsuit every time the NMFS prescriptions need to be adjusted for local conditions.