To: National Oceanic and Atmospheric Administration (NOAA)
Re: Comments regarding implementation of Section 120 permit
Docket ID: NOAA-NMFS-2019-0073
October 4, 2019
To Whom it may concern:
The Northwest Guides and Anglers Association has over 100 professional fishing guide and charter operators in the states of Oregon and Washington. Collectively, we represent tens of thousands of angler trips every year in the region.
We are writing you today, to express overwhelming support for the section 120 permit to remove problematic sea lions from the mainstem Columbia (RM 112 – McNary Dam) and all Columbia River tributaries to stem the rate of extinction for 13 species of listed Columbia Basin salmonids, and eulachon smelt as well as the decline of white sturgeon.
The predation problem is dire and demands immediate attention, to implement lethal measures of removal for both California and Stellar sea lions in the previously mentioned river reaches and tributaries.
Furthermore, we’d like to express these concerns, outlining the concern that the parameters of this permit may not stem the path to extinction. For this reason, we would like to make further recommendations outlined here:
- The limited scope of this permit does NOT address copious amounts of predation occurring on listed juvenile salmonids by other pinnipeds, such as the explosive population of harbor seals in the lower Columbia River estuary. Anecdotal observations suggest the region is losing hundreds of thousands of T&E salmonids to this effective predator.
- The eulachon smelt stronghold is the Cowlitz River (RM 67) so addressing the pinniped problem at RM 112 will provide little to no benefit to ESA listed eulachon.
- This section 120 permit addresses the effects of pinniped predation on Columbia River salmonids, smelt and sturgeon. However, thousands, likely tens of thousands of listed Oregon Coastal coho, Southern Oregon coho, Puget Sound salmon and steelhead and green sturgeon are also being taken by an abundant population of California and Stellar sea lion population in these affected areas.
- While implementation of this permit should aid in the recovery of threatened and endangered salmonids, smelt and sturgeon, this strategy does not address the other effects of decline for these species such as habitat loss, river modification due to hydropower projects and degraded water quality throughout the basin. State and federal agencies need to continue to address the needs of these species by implementing conservation measures that mitigate the effects of these issues.
Thank you for the opportunity to comment on the implementation of this program, it begins a start to recovery for these iconic species that fuel a $2.5 billion sportfishing industry in the Pacific Northwest.
Finally, our organization would like to express support for a representative from the NW Guides and Anglers Association for a position on the Pinniped-Fishery Interaction Task Force when nominations come up. Members of our organization are clear stakeholders in this process and wish to work towards a solution to deal with this growing problem.
Bob Rees, Executive Director
NW Guides and Anglers Association
P.O. Box 3208
Clackamas, OR 97015