January 6, 2012
Mr. Jim Kellogg, President
California Fish and Game Commission
P.O. Box 944209
Sacramento, CA 94244-2080
Dear President Kellogg and fellow Commissioners:
This letter will provide the comments of the Golden Gate Salmon Association (GGSA) on the proposal by the California Department of Fish and Game to change the bag and size limits on striped bass in order to comply with the court order of April 15, 2011. We have serious concerns about that proposal and have what we feel is a better alternate plan to offer the Commission.
The Golden Gate salmon Association was formed in December of 2010 to represent the interests of all segments of the salmon industry in promoting the actions it will take to rebuild the California Central Valley salmon stocks. We represent commercial fishermen, recreational anglers, native Americans, charter boats, coastal marinas, river guides, salmon equipment manufacturers, equipment and fish wholesalers and hundreds of salmon equipment retailers. The commercial operations of the salmon industry have no direct involvement in the striped bass fishery, however, they strongly support the proposals of this letter as being the best for rebuilding the salmon stocks.
Predation on juvenile salmon in the rivers and the Delta is a serious problem and is one of our primary concerns. Without question, the salmon industry has the most to gain if the impact of predation can be reduced and the most to lose if it cannot be reduced. We strongly support the reduction of predation on salmon fry and smolts but we feel the proposal under consideration by the Commission is far from optimum.
In cooperation with the fishery agencies, GGSA has recently undertaken the development of a plan for action steps that will rebuild the salmon stocks on a priority basis. We have arranged with some top salmon science advisors to assist us in this effort and the plan is now underway. In six to eight months we expect to highlight up to twenty five projects that we will propose for priority action. Steps to minimize predation will be an important part of that plan. We believe funding can be secured for implementation of these projects. A task force which includes the fishery agencies will participate in the work. It currently includes Mr. Kevin Shaffer of Fish and Game, Mr. Tristan Leong of NMFS, Mr. Jim Smith of the U.S. Fish and Wildlife Service and Dr. Josh Israel of the Bureau of Reclamation.
We believe the striped bass proposal now under consideration by the Commission is deeply flawed. We believe there are better alternates to deal with the entire predation problem which goes beyond striped bass and includes Pikeminnows and other predators. Some of our concerns with the proposed plan are:
- • The plan simply proposes to destroy striped bass. It does not address the root causes of much of the predation. Most scientists agree that heavy export pumping in the spring of the year is probably the biggest single reason for predation of juvenile salmon by striped bass, pikeminnows and other predators. The proposal by DFG and the court ignores this export problem. If the flows in the Delta were returned to a more natural estuarial flow where most of the water moves West towards the Bay and Ocean instead of South to the pumps, salmon and other migrating fish would return to their natural migration path and would not be pulled into the open channels of the Central Delta where they are easy prey for dozens of predators including striped bass.
- • In the opinion of the esteemed UC Davis scientists Dr. Peter Moyle and Dr. William Bennett, reducing the population of striped bass is most likely to have a negative effect on migrating native species. They point out that this type of plan is inadvertently playing roulette with basic ecosystem processes that can change in unexpected ways in response to reduced striped bass numbers. In their letter of recommendations to the Commission they conclude by saying, “We stress that attempting to reduce striped bass and other predator populations is unlikely to make a difference in saving endangered fishes, and will serve only to distract attention from some of the real problems.” GGSA and our science advisors agree with these statements particularly the point about distractions from the real problems.
- • Destruction of the striped bass populations will have a devastating impact on anglers and the fishing industry. Hundreds of businesses, thousands of jobs and hundreds of thousands of fishermen depend on the striped bass. Precise estimates of the economic impact of striped bass have not been made, but conservative estimates rank it at more than a billion dollars annually. GGSA believes there is no valid reason to destroy this entire industry and the recreation it provides to thousands of licensed anglers on the chance that the migrations of native fish will improve. There are better options with much less economic and natural resource risk.
- • By filing a lawsuit and forcing the plan to destroy stripers, the San Joaquin and Kern County water contractors continue in their efforts to divert attention from the primary water export causes of the salmon losses and the associated salmon rebuilding actions. GGSA and the salmon industry strongly oppose fisheries management by the water contractors and propose that their plan be soundly rejected by the Fish and Game Commission. Any other course of action simply invites more lawsuits against other predators like black bass or lawsuits to shut down the salmon fishing industry.
GGSA and the salmon industry believe the primary elements of a striped bass and other predator control plan should have two parts.
1) Dedicate a much greater percentage of unimpaired runoff in the winter and spring to Delta inflows and outflows, and generally restore more natural flow patterns throughout the year, in order to provide habitat conditions that promote much greater survival of native species populations and reduce the effects of predation and,
2) Aggressively remove hot spots where striped bass and other predators can congregate and easily attack juvenile native fish.
The GGSA plan will address both of these elements.
In summary, GGSA recommends that the Commission reject the current court approved plan in favor of the development of a better and more comprehensive plan to deal with these issues. We propose that GGSA along with other stakeholder organizations, DFG and the other fishery agencies work together to develop a new proposal. GGSA suggests the target timetable for completion of this work be eight months. We appreciate the opportunity to present our views.
Victor Gonella, President
Zeke Grader Roger Thomas Dick Pool John McManus
Vice Chairman Chairman Secretary Treasurer Executive Committee
Bob Boucke Caleen Sisk-Franco Darrell Ticehurst Director Director Director
Attachment: Pikeminnow Predation
cc. Honorable Edmund J. Brown, Governor
Mr. John Laird, Secretary, Natural Resources
Dr. Jerry Meral, Deputy Secretary, Resources
Mr. Chuck Bonham, Director, DFG
Mr. Charles R. Hoppin, Chair, Water Resources Control Board
Mr. Rod McInnis, Regional Director, NMFS
Mr. Ren Lohoefener, Regional Director, USFWS
Dr. Peter B. Moyle PhD, UC Davis
Dr. William A. Bennett, PhD, UC Davis