192 



DRAFT 



to rank the factors included an assessment of the technical validity of the methodology, 

 and an evaluation of the scientific basis for the analyses according to the scientific 

 information presented in the report. 



SCOPE OF THE INFORMATION AND ANALYSIS 



The Department's review indicates the OFIC report contains major technical and 

 analytical weaknesses. These weaknesses are based upon failures to stratify analyses by 

 location and by species. 



Failure to Stratify by Species and Location 



The relative importance of factors affecting the productivity of salmonids in Oregon 

 varies by region, and watershed according to the distribution and intensity of various 

 human activities and environmental conditions. The OFIC report's analyses of the 

 relative importance of various environmental and management factors (Tables R- 1 , R- 

 2, Table 2.3-1) are based upon a statewide pooling of information that fails to include 

 regional variability in assessing the importance of these factors. 



The report's primary source of information comes from the Columbia River basin. 

 Conclusions from this information are generalized to the entire state. Specifically, the 

 majority of information presented on fishery harvest and management, hydroelectric 

 development impacts, and predation is based upon Columbia River data. Reliance 

 upon the history and dynamics of anadromous stock declines in this area to make 

 conclusions for all populations within the State is unwarranted because of the 

 following: 



(1) hydroelectric development, land and water use in this basin is unequalled in any 



other basin of the State; 



(2) the Columbia River basin has historically been the most active area for commercial 



fisheries, experiencing harvest rates well in excess of most other Oregon 

 watersheids; 



(3) predation results are uniquely applicable to large hydroelectric reservoirs of the 



Columbia River Basin; 



(4) the majority of wild anadromous salmonid production occurs in coastal tributaries 



totally unrelated to Columbia River conditions. 



An example of how the use of Columbia River information fails to depict statewide 

 conditions is the authors use of Columbia River tule and coho harvest data to represent 

 the impacts of harvest on all wild populations of anadromous salmonids (V. W. 

 Kaczynski and J.F. Palmisano, June 30, 1992). These stocks are of hatchery origin 

 and are managed for high catch rates. Harvest rates predicated on these hatchery stocks 

 is not a valid measure of the relative statewide harvest impacts on coastal stocks of 

 coho and chinook, or on stocks of steelhead or seanin cutthroat trout. 



