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DRAFT 



(3) limiting the comparison of "recent trends" to the period of the 1970's to 

 1990 is too short a timeframe to derive conclusions concerning the health of 

 anadromous populations. The effects of increased regulatory restrictions on 

 harvest, and natural variability in run sizes prohibit making definitive 

 conclusions based upon this range of information. 



In addition, the supporting tables and figures that report fishery harvest statistics 

 contain a significant number of inaccuracies (see Appendix A). 



Section 1.2 Fish Resource Agency Policies and Goals 



This section describes management goals and trends in the escapement of Oregon 

 Chinook and coho salmon stocks, and fishery agency policies related to the management 

 of these populations. The major problems within this section are as follows: 



(1) declines in Oregon's salmonids are attributed to harvest and harvest 

 management policies without recognizing that changes in the productivity of 

 individual stocks (as reflected by stock-recruitment relationships) due to 

 freshwater habitat degradation can influence spawning escapement. Changes in 

 freshwater habitat productivity can synergistically contribute to the decline of 

 salmonids when harvest management does not compensate for these changes. 



(2) escapement information for chum salmon, steelhead and searun cutthroat 

 were not presented due to lack of data on these species. However, the report 

 uses escapement trends for coho and chinook to conclude that harvest is a 

 primary factor in the decline of all Oregon's anadromous salmonids (Tables R- 

 l,R-2 and 2.3-1). 



(3) ODFW methods to estimate the escapement of coastal wild coho stocks are 

 inaccurately portrayed. 



(4) the report describes an ODFW Harvest Policy which does not exist. 



(5) in describing the ODFW Wild Fish Management Policy, no 

 acknowledgment is given to Habitat Policies which are an integral component. 



Section 1.3 Hatcherv Practices 



This discussion is a general presentation of past hatchery management practices (largely 

 based on Columbia River information) that is an inaccurate portrayal of the majority of 

 current ODFW Fish Propagation programs. The report fails to note that many of the 

 practices described have been discontinued. In addition, no information is presented 

 that could provide the basis to rank the importance of this management factor to the 

 decline of Oregon's anadromous salmonids. 



