221 



DRAFT 



'In the past, the number of spawners from the three coastal lake basins 

 was expanded to determine escapement for the entire Oregon coast. It 

 now appears probable that there was an overexpansion of spawning 

 densities from the index surveys. This over expansion of spawning 

 densities led to treated estimates of spawners, stock recruitment, and 

 escapemeru goals, and is believed responsible for underescapement and 

 overharvesting of coastal coho salmon. PFMC is preseruly revising the 

 method to estimate future spawning escapement for coho salmon... " 



This paragraph is a total misrepresentation of the methods of estimating coho spawning 

 escapement, the conclusions of PFMC (1992), and the work ODFW (not PFMC) is 

 doing to investigate the current methods to estimate spawners. Specifically: 



1. Estimates of coho salmon spawning abundance are derived from index 

 surveys in 14 basins plus 3 lake basins, not just the 3 lake basins as stated in this 

 paragraph. 



2. Preliminary data indicate that in years of very low escapement, estimates of 

 spawner abundance derived from the standard index streams are higher than 

 estimates derived from random surveys. Research into better methods to 

 estimate spawning escapement were initiated and are being conducted by 

 ODFW, not PFMC, as part of a continuing process to improve coho salmon 

 escapement estimates that began in 1980 [see Beidler and Nickelson (1980) and 

 Solazzi (1984)] 



3. If estimates of spawner abundance were inflated, they would result in 

 inflated stock recruitment and escapement goals, but would not result in 

 underescapement and overharvest because the relationship between catch and 

 escapement would remain the same (since catch is estimated directly from 

 escapement) and the MSY harvest rate would remain the same. The net result 

 would simply be that we would have fewer fish (both catch and escapement) 

 than we originally thought. 



Columbia River (pages 36-37) 



The goals listed for spring chinook are not wild fish goals, but rather an aggregation of 

 wild and hatchery fish. 



The lower river fall Chinook goal is not 17,000 adults. The only Lower Columbia 

 wild goal recognized is 5,700 for the North Lewis River. This goal has been exceeded 

 in every year of record. Data in Table 1.2-11 does describe wild fish, even though the 

 text does not make this distinction. 



'In 1990, spawning escapemeru goals were met for only three of eight 

 populations of wild anadromous salmonids in Oregon. " 



This statement is incorrect for the following reasons: 



A-15 



