222 



DRAFT 



1. Three of the eight salmon populations analyzed are not wild populations 

 based on the data used (Columbia River spring, summer, and Upper River fall 

 Chinook). 



2. Two of the populations are not Oregon populations: Columbia River sockeye 

 spawn in Washington; Snake River sockeye are from Idaho. 



3. Only one of the eight populations analyzed, OCN coho, correctly fits the 

 claim of a wild population not attaining the escapement goal. 



Page 38, 1.2.5. Production Harvest Policies 



Management Agencies (pages 38-39) 



"Harvest of Columbia River salmonids is managed by ODFW under the 

 Columbia River Management Plan. " 



The Columbia River Compact manages commercial fisheries in the Columbia River. 

 Oregon has one vote in this Compact. 



"State regulation within territorial waters (0-3 miles offshore) are not 

 required :o follow PFMC regulations. " 



This statement is incorrect. The State of Oregon has twice been preempted by the 

 Department of Commerce for opening fisheries within state marine waters that were 

 inconsistent with PFMC regulations for waters 3-200 miles offshore. 



'The Columbia River Management Plan is a litigation settlement... " 



The citations for this statement (ODFW, 1987, 1988) are incorrect. The proper 

 citation is the U.S. District Court legal description. 



Harvest Policy (page 39) 



It is unknown how the authors determined that the harvest policy cited is the ODFW 

 'harvest management policy". ODFW has no documented harvest policy with this 

 degree of specificity. 



Chinook Salmon (pages 39-40) 



The harvest rate data on which the authors conclusions are based are false. Also, ocean 

 harvest rates for Columbia River chinook are wrong, therefore, the total harvest rates 

 are wrong. The largest error is for 1987-89 Upriver fall Chinook. The 1961-69 ocean 



A-16 



