223 



DRAFT 



harvest rates for coho seem substantially high as well. Therefore, concluding 

 statements about the effect of harvest rates on populations are also false. 



Coho Salmon (pages 40-41) 



'The Columbia River coho salmon run. which has about five percent 

 wild fish, is managed for the maximum production of the hatchery 

 component (Crammer (sic) et al. , 1991). " 



The Columbia River Compact considered Clackamas River wild coho in management 

 decisions to regulate the commercial gill-net fishery in 1991. 



Page 42, 1.2.6. Present Wild Fish Management Policy 



A paragraph is presented on each of the major sections of the policy that were approved 

 in 1990, with the exception of the section on habitat. Statements to the effect that 

 ODFW "shall oppose habitat degradation that causes a population to experience a 

 decline in abundance. . . " [OAR 635-07-527 (2)] have been left out of the discussion. In 

 addition, the 1990 version of the policy was updated and expanded in 1992. 



Section 1.3 Hatcher 



Page 47, 1.3.2. Hatchery Culture Practices 



Since 1977, ODFW researchers have developed an extensive data base of survival and 

 hatchery practices that guide hatchery programs. The authors make no mention of 

 studies published by ODFW scientists on these subjects [for example: Johnson et al. 

 1990 and Solazzi et al. (1991)]. 



'Current hatchery practices commonly maintain fish in an unnatural, 

 stressful environment. " 



This statement implies that most hatchery fish are raised in a stressful environment. 

 This is not true. In some isolated instances fish may be stressed for short periods of 

 time due to crowding or low water flows and consequently low dissolved oxygen 

 levels, but this is not the common rearing practice at our present hatcheries. The 

 Department generally restricts the loading levels in rearing ponds and routinely 

 monitors dissolved oxygen levels in the outfall of hatchery rearing ponds. 



A-17 



