262 



DRAFT 



'Further, actual escapements year-to year are directly correlated with 

 perceru survival from production to escapement for the same years 

 (Figure S-5) 



This statement is false. Figure S-5 has the same errors in survival to escapement as 

 discussed above for page 131 and Table S-1. A statistical test of the correct data 

 demonstrates no relationship between the percent escapement from the fisheries and 

 escapement. 



Harvest Rates fpaee 136): 



'Forty to 60 percent harvest of wild salmonids is generally optimal for 

 maximum sustainable yield,.. . ' 



The source for this statement is not stated. However, MSY harvest rates for OCN 

 coho salmon have been estimated to be 61.8-72.8% (PFMC 1992, Table 1 and ODFW 

 Coho Plan) not 40-60%. 



Actual ocean and river harvests for both chinook and coho salmon have 

 ranged from roughly 70 to 90 percent... ' 



Except for one year, every year since adoption of the Coho Plan, harvest rates for 

 coastal coho have been below 60%. 



F-nvirynm ental Factors (p. 139-182) 



Page 139, Human-Influenced Biological Interactions 



Predation (pages 139-141) 



Predation and competition between naturally occurring species of fish and wildlife, 

 including salmonids, are certainly "natural phenomena" but the report presents these 

 relationships under the loosely defined category of 'human-ir0uenced biological 

 interactions'. 



No scientific evidence was presented to support the contention that "human actions" 

 have significantly changed overall marine mammal predation pressures on salmonids. 

 Since there have been no measures of this "pressure" 100 years ago, 50 years ago, or 

 even 10 years ago, it is not valid to suggest that such general predator-prey 

 relationsriips and interactions in the majority of the habitat have changed. It is true that 

 for specific fish stocks that have been depressed for reasons related to various human 

 activities, and at sites where dams, ladders, water diversions or other human structures 

 have restricted free movement of salmonids, pr^iation from pinnipeds can have 

 significant impacts (e.g. Ballard Locks, Seattle). However, there is no information 

 presented in the report that supports the premise that human actions have altered the 



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