148 



The Draft Plan docs not equitably distribute the harden of salmon recovery among the 

 various sources of saUnoa mortality. 



A key clement of salmon recovery must be the equitable disttibution of the rcoovcty 

 burden. However, the Team's recommendations place a disproportionally high burden for 

 sahnon recovcty on treaty fisheries. The treaty fishety is one of th<; few sources of salmon 

 mortality for wfaidftfac Team sets measurable performance standards and the only source for 

 which the Team recommends an eventual mortality of zero. The Team's recommendations, if 

 adopted, would amotmt to a de facto abrogation of the tribes' treaty rigjits. 



The tribes' treaty secured fishing tights require that the burden for conserving the listed 

 Snake River salmon stocks must not be disproportionately placed on tribal fisheries nor may flie 

 •constrvafion" aspects of the recovery plan discriminate against tribal fisheries. Unfortunately, 

 the draft recovery plan does both. Despite the fact that for every one salmon an Indian catches, 

 non-Indian devdopmeot activities kill at least one hundred salmon, the tribes' small harveste are 

 still being blamed for tiie decrease in salmon. Hie truth is, the dams are by for the biggest "net" 

 in the river; operation of the hydrosystem must change if salmon restoration is to become a 

 reality. Therefore, NMFS must modify tiie Team's recommendations such that the first recovery 

 actions implemented are those actions which remedy the major factors cauang the decUne of the 

 stocks of concern. This is, in fact, the policy NMFS enundated for setting priorities in its own 

 recovery planning guidelines. 



In die event that more severe reductions in tiie tribes' treaty fineries are deared fay 

 NMFS to conserve listed Snake River stocks, tiiose reductions must not be sought witiiout prior 

 impleinentation of reductions for all non-treafy fisheries, as well as for otiier sources of 

 mortalify. Where conservation of a sfjedes is at issue, the legal standards described above raus^ 

 be met before a federal agency takes unilateral actions that affect the rights reserved by Indian 

 tribes. 



In short, the draft plan clearly does not provide for equitable distribution of the recovery 

 burden. Tie burden of lecoveiy must fall most heavily on the largest sources of salmon losses 

 as measured in adult eqravalents- AH otiier sources of salmon mortality must be addressed 

 bdfore any additional conservation burden is assessed against die tribes' tceaty-secured fisheries. 



Uie Draft Plan mischaracterizes the causes for decline of Snake Biver salmon stocks. 



The causes for decline of Snake River salmon stocks (and the impediments to salmon 

 recovery) are not dnave; fliey are well known. The cunent depleted status of Snake River 

 salmon stocks bears vdtness to flie giim efficiency of non-Indian domination of Colxmibia baan 

 anadromous fisheries and fcdr habitat Habitat destinction, appropriafion of water to non-fish 

 OSes, hydroelectric' power iiroduction and inadequate irritigation programs, are the prinaple 

 • causes for tiie dedirie of Snake River sahnon stocks. These same activities are also tfie prindple 

 impediments to--salmon recovery. 



