149 



Accurate idcndficadoa and description of the causes for dcdine is cti^<^ to 

 deteniunation of the conservation burden because those responablefor the decline m Snalce 

 River salmon should be accountable for restoring the resouroe. You can surely appreciate fte 

 tribes' sensitivity to this issue, given that the listed Snaloc River stocks (and indeed aU Columbia 

 Basin salmon nins) thrived for over 700 human generations under tribal management, .while tiie 

 near complete destruction of these stocks has occurred within a few generations imdcr non-Indian 

 managemenL Tribal fisheries and the economy and culture based on the fishery nsource have 

 suffered grievously due to the drastic reductions in productivity related to habitat loss and the 

 concomitant increase in salmon mortaUty caused by non-Indian development activities. 



The Draft Plan's reconunendations for delisfiiig criteria are inconsistent with.the Colombia 

 River tribes' treaty {ruling ligjits- 



Criteria for delisting Snake River salmon stocks must be conastent mth the oontinuadon 

 of treaty fisheries and inust not denigrate the value the tribes attach to their treaty fishmg nghb. 

 •Die federal government's duties under its treaties with the tribes extend b^ond &e neol to 

 merely ensure the viability of salmon stocks as requited by various federal laws. ^e^«^ 

 government has an obligation to. pro>ride for harvest adequate to meet tabal needs as 

 contemplated during treaty-making. The tribes did not reserve a right to take a few fish ftom 

 remnant runs hovering just above" some arbitrarily set numencal delisting catena. 



The Team's approacfa to establishing recovery goals and delisting criteria is prin^ly 

 poMcal rather than biologicaL The Team failed to review and incoipor^ agmficant 

 formation fiom the scientific literature on the development of recovery goals and nianagement 

 objectives for distinct population segments. Such rewewdiould have been ftefoundajonfor. 

 development of theTeam's lecommeadatioas. Instead, the Team accepted NMFS ^^^ 

 evolutionarily significant unit (ESU) concq)t, and then appUed the ESU concq)t in such a vra^y 

 that recovery of a healthy population structure' for the listed Snake River salmon may be 

 impossible. 



Theperformance goals recommended by theTeam for the various life stages also do not 

 reflect a feir^ocadon of the recovery burdeiu For instance, the draft plan recoimn«ids ttat 

 in-nverjuveoflesurvivalbe -improved.- whiiepassagethroughfisheaes^ manmizedLms 



is but one exanq)le of the tmfeir standard in the accountability between Jievanous aspects of 

 the life cycle and reflects an inequitable distributioa of the conseivatioQ braden- 



For spedes with complex life histories, " such as cfainook and sock^^ "^^^ 

 inq)rovemeats in survival rates for each major life history stage mu^ ^..f^f^^^t^ 

 Sd to develop an analytical tool incorporating aU aspects of the Me <=y^f f^^^ 

 inqjlemeatationofproposedactionstotfaeprobabiHtyof extinctioa. /ucb^^^f °^^ 

 dSdoping an ESA reoomy plan and for tracking the progress of vrater. land and fishery 

 managemeot actions toward meeting- recovery g<»ls. 



5 



