247 



A. Question # 1: 



While Oregon Trout made many critical comments on the draft 

 recovery plan, we concluded that it was the first full life cycle 

 salmon plan and therefore we generally support it. The only 

 other life cycle plan is the Strategy For Salmon recently adopted 

 by the Power Planning Council, but the Council lacks authority to 

 implement its plan. The strengths of the Recovery Plan are: (a) 

 it provides a single authority and accountability in the National 

 Marine Fisheries Service (NMFS) for salmonid recovery coastwide; 



(b) it establishes a Scientific Oversight Committee so the 

 recovery measures are scientifically driven and evaluated; and 



(c) it sets sound delisting criteria. Without a recovery plan 

 the region will continue to perpetuate the problems that caused 

 the salmon to be listed. 



The weaknesses of the Recovery Plan are its reliance upon 

 technological intervention such as hatchery propagation and smolt 

 transportation. Based on our review of the scientific 

 literature, we view hatchery supplementation as an untested 

 theoretical experiment that should not be broadly applied until 

 evaluated. Any funding should be directed at evaluation of this 

 experimental design and aimed at risk containment. Further, 

 transportation can only be one of the tools used to aid in 

 juvenile migration; it must be used in combination with spill, 

 flow and other methods. 



Another major weakness is that the Recovery Plan does not 

 establish an institutional mechanism or commitment that is 

 specific to the recovery of natural stocks. This is evident from 

 the absence of a natural production strategy in the Recovery 

 Plan. We also believe the NMFS is unable, under present funding 

 and staffing, to effectively execute the Recovery Plan. We also 

 believe that NMFS has been a participant in west coast salmon 

 decline and therefore currently lacks the vision that will carry 

 it beyond the status quo. Finally, NMFS cannot, by itself, 

 recover the salmon without the institutional commitment of other 

 federal and state agencies to solve the salmon habitat problems. 



