18 



as best available scientific data), but was instead ranked number 11 of 

 20 since 197S (when Lower Granite Dam was installed), and ranlced number 

 6 of 15 since 1980 (the first year for which the majority of the adults 

 had to circumvent all four lower river dams during their juvenile 

 downstream migration). Given the currently restricted spawning and 

 rearing habitat, the 1994 escapement of wild fall chinook was within the 

 range of escapements expected it hardly approached a record low level as 

 stated in the December 28, 1994 Federal Register. 



Further, the record low count in 1993 of 39 jaclcs which was used as a 

 rational in the December 28, 1994, Federal Register to predict a low run 

 of adults in 1994 and a continued low run of adults in 1995, hardly 

 resulted in a dismal return of adults in 1994. In fact the second 

 lowest count of jac)cs passing Lower Granite Dam (102 jacks) occurred in 

 1992 and was followed one. year later with an adult return of 742 fish 

 (the highest count since 1980; rank 1 of 15) and an adult return two 

 years later of 441 fish (the sixth highest count since 1980; rank 6 of 

 15). 



Thus, the basic question as to whether status of Snake River fall 

 Chinook has changed since 1990 and whether or not this change justifies 

 a change in the listing status has not been adequately substantiated by 

 the information presented in the December 28, 1994, Federal Register. 

 NMFS in announcing its decision to reclassify Snake River fall Chinook 

 from threatened to endangered failed to use the best available 

 scientific and commercial data. Further, NMFS has substantially changed 

 their characterization of the value of escapement increases since 1990 

 in an arbitrary and capricious manner. To properly address the change 

 in listing status question, an objective analysis is required. 



INFORMATION NEEDED TO DETERMINE 



THE NEED FOR A CHANGE IN THE LISTING OF SNAKE RIVER 



FALL CHINOOK 



Several analyses necessary to make a biologically sound determination 

 concerning the need to reclassify the Snake River fall chinook from 

 threatened to endangered were absent from the December 28, 1994 Federal 

 Register announcement. The following factors should be analyzed prior 

 to any change in the listing of the Snake River fall chinook. 



Escapement 



An objective analysis should include the basic data concerning 

 escapenckents of fall chinook through 1994. The basic data presented 

 should include estimates of both "natural' fish and strays in the 

 escapements. And to the extent possible, hatchery production should be 

 separated from 'natural' production so that trends in the "natural' 

 population can be more fully evaluated. Because of the way the 

 evolutionartly significant unit (ESU) is currently defined, the key 

 question is whether or not "natural' escapements have increased over 

 levels prior to listing. A change in status to the more conservative 

 endangered level of ESA listing would be in order if natural escapements 

 decreased relative to pre-listing levels. 



Likelihood of Extinction 



An objective analysis should compare the status and risk of extinction 

 for fall chinook through 1990 to the status and risk of extinction for 

 extinction based upon time series ending in 1990 versus time series 

 ending in 1994 will indicate whether the likelihood of extinction has: 



• decreased, indicating a change in status is not warranted; 



• stayed the same, indicating a change in status is probably not 

 warranted; or, 



• increased, indicating a change in status is warranted. 



