11 



prepared by the Alaska Department of Fish and Game as a formal comment on the 

 relisting proposal — and as anyone who looks at the record of that agency will under- 

 stand, the Alaska Department of Fish and Game knows something about scientific 

 management of salmon. Alaska's harvests of Pacific salmon have hit new highs dur- 

 ing 10 out of the last 14 years, with last year's catch reaching an all-time record 

 of 197 million fish. While these phenomenal returns owe something to favorable nat- 

 ural conditions, they are also indicative of well-planned, well-carried-out manage- 

 ment. 



I will summarize the Department's findings in a moment, but first let me inject 

 a very important note of caution, lest my comments be taken out of context by mem- 

 bers of the environmental community or the media. It should be clearly understood 

 by all that I recognize the deeply depressed status of many Columbia and Snake 

 River salmon stocks. I am not arguing against the Endangered Species Act, or 

 against efforts to help the salmon of these rivers regain their historic abundance. 

 In fact, as an Alaskan I understand very well the importance of these stocks, includ- 

 ing the fact that healthier stocks in the Columbia and Snake rivers mean healthier 

 fisneries in Alaska as well as the Northwest, healthier economy and fewer burdens 

 on electricity rate-payers and other river users, and a healthier relationship with 

 our Canadian partners in the Pacific Salmon Treaty. As an Alaskan, therefore, I 

 WANT more fish in the Columbia and Snake rivers. 



Sound science is the key. But I submit, Mr. Chairman, that sound science is NOT 

 being used in the relisting of the Snake River fall chinook salmon, and that failure 

 not only affects your Pacific Northwest ratepayers, but also calls into question the 

 science used elsewhere in the Columbia and Snake system. 



Now, Mr. Chairman, allow me to summarize the details: 



The effort to list Snake River fall chinook began in 1990. In 1992, after careful 

 scientific review and ample public comment, the National Marine Fisheries Service 

 listed the stock as "threatened." In 1994, the agency took emergency steps to tempo- 

 rarily classic the stock as "endangered," and it is now proposing to make the latter 

 action permanent. 



These classifications hinge not on the numbers of individual creatures, as many 

 think, but on the likelihood of a stock becoming extinct within a particular time 

 frame. In this case, the number of wild fish returning to the river has increased sub- 

 stantially since 1990, and the likelihood of extinction within 100 years has fallen 

 dramatically. 



In 1992, the National Marine Fisheries Service strengthened its choice of "threat- 

 ened" status by noting that the 1991 count of 318 adult fish passing Lower Granite 

 dam was a "considerable increase" over the 78 fish level which existed when the list- 

 ing discussion began in 1990. And today, we can look back and see that the number 

 of returning adults continued to increase— 549 in 1992 and 742 in 1993. The 1994 

 return was 441 fish, still the sixth highest return since 1980. Furthermore, the av- 

 erage number of fish returning is also increasing: from 377 during the period 1980- 

 90, to 512 fish in 1990-94. 



Mr. Chairman, these statistics are GOOD news, not bad. Yes, Snake River fall 

 chinook are still in trouble. But things are not getting worse, they are getting bet- 

 ter. What has changed for the worse is the agency's attitude. Where in 1992 it made 

 a rational decision based on observed data, it is now relying on unfounded specula- 

 tion that things will get worse despite the facts. That, Mr. Chairman, is NOT good 

 science. 



Finally, let me touch on one other area with respect to these fish. The Endangered 

 Species Act is intended to preserve species, subspecies and distinct populations, on 

 the theory that they may have some unique value either ecologically, or in the case 

 of subspecies and distinct populations, as a source of genetic material which would 

 otherwise be lost to the species as a whole. Stocks such as the Snake River fall chi- 

 nook are treated as subspecies. 



For the purposes of the Endangered Species Act, however, the agency separates 

 Snake River fall chinook into two groups: fish which make it past Lower Granite 

 dam to spawn naturally in the river, and fish associated with the Lyons Ferry 

 hatchery, for which the most genetically "pure" fish were collected and removed 

 from the spawning population well below Lower Granite dam. Only the fish spawn- 

 ing above Lower Granite are given Endangered Species Act protection. 



First of all, if both groups were counted toward Endangered Species Act goals, it 

 is evident that the numbers of "Snake River fall chinook" would be considerably 

 higher than the agency now insists. However, we have already seen that the agency 

 is no stranger to manipulating numbers. 



More important questions are raised by the fact that the fish allowed to spawn 

 naturally have also been most heavily infiltrated by strays from elsewhere in the 

 river system. 



