MFS late season cancellations solution - Page 2 - Mountain Buzz
 



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Old 07-28-2016   #11
 
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FYI - these are not some musings of a disenchanted boater, I happen to study these things for a living and have been a fish biologist working in the PNW for more than 20 years now and also happen to specialize in ESA regulation as well as technical scientific assessment of salmon, steelhead, and trout population limiting factors related to all manner of human disturbance, from hydropower and flow regulation to recreational and commercial fisheries, and hatchery programs. I work on all sides of the fence and have seen it all from all angles, I work as a consultant for tribes, land conservation non-profits, hydropower utilities, state and federal agencies. I did pure research for many years as well. I don't pick sides, I pick scientifically based and rational viewpoints. I am not a sheep, I think critically based on objective data. If I thought boaters were causing a problem, I would have no hesitation in saying so and doing away with all the boater permits entirely. However, there is nothing pointing the the need for any limitation of the current permit system with respect to additional protection of Chinook spawning.

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Old 07-28-2016   #12
 
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I don't have first hand information to back this up but . . .

I was told that there are fish/conservation/anti-boating groups that actively apply for permits in that period just so that they can cancel them with basically no penalty.

I think MFS permits (and basically all permit systems) should be like GC permits where there's a significant deposit required up front. We wouldn't be so worried about cancellations if the permit required a $400 deposit right off the bat. And we also wouldn't be so capricious in our willingness to pick up a permit, knowing that we can cancel it later at the cost of a $6 non-refundable fee.

Sounded a bit conspiratorial to me, but also sounded believable.
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Old 07-29-2016   #13
 
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Quote:
Originally Posted by zbaird View Post
Sounds reasonable to me.

I'd pitch $50 to a go fund me set up by shap to fund a lawsuit to get this reversed.
Me too! Doesn't have to be a law suit. thou...

I think climbdenail has a good idea too.

Quote:
Originally Posted by climbdenali View Post

I think MFS permits (and basically all permit systems) should be like GC permits where there's a significant deposit required up front. We wouldn't be so worried about cancellations if the permit required a $400 deposit right off the bat. And we also wouldn't be so capricious in our willingness to pick up a permit, knowing that we can cancel it later at the cost of a $6 non-refundable fee.
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Old 07-29-2016   #14
 
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It does have to be a lawsuit, the USFS/NMFS are trying to limit boaters Aug 15-Sept 15 based on poor and unfounded speculation on potential impacts to very few Chinook spawners. Changing the fee structure to ensure the maximum number of folks don't cancel and actually use there permits will be rejected because it is counter to their stated objective.

I would think a successful lawsuit would could actually cost well in excess of $100,000. Thats a lot of $20 donations.
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Old 07-29-2016   #15
 
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Has anyone ever done a FOIA request for documents about the decision, process and policy?
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Old 07-29-2016   #16
 
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Originally Posted by restrac2000 View Post
Has anyone ever done a FOIA request for documents about the decision, process and policy?
Not necessary, The policy is the ESA, federal agencies must consult with either NMFS or USFWS (base don the species of concern) to ensure that actions directly taken, permitted, or funded do jeopordize the continued existence a ESA listed fish species or destroy or adversely modify any designated critical habitat for the species.

This is done through ESA Section 7 consultation. In this case the USFS implements/adminsters the MF Salmon permit system. Every so often they have to re-consult with the NMFS to ensure that implementation of this program does not jeopordize the continued existence of the listed Chinook unit. IN this case the listed Chinook unit covers a huge area. not just Chinook in the Middle Fork. The ultimate decision is weather or not letting folks float down the MF Salmon river under the permit system jeopordizes the continued existence of Chinook salmon in the Snake River Spring Chinook Evolutionary Significant Unit (ESU). This ESU inincludes naturally spawned spring/summer-run Chinook salmon originating from the mainstem Snake River and the Tucannon River, Grande Ronde River, Imnaha River, and Salmon River subbasins. It also includes spring/summer-run Chinook salmon from 11 artificial propagation programs.

So when the NMFS/USFS analyze effects they should not only analyze what effects floaters have by potentially disturbing on average 1% of Chinook that may spawn in the MF Salmon River basin, but place that into the context of what that effect is in relation to the long term existance or risk to the entire ESU.

The way this process works is that the USFS drafts a biological assessment where they lay out the program and analyze potential effects. Where effects may occur, they typically develop measures to minimize or avoid negative effects. They submit the document to NMFS. If NMFS concurs they have essentially minimized those effects and are not likely to adversely affect the species, then they just write a letter concuring with the USFS. If they think that there are some actual effects then they write a document called a biological opinion. Where they lay out measures to minimize/avoid impacts, they can also include an icidental take statement for minor effects to listed species, such as floating past a few spawners with some level of potential disturbance to an small part of the population that inhabits the MF Salmon and a very very small proportion of the entire ESU, if they believe that such harassment or any potential minor mortality will not jeoprodize the continued existence of the entire listed ESU. Does anyone think that floating past 1% of the redds with some level of small potential for actual disturbance would jeopordize the continued existence of the entire Snake River spring Chinook ESU or even the spring Chinook population that inhabits the MF Salmon sub basin?

In this case, the USFS threw up a bunch of speculative measures to ensure that NMFS would concur with their assessment that the permit system is not likely to adversley affect the Snake River Spring Chinook Salmon ESU. And NMFS concurred. The question is, would NMFS not have concurred with a "not likely to advesely affect" determination by the USFS if they had left out the Aug 15 to Sept 15 no -reissuance of canceled permits rule? IF not, all NMFS would have had to do was write a Biological Opinion instead of a concurrence letter and allow some minimal level of take in the form of potential harassment by floaters that on average may pass by 1% of spawners in the MF Salmon sub basin or less than 0.1% of spawners as a proportion of the Snake Rive Spring Chinook ESU, the level at which the jeopordy determination is made.
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Old 07-29-2016   #17
 
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Got to get the facts straight. I typed the above on the process without refreshing my memory first of the process, I just looked back in the folder I have on the subject. NMFS did produce a biological opinion including the permit cancelation measure. The biological opinion is here for all to read (attached):


And latest summary of Chinook info from the MF Salmon:
https://pisces.bpa.gov/release/docum...px?doc=P138723


NMFS did include incidental take in the form of harassment of spawners by floaters passing by up to 34 redds per year in the MF salmon floater permit area, and concluded that this form of harassment would not cause increased mortality. So it boggles the mind why the Aug 15 to Sept 15 rule is necessary.
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Old 07-29-2016   #18
 
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Long term average of the number of redds in the mainstem MF Salmon is way way less than 34 total, again on average 99% spawn upstream of boundary creek or in the tribs.


On another note, this consultation and rules associated with it expire in 2020. At that time we need to make some serious noise with data analysis to back it up to the forest supervisor.
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Old 07-29-2016   #19
 
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After my donation we only need 4997 $20 donations and one cheapass to give $10.

How many people put in for the middlefork each year? How many of us give away at least a $20 in permit apps to idaho each year for nothing and never look back? It cant be that hard to raise the 100k. Like I said, start it up, if it doesnt work give it to AW or we can keep it for another worthy cause down the road.
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Old 07-29-2016   #20
 
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If you read the biological opinion, attached above you will see that there is not any discussion or analysis of the need or benefit of the Aug 15 to Sept 15 permit cancellation rule. If there is no discussion or analysis of it, how did they determine it was needed?


There is a lot of analysis in the Biological Opinon on the potential effects of floaters passing by redds and the ultimate conclusion was:


"A small number of adult Chinook salmon will be disturbed from floatboat activities, and the total effect of this disturbance on the extended population is expected to be very small."


The small level of harassment was authorized by the incidental take statement. The biological opinion itself essentially argues that the Aug 15 to Sept 15 cancellation policy is unnecessary.




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