> Northwest Fisheries Science Center
>
> 2725 Montlake Boulevard East
>
> Seattle, WA 98112-2097
>
> February 20, 2003

Dear Co-manager,

I would like to ask your help in reviewing an important technical work
product related to salmon conservation and management.

As you know, about a year ago the National Marine Fisheries Service
(NMFS) committed to a systematic updating of the Endangered Species Act
(ESA) status of all listed Evolutionarily Significant Units (ESUs) of
Pacific salmon and steelhead. This decision was influenced by several
considerations. First, a September 2001 ruling in a lawsuit involving
Oregon Coast coho salmon concluded that NMFS had violated the provisions
of the ESA by listing only part of an ESU (i.e., NMFS had included
hatchery populations in the ESU but not listed them). Although this
legal case applied directly only to Oregon Coast coho salmon, the same
factual situation (hatchery populations considered part of listed ESUs
but not listed) also applied to most of the other listed ESUs of salmon
and steelhead. Second, another lawsuit currently pending that involves
the Southern California ESU of steelhead raised a similar issue---NMFS
concluded that resident fish were part of the steelhead ESUs but they
were not listed. Again, this same factual situation is found in most, if
not all, listed steelhead ESUs. Finally, at least several years of new
data are available even for the most recently listed ESUs, and up to a
decade has passed since the first populations were listed in the
Sacramento and Snake Rivers. Furthermore, in some areas, adult returns
in the last few years have been considerably higher than have been seen
for several decades. Collectively, these factors indicated that it was
time to update the status of listed ESUs of West Coast salmon and
steelhead, in a uniform way and based on the most current information.

For the past year, NMFS scientists have been working with state, tribal,
and other federal biologists to develop the updated information
necessary to re-evaluate the status of each listed ESU. To maximize
efficiency and accuracy and avoid unnecessary duplication of effort, as
much as possible the compilation of these datasets has been done through
the Technical Recovery Teams (TRTs) established to provide the
scientific basis for ESA recovery planning for salmon and steelhead. The
TRTs have broad representation from state, tribal, federal, academic,
and independent scientists, and we appreciate the work your staff has
already contributed to this extensive effort.

Recently, the NMFS Biological Review Team (BRT) met to review this
updated information and analyses and to draw preliminary conclusions
about the status of each listed ESU. The results of that review are
included in the enclosed draft report. **\[The entire report will also
be available soon online at http://www.nwfsc.noaa.gov/\]** I would like
to ask the help of you and your staff in ensuring that the report is as
accurate and complete as possible. Specific questions regarding which we
would appreciate your comments include the following: Are the data
complete and up-to-date? If not, can you provide more recent or complete
data? Are the preliminary BRT conclusions reasonable, given the
information and analyses presented?

The draft BRT conclusions in this report should be considered
preliminary for two reasons. First, the BRT will not finalize its
conclusions until comanagers have had a chance to review and comment on
the draft report. Written comments provided by the comanagers as part of
this review process will be considered by the BRT in their subsequent
evaluations. Second, as discussed in the main body of the report, some
policy issues regarding the treatment of hatchery fish and resident fish
in ESU determinations and risk analyses are not resolved at this time.
If subsequent policy decisions substantially change the working
framework used by the BRT in this report, the BRT conclusions could
change as well.

In addition, it is important to recognize that, even in its final form,
the BRT report will not provide recommendations regarding listing
determinations for these ESUs. Instead, as in the past, the BRT report
will present conclusions of the team regarding the degree of risk faced
by each ESU, based on the best available scientific information. By
statute, ESA listing determinations also must take into consideration
those efforts being made to protect the species. After receiving the
final BRT report and after considering the conservation benefits of such
efforts, NMFS will determine what changes, if any, to propose to the
listing status of the affected ESUs.

As before, we will try to arrange for face-to-face meetings of BRT
members and comanager biologists to discuss technical issues before the
BRT meets again to finalize its conclusions. With 27 ESUs of 5 species
spread across 4 states involved in these deliberations, arranging such
meetings on a tight time frame will present some serious logistical
challenges, but they should be feasible if they can be focused on those
ESUs and species for which substantial issues arise. Please contact
Robin Waples ([robin.waples@noaa.gov](mailto:robin.Waples@noaa.gov)) if
you have questions or want to discuss such a meeting.

To allow time for full consideration by the BRT, we will need to receive
any written comments on the draft by **20 March.** I appreciate that
this is a great deal of material to review in a relatively short time,
but this time frame is necessary to allow the agency to meet legal
deadlines associated with the updated status reviews.

Thanks very much in advance for your assistance in this important
effort.

Sincerely,

> ![](media/image1.jpeg){width="1.5569444444444445in"
> height="0.4736111111111111in"}
>
> Usha Varanasi, Ph.D.
>
> Science and Research Director