Executive Sunmary
This document summarizes my serious concern about any harvest of Sacramento River Fall Run Chinooks in 2010 based on the Sacramento Index Forecast of 245,483 salmon returning to the Sacramento River system. With a river of this ecological significance on the brink of disaster we must be conservative in the decisions that we make. A wrong move at this time may cause returns to drop below minimum sustainable levels.

There are several factors leading me to the above statements; 1) Actual results from last year’s adult returns showed the predictive model to over-predict the run size in the Sacramento by a factor of more than 3. 2) The anomalous return of jacks to the Feather River Hatchery artificially inflates the prediction for Chinook returns. 3) Lack of historical precedent for a factor of three times year over year increase as proposed for 2010 in salmon population to just meet minimum escapement goals is cause for serious concern about making escapement this year.

In the presence of the above stated facts it would be both reckless and potentially devastating to Sacramento River Fall Chinooks to allow any ocean, main stem or upper Sacramento River harvest. To allow a harvest would be to "Manage by Miracles” and, we all know the results of that management style.

While you might expect a person who would gain financially from a 2010 harvest to be overjoyed with this forecast, I am not. Unfortunately, I am doubly cursed with a PhD in Chemistry and 25 years of experience managing Silicon Valley companies. Numbers mean something to me and my business experience has taught me that past poor performance is, unfortunately, a good indicator of future results. When we have developed a model capable of predicting run size within a percentage of reality only then can we rely on it to guide the decisions for a river that hangs on the brink of extinction.

The following forms the detailed basis of my lack of scientific confidence in the predictive model and decisions made from it:

Dysfunctional Model
While there is some correlation between salmon abundance and previous year’s jack return on the Sacramento, the correlation is tenuous at best. For proof, we need only look at the 2009 Salmon abundance prediction of 122,100 salmon and an actual return of 39,800. More simply, for every 3 salmon that the model predicted, less than 1 salmon actually materialized. The 2009 prediction was not an isolated incident. One need only look at the 2005, 2001 and 1998 predictions to see that the model can fail to predict actual returns by hundreds of thousands of fish. If the current prediction is off by the same amount as it was in 2009, we would see less than 82,000 Fall Chinooks – a number far below escapement goals.

Distribution of Jacks Used in the Model
If one were to make the highly optimistic assumption that PFMC has a functional model that would indeed predict 2010 Sacramento Fall Chinook abundance, there is another problem with the data that feeds the model. Jack distribution was strongly skewed toward the Feather River and in particular the Feather River Hatchery. Of the 9,216 jacks counted on the Sacramento, 4,620 were Feather River jacks while only 2,233 were Upper Sacramento jacks. This is important because the Upper Sacramento has historically produced more ocean caught salmon than any other California river sub-system. In the past the Upper Sacramento produced 3 – 5 times the number of salmon produced by the Feather.

Digging a little deeper into the numbers, we find that the 3,723 jacks that returned to the Feather River Hatchery was quite an anomaly. Refer to Table B-2 on page 194 of the Feb 2010 version of the Review of 2009 Ocean Salmon Fishery and you will see that over the past 40 years, only once, in 2004, did the Feather River receive more jacks than in 2009. Even in years preceding good salmon returns, the average number of jacks returning to the Feather River Hatchery was 1/3 – ½ of the 2009 return. In the midst of the Central Valley salmon collapse, doesn’t anyone find it odd that the Feather River Hatchery has a near record return of jacks while the Coleman and Nimbus received very low returns of jacks?

I suspect that there was an anomaly in hatchery operations, timing of release of the 2007 juvenile salmon from the Feather Hatchery or these smolt finding a particularly rich food source upon outmigration that was not found by their Upper Sacramento and American cousins that led to such a high hatchery jack return. Inclusion of these jacks in the model is highly suspect at best. If one were to rightly assume that the Feather jack return is an anomaly and take the median of the 1971 – 2008 jack returns (1,370) as a more reasonable, but probably still high estimate for modeling 2010 returns, you would have to subtract 2,353 jacks from the Sacramento River Index model which would lower the number of jacks used in the model from 9,216 to 6,863. Plugging this number back into the model, you would project a Sacramento Index of 182,809 adult salmon, barely making the upper escapement goal range.

The skewed distribution of jacks toward the Feather and particularly the Feather River Hatchery is important because the Upper Sacramento run of Fall Chinooks is still depleted. Since the Upper Sacramento ecosystem has historically produced the lion’s share of California ocean caught salmon, we need to rebuild this run if we are to see strong ocean runs in the future. Any ocean season targeting Sacramento River Fall Run Chinooks will significantly harm these fish and at best delay recovery of the Upper Sacramento stocks.

There is No Historical Precedence for the Sacramento Making Minimum Escapement in 2010
Looking beyond the model, one needs to apply a little common sense when making harvest decisions. For natural systems, historical precedence is a good place to start. With the hand of man involved, we can see record setting declines in fish populations but rarely record setting population increases. When the rare population increases do occur, there is normally some very visible, heroic effort involved.

With just 39,800 salmon in 2009, for the current prediction of 245,483 Fall Run Chinooks in 2010 to be accurate, we would need see a 6 times increase in salmon abundance over 2009. This has never happened and most certainly won’t this year. We need to then look at what increase over the 2009 return that we need to just make escapement:

Lower End of Escapement – To meet the lower end goal of 122,000 salmon for 2010, we would need to see a year over year increase of a factor of 3. Has this ever happened? Not really. 1995 saw an increase in the Sacramento Index of approx. 2.2 over 1994. Unfortunately that was an anomaly with most year over year increases measured in percent rather than factors of 2 or 3. In other words with only 39,800 fall Chinooks in 2009, there is no historical precedence that should make us feel comfortable that we could possibly make even minimum escapement in 2010.

Given all of the above, I would urge the council to manage by fact rather than manage by miracles and to allow no salmon harvest targeting Sacramento River Fall Chinook in 2010.