Comment from Lauren Goldberg

Document ID: NOAA-NMFS-2009-0074-0005
Document Type: Public Submission
Agency: National Oceanic And Atmospheric Administration
Received Date: May 12 2009, at 05:17 PM Eastern Daylight Time
Date Posted: May 12 2009, at 12:00 AM Eastern Standard Time
Comment Start Date: March 13 2009, at 12:00 AM Eastern Standard Time
Comment Due Date: May 12 2009, at 11:59 PM Eastern Standard Time
Tracking Number: 8098bdb3
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May 12, 2009 Via Electronic Mail RE: Listing of southern distinct population segment (DPS) of Eulachon under the Endangered Species Act (ESA). Dear NOAA Fisheries Service Representative, Columbia Riverkeeper submits these comments in support of the proposed listing of the southern distinct population segment (DPS) of Eulachon (Columbia River Smelt) under the Endangered Species Act (ESA). Columbia Riverkeeper (“CRK”) is a non-profit organization with a mission of protecting and restoring the water quality of the Columbia River and all life connected to it. CRK works throughout the Colubmia River basin to improve protect and improve habitat and water quality. Many of CRK’s members, and all of CRK’s staff, reside in the Columbia River Basin. Members of CRK participate in recreational activities in and along the Columbia River, including fishing and observing wildlife. CRK values the rich biodiversity of the basin and advocates for meaningful environmental protections that protect and enhance the region's biodiversity. NOAA’s fisheries (NOAA) has identified eulachon population between the Skeena River in British Columbia, Canada to the Mad River in California as a distinct population segment, termed the southern DPS. NOAA has determined that the southern DPS eulachon is likely to become endangered within the foreseeable future. CRK supports NOAA’s proposal to list the southern DPS under the ESA because CRK values the eulachon as an essential element of the Columbia River ecosystem and a species of important cultural significance to some of CRK’s members. The Columbia River is a major production area for the southern DPS of Eulachon, providing essential habitat for a “core population” of the fish. The Columbia River and its tributaries support one of the largest eulachon runs in the world. Eulachon that hatch in the Columbia River Basin waters spend two to five years in marine waters before returning to spawn. The small fish are rich in calories and are an important part of both marine and freshwater food webs. Eulachon are a food source for marine mammals, salmon, sturgeon, numerous bird species, and humans. Eulachon populations have been declining for decades. Threats to the eulachon in the Columbia River Basin include hydroelectric dams, industrial development, pollution, and shoreline modifications. CRK and its members are very concerned about the decline and possible extinction of the southern DPS of eulachon. CRK believes that federal actions stemming from the proposed listing under the ESA of the southern DPS of eulachon are essential for the protection of this species and its habitat. Therefore, CRK strongly supports NOAA’s action in listing the southern DPS of eulachon under the ESA. CRK respectfully submits these comments regarding the proposed listing of eulachon. CRK greatly appreciates the assistance of NOAA’s Fisheries staff in the public commenting process. Columbia Riverkeeper recognizes that NOAA’s staff exerts a significant amount of time, thought and effort in listing a species under the ESA. Thank you in advance for considering these comments. If you have any questions, please contact me at 541-965-0985. Regards, /s/ Lauren Goldberg Lauren Goldberg Staff Attorney Columbia Riverkeeper 724 Oak St. Hood River, OR 97031 lauren@columbiariverkeeper.org

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