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
Comment from Lauren Goldberg
This is comment on Proposed Rule
Endangered and Threatened Wildlife and Plants: Proposed Threatened Status for Southern Distinct Population Segment of Eulachon
View Comment
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