Incidental Take Permits for Shasta and Scott River Coho Salmon
The National Marine Fisheries Service (Weitkamp et al., 1995) found Coho salmon (Oncorhynchus kisutch) required protection under the federal Endangered Species Act (ESA), throughout their range in northwestern California and southern Oregon more than a decade ago. The California Department of Fish and Game (CDFG) eventually reached a similar conclusion and moved to list coho under California Endangered Species Act (CESA) statutes in 2003 (CDFG, 2002).
An Incidental Take Permit (ITP) is required by CESA by any party planning to engage in any land or water use that might cause harm to any species listed. On October 11, 2006 CDFG issued a Notice of Preparation (NOP) of a Draft Environmental Impact Statement (DEIS) for a Shasta and Scott River Watershed-Wide Coho Salmon Incidental Take Permitting Programs. CDFG’s ITP initiative and EIS are in response to draft applications by agricultural groups in both basins, which Work Group members found to be problematic in terms of approach and sufficiency (see comments below).
Coho salmon populations in both the Shasta and Scott River basins are clearly at high risk of extinction (NRC, 2004) and the quality of the ITPs will determine whether they continue their decline to extinction or begin recovery. Work Group members are also concerned about how CDFG will deal with flow issues in these basins, because TMDL studies indicate that water quality problems like temperature cannot be solved unless agricultural water diversion and ground water pumping is reduced.
Status: CDFG issued the final EIR for incidental take permit (ITP) for agricultural activities in the Shasta and Scott River basins for coho salmon under the California Endangered Species Act (CESA) on September 21, 2009. Member tribes of the Work Group have expressed strong reservations about both ITPs that are characterized in linked documents below. The local agricultural interest groups that would be ITP Permittees would be vested with enforcement authority for CDFG Codes, including Section 5937 that requires that flows be left in streams. Instead of improving enforcement to provide water for coho, CDFG will sanction these illegal practices going forward. Coho salmon are currently in “jeopardy” status under CESA guidelines in both the Shasta and Scott River basins and the actions taken under the ITPs are not sufficient to reverse their decline. Consequently, the ITPs do not meet CESA guidelines and should be opposed.
Shasta ITP Work Group Comments:
Quartz Valley Indian Community. 2006. Scoping Comments on Shasta River Basin Agricultural Coho Salmon Incidental Take Permit. Submitted to CDFG, Region 1 by QVIR. ITP filed with CDFG. 20 p
Quartz Valley Indian Community. 2008. Comments on Draft Shasta River Basin Agricultural Coho Salmon Incidental Take Permit. Submitted to CDFG, Region 1 by QVIR. ITP filed with CDFG. 13 p.
Scott ITP Work Group Comments:
Quartz Valley Indian Community. 2006. Scoping Comments on Scott River Basin Agricultural Coho Salmon Incidental Take Permit. Submitted to CDFG, Region 1 by QVIR. ITP filed with CDFG. 23 p
Quartz Valley Indian Community. 2008. Comments on Draft Scott River Basin Agricultural Coho Salmon Incidental Take Permit. Submitted to CDFG, Region 1 by QVIR. ITP filed with CDFG. 29 p.
Download Final Shasta and Scott ITP DEIR’s (very large! 35 Mb)
Final Scott River ITP Volume #1
Final Scott River ITP Volume #2
Final Shasta River ITP Volume #1
Final Shasta River ITP Volume #2
Shasta River Incidental Take Permit
Quartz Valley Indian Community (QVIC) ITP Scoping Comments on Shasta ITP filed with CDFG
- CDFG Initial Study does not mention removal or modification of Dwinnell Dam, which violates CDFG 5937, because it dewaters the river, and blocks passage to a huge amount of salmon spawning and rearing habitat;
- Does not address reconnection of tributaries like Parks Creek or the Little Shasta River through flow restoration;
- Does not reference Shasta TMDL or address water quality problems that are related to diminished flow; and
- The CDFG Initial Study considers validating flow levels that target coho only and could incidentally harm Chinook salmon and steelhead, if approved.
Scott River Incidental Take Permit
QVIC ITP Scoping Comments on Scott River ITP filed with CDFG
- The CDFG Initial Study fails to meet the stated CESA requirements for the use of best available science;
- It does not properly characterize the true risk of coho salmon extinction in the Scott River;
- It does not address excessive diversion of streamflow, over-extraction of groundwater and, therefore, flow-related water quality problems in the Scott River will not be resolved;
- There is no indication that CDFG will require unrestricted public data sharing, which is a requirement of science and necessary for public trust protection; and
- Actions taken under the SRCD Draft ITP and Initial Study focus only on coho salmon, which is not the only Pacific salmon species at risk in the Scott River basin nor the species of greatest economic importance.
References
California Department of Fish and Game. 2002. Status Review of California Coho Salmon North of San Francisco. Report to the California Fish and Game Commission. California Department of Fish and Game, Sacramento, CA. 336pp. At KRIS Web site.
California Department of Fish and Game. 2006. Scott River Watershed-Wide Permitting Program Environmental Check List and Initial Study. CDFG, Region 1, Redding, CA. 73 p.
California Department of Fish and Game. 2006b. Notice of Preparation of a Draft Environmental Impact Report: Scott River Watershed-Wide Permitting Program for Coho Salmon Incidental Take Permit (ITP). 10/19/06. CDFG, Region 1, Redding, CA. 11 p.
California Department of Fish and Game. 2006b. Shasta River Watershed-Wide Permitting Program Environmental Check List and Initial Study. CDFG, Region 1, Redding, CA. 77 p.
California Department of Fish and Game. 2006a. Notice of Preparation of a Draft Environmental Impact Report Shasta River Watershed-Wide Permitting Program. CDFG, Region 1, Redding, CA. 11 p.
California Department of Fish and Game. 2009. Chinook salmon reconnaissance survey on the Scott River, Memo of September 28, 2009 from Mark Hampton to Mark Pisano, CDFG, Yreka, CA. 4 p.
National Research Council (NRC). 2003. Endangered and threatened fishes in the Klamath River basin: causes of decline and strategies for recovery. Committee on endangered and threatened fishes in the Klamath River Basin, Board of Environmental Toxicology, Division on Earth and Life Studies, Washington D.C. Prepublication copy. 334 pp.
At KRIS Web site.
Shasta Valley Resource Conservation District. 2005. Master Incidental Take Permit (ITP) Application for Coho Salmon (Oncorhychus kisutch). March 29, 2005. Submitted to the California Department of Fish and Game. SVRCD, Yreka, CA.
Siskiyou Resource Conservation District. 2005. Draft Siskiyou Resource Conservation District Incidental Take Permit Application for Coho Salmon. Submitted to the California Department of Fish and Game Region 1 in March 2005. Siskiyou RCD, Etna, CA. Download zipped document with all the appendices.
Weitkamp, L. A., T. C. Wainwright, G. J. Bryant, G. B. Milner, D. J. Teel, R. G. Kope, and R. S. Waples. 1995. Status review of coho salmon from Washington, Oregon, and California. U.S. Dep. Commer., NOAA Tech. Memo. NMFS-NWFSC-24, 258 p. At KRIS Web site.
