# MFS late season cancellations solution



## dirtbagkayaker (Oct 29, 2008)

Over the years its plagued me and many others about ppl who cancel MFS permits from 8/15 to end of lottery season. 

fdon posted in another thread;

_"I have written to the FS asking them to consider re-issuing the cancelled permit to a 4-5 boat max trip just to keep that month open to at least a few private boaters. That concept fell onto deaf ears. *Perhaps if more buzz folk would speak up the FS might listen?* Just an idea."_


lets do this! 

How do we unite on a goal, draft it, and be heard?

Can anyone help a guy out here?


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## shappattack (Jul 17, 2008)

I have written on various forums extensively on this subject and sent a detailed analysis to the USFS (as a fish biologist) arguing that this management strategy (i.e. not issuing cancelations from Aug 15 to Sept 15) to protect endangered species act listed Chinook spawning is arbitrary and capricious under the ESA rules and that any potential effects are also biologically meaningless and insignificant. So far I got a thank you for your comments response. The only way to eliminate this rule is by a lawsuit on the grounds it is an arbitrary and capricious rule. Under the ESA the USFS as management agency does not have to consider public input to implement this rule. It was implemented with nothing to back it up, totally speculative, it was part of a scatter blast of actions thrown up in when the USFS consulted with NMFS on the MF Salmon permit issuance program as a way to minimize/avoid effects on Chinook. They implemented several actions that do nothing to address the real issues with this ESA listed stock, but instead penalize the few that want to float this river at low flows. We floated it last year at 1.45 feet. There is very little if any potential Chinook spawning habitat from Boundary all the way downstream, which is why 99% of the Chinook spawn in the tribs or upstream of Boundary where the spawning habitat is actually at. In addition, places where we briefly hung up were in shallow boulder gardens, not on gravel beds and pool tailouts where Chinook like to spawn. Don't get me started!


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## dirtbagkayaker (Oct 29, 2008)

shappattack said:


> The only way to eliminate this rule is by a lawsuit on the grounds it is an arbitrary and capricious rule.


OK, so is this doable? do you believe with a mountain of $$ and good attorneys it could be done? Or would it be like getting dog shit to stick on Hillary's shoe? Just not happening.

What about some sort of education? Or loss of future application status? Could we append a rule that states if you cancel after the march date you lose out the next 3 years???

maybe a second late season lottery where the forest service could make another $6 per person in mid July??

There just has to be something.


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## shappattack (Jul 17, 2008)

If you had $$ and good lawyers I guarantee a lawsuit based on arbitrary and capricious would prevail for the protection of Chinook spawning argument. However, there is no one that will sue. The rule is not affecting the outfitters, privates can't band together to do such a thing.


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## restrac2000 (Mar 6, 2008)

What is your support to the statement that the policy is "biologically meaningless and insignificant"? The veracity of that claim leaves me curious.


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## shappattack (Jul 17, 2008)

Search Idaho whitewater yahoo forum or here for long explanation, the short version is that IDFG (and their agency predecessor) have collected data on Chinook spawner distribution in the MF salmon sub basin for many decades. There is data back to the 1960s. On average about 1% of Chinook that return to the MF sub basin spawn in the mainstem MF proper. The rest spawn in tributaries or upstream of boudary in the headwater reaches. 

The reason is likely 2 fold, fist the tribs and headwaters is where the spawning gravel is. Second, there is limited gravel in the mainstem MF Salmon. In general the masinstem MF is steep and confined by a steep v-shapped valley. Not a conducive spot for spawning gravel beds to accumulate. Where there is limited gravel in the mainstem, there is likely high bedload transport and scour going on due to the steep gardient, high seasonal flows such as rain on snow during pineapple express events etc, confinement and regular tributary blow-outs that occur. 

So even if a chinook spawns in the mainstem, there is significant chance that they don't survive. Hence the reason only a small proportion normally spawn in the mainstem. Mainstem spawning is selected against by the forces listed above. These are fish that are likely "strays" not fish that are homing exactly to where they were spawned. A certain percentage of returning adults will just spawn in sporadic locations with appropriate gravel. This doesn't mean that the eggs will hatch and be successful. I would imaging just based on the physical nature of the mainstem gravel patches, that egg to fry recruitment/survival on the low side. Even if boats flat out killed every single redd in the mainstem, it would not result in a measurable biological response given all the other mortality factors that exert real biological consraint on the population, which include downstream survival of juveniles at each dam, estuary survival, ocean survival, incidental and direct mortality from commercial and recreational fisheries, predation of adults at fish ladders by seals on their way backupstream, etc. etc, unnatturaly high predation by colonary birds that are at natural high abundance at the mouth of the columbia due to islands of dredge material built up by the Army Corps to maintain navigation channels.

Even before boaters were present, most spawners did not spawn in the mainstem MF so it isn't that we are scaring them away from prime habitat. Take a look at some other rivers with huge boat traffic in Alaska, still an order of magnitude more Chinook with tourists tromping all over the redds all day long. There is also no research that shows that walking, parking a boat, scaring a fish off a redd by floating by, or the like has any measurable decrease in egg to fry survival, though I am not suggesting this is a good idea. Chinook burry their eggs deep, and they get subject to a huge amount of force during high water naturally. Again the proportion of the population even subject to potential impact by boaters is small. The yearly return of Chinook has varied widely from year to year, yet the number of boats on the MF Salmon has remained essentially unchanged for decades. 

The other large forces mentioned above account for the annual variability in returning adults. But the USFS has no control over the big stuff, some desk biologists at NMFS and USFS came up with a host of stuff so they could put something in the Biological Opinion to show that the permit system on the MF Salmon is compliant with the ESA and minimizing "take" i.e harassment, morality etc. of listed Chinook. Yet even harassment or direct mortality is permissible under the ESA. All they have to do is have an incidental take statement added to the biological opinion. Hydroprojects get incidental take statements all the time to kill 1% of listed fish that may encounter their projects. How can a hydroproject get an incidental take statement to allow 1% mortality of fish, yet the MF Salmon permit system can't even allow floaters to pass by 1% of spawners where no-direct moratality is even being argued?

1 fish biologists rational thoughts


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## shappattack (Jul 17, 2008)

To the arbitrary and capricious nature of the rule to not re-issue permits to private groups that cancel between Aug 15 to Sept 15. 

Under the ESA, reasonable and prudent measures or measures to minimize/avoid "take" of listed fish (i.e. to hunt, peruse, found, shoot, trap, kill, harass) must be reasonably certain to occur, not be speculative, and not subject to voluntary action outside of the agencies control. In this case, there is no way to predict how many boaters/trips will occur for sure from year to year as it is based on voluntary permit cancelation. This means that if no permits were canceled in any given year, the maximum number of folks could still go down the river legally. The rule in no way limits the number of boats by any certain or predictable amount. How can this be possible if the USFS and NMFS have determined that fewer boaters are necessary from Aug 15 to Sept 15 to reduce impacts on spawning Chinook? If they or you really believe that less boat traffic is needed to protect Chinook spawning from Aug 15 to Sept 15, then they should identify a maximum allowable number of boaters and only let that number pass each year. But they haven't done that because they cannot actually identify what the impact actually is or what an appropriate level of boaters should be to minimize it. 

The rule and action to implement it was based on speculation alone and does not reasonably do anything to limit floating parties to some unknown "safe" number.


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## zbaird (Oct 11, 2003)

Sounds reasonable to me.

I'd pitch $50 to a go fund me set up by shap to fund a lawsuit to get this reversed. If it doesnt get enough contributions to fund the lawsuit because of cheapass boaters who love to bitch but not step up, we can just give the money to AW. Seems if we could get the majority of buzz members to even give a 20 spot it could work. Certainly there are lots of idaho boaters not on this site that it would be worth more than a 20 to. Start it up and spread the word.

I'd open a joint bank account with him if people want, so he doesnt swindle us and buy a new AIRE.

Those later dates are times when I can actually get away and go boating. I'd love to be able to pick up a late august cancellation.


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## rivers2run (Jun 7, 2012)

NMFS could issue take for salmon, I would ask some hard questions about that. They sometimes hold the agency's (BLM and USFS) hostage with their opinions. Essentially they tell you they can't issue an opinion (therefore hold up the entire season of boating) unless the action doesn't adversely affect fish they hold out and hold out. The regulations state issue take or call jeopardy but of course they would not take the heat of doing that. Yes they can dictate terms and conditions, horrible process. NMFS frustrates me to no end I used to work with them on ESA issues.


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## restrac2000 (Mar 6, 2008)

Thanks for the thoughtful response, Shap. Gives me something to look into and better understand the context. I am in the camp of not having a strong opinion in either direction on this issue. 

Phillip


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## shappattack (Jul 17, 2008)

FYI - these are not some musings of a disenchanted boater, I happen to study these things for a living and have been a fish biologist working in the PNW for more than 20 years now and also happen to specialize in ESA regulation as well as technical scientific assessment of salmon, steelhead, and trout population limiting factors related to all manner of human disturbance, from hydropower and flow regulation to recreational and commercial fisheries, and hatchery programs. I work on all sides of the fence and have seen it all from all angles, I work as a consultant for tribes, land conservation non-profits, hydropower utilities, state and federal agencies. I did pure research for many years as well. I don't pick sides, I pick scientifically based and rational viewpoints. I am not a sheep, I think critically based on objective data. If I thought boaters were causing a problem, I would have no hesitation in saying so and doing away with all the boater permits entirely. However, there is nothing pointing the the need for any limitation of the current permit system with respect to additional protection of Chinook spawning.


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## climbdenali (Apr 2, 2006)

I don't have first hand information to back this up but . . .

I was told that there are fish/conservation/anti-boating groups that actively apply for permits in that period just so that they can cancel them with basically no penalty.

I think MFS permits (and basically all permit systems) should be like GC permits where there's a significant deposit required up front. We wouldn't be so worried about cancellations if the permit required a $400 deposit right off the bat. And we also wouldn't be so capricious in our willingness to pick up a permit, knowing that we can cancel it later at the cost of a $6 non-refundable fee.

Sounded a bit conspiratorial to me, but also sounded believable.


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## dirtbagkayaker (Oct 29, 2008)

zbaird said:


> Sounds reasonable to me.
> 
> I'd pitch $50 to a go fund me set up by shap to fund a lawsuit to get this reversed.


Me too! Doesn't have to be a law suit. thou...

I think climbdenail has a good idea too.



climbdenali said:


> I think MFS permits (and basically all permit systems) should be like GC permits where there's a significant deposit required up front. We wouldn't be so worried about cancellations *if the permit required a $400 deposit right off the bat*. And we also wouldn't be so capricious in our willingness to pick up a permit, knowing that we can cancel it later at the cost of a $6 non-refundable fee.


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## shappattack (Jul 17, 2008)

It does have to be a lawsuit, the USFS/NMFS are trying to limit boaters Aug 15-Sept 15 based on poor and unfounded speculation on potential impacts to very few Chinook spawners. Changing the fee structure to ensure the maximum number of folks don't cancel and actually use there permits will be rejected because it is counter to their stated objective.

I would think a successful lawsuit would could actually cost well in excess of $100,000. Thats a lot of $20 donations.


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## restrac2000 (Mar 6, 2008)

Has anyone ever done a FOIA request for documents about the decision, process and policy?


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## shappattack (Jul 17, 2008)

restrac2000 said:


> Has anyone ever done a FOIA request for documents about the decision, process and policy?


Not necessary, The policy is the ESA, federal agencies must consult with either NMFS or USFWS (base don the species of concern) to ensure that actions directly taken, permitted, or funded do jeopordize the continued existence a ESA listed fish species or destroy or adversely modify any designated critical habitat for the species. 

This is done through ESA Section 7 consultation. In this case the USFS implements/adminsters the MF Salmon permit system. Every so often they have to re-consult with the NMFS to ensure that implementation of this program does not jeopordize the continued existence of the listed Chinook unit. IN this case the listed Chinook unit covers a huge area. not just Chinook in the Middle Fork. The ultimate decision is weather or not letting folks float down the MF Salmon river under the permit system jeopordizes the continued existence of Chinook salmon in the Snake River Spring Chinook Evolutionary Significant Unit (ESU). This ESU inincludes naturally spawned spring/summer-run Chinook salmon originating from the mainstem Snake River and the Tucannon River, Grande Ronde River, Imnaha River, and Salmon River subbasins. It also includes spring/summer-run Chinook salmon from 11 artificial propagation programs.

So when the NMFS/USFS analyze effects they should not only analyze what effects floaters have by potentially disturbing on average 1% of Chinook that may spawn in the MF Salmon River basin, but place that into the context of what that effect is in relation to the long term existance or risk to the entire ESU. 

The way this process works is that the USFS drafts a biological assessment where they lay out the program and analyze potential effects. Where effects may occur, they typically develop measures to minimize or avoid negative effects. They submit the document to NMFS. If NMFS concurs they have essentially minimized those effects and are not likely to adversely affect the species, then they just write a letter concuring with the USFS. If they think that there are some actual effects then they write a document called a biological opinion. Where they lay out measures to minimize/avoid impacts, they can also include an icidental take statement for minor effects to listed species, such as floating past a few spawners with some level of potential disturbance to an small part of the population that inhabits the MF Salmon and a very very small proportion of the entire ESU, if they believe that such harassment or any potential minor mortality will not jeoprodize the continued existence of the entire listed ESU. Does anyone think that floating past 1% of the redds with some level of small potential for actual disturbance would jeopordize the continued existence of the entire Snake River spring Chinook ESU or even the spring Chinook population that inhabits the MF Salmon sub basin? 

In this case, the USFS threw up a bunch of speculative measures to ensure that NMFS would concur with their assessment that the permit system is not likely to adversley affect the Snake River Spring Chinook Salmon ESU. And NMFS concurred. The question is, would NMFS not have concurred with a "not likely to advesely affect" determination by the USFS if they had left out the Aug 15 to Sept 15 no -reissuance of canceled permits rule? IF not, all NMFS would have had to do was write a Biological Opinion instead of a concurrence letter and allow some minimal level of take in the form of potential harassment by floaters that on average may pass by 1% of spawners in the MF Salmon sub basin or less than 0.1% of spawners as a proportion of the Snake Rive Spring Chinook ESU, the level at which the jeopordy determination is made.


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## shappattack (Jul 17, 2008)

Got to get the facts straight. I typed the above on the process without refreshing my memory first of the process, I just looked back in the folder I have on the subject. NMFS did produce a biological opinion including the permit cancelation measure. The biological opinion is here for all to read (attached):


And latest summary of Chinook info from the MF Salmon:
https://pisces.bpa.gov/release/documents/DocumentViewer.aspx?doc=P138723


NMFS did include incidental take in the form of harassment of spawners by floaters passing by up to 34 redds per year in the MF salmon floater permit area, and concluded that this form of harassment would not cause increased mortality. So it boggles the mind why the Aug 15 to Sept 15 rule is necessary.


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## shappattack (Jul 17, 2008)

Long term average of the number of redds in the mainstem MF Salmon is way way less than 34 total, again on average 99% spawn upstream of boundary creek or in the tribs. 


On another note, this consultation and rules associated with it expire in 2020. At that time we need to make some serious noise with data analysis to back it up to the forest supervisor.


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## zbaird (Oct 11, 2003)

After my donation we only need 4997 $20 donations and one cheapass to give $10. 

How many people put in for the middlefork each year? How many of us give away at least a $20 in permit apps to idaho each year for nothing and never look back? It cant be that hard to raise the 100k. Like I said, start it up, if it doesnt work give it to AW or we can keep it for another worthy cause down the road.


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## shappattack (Jul 17, 2008)

If you read the biological opinion, attached above you will see that there is not any discussion or analysis of the need or benefit of the Aug 15 to Sept 15 permit cancellation rule. If there is no discussion or analysis of it, how did they determine it was needed? 


There is a lot of analysis in the Biological Opinon on the potential effects of floaters passing by redds and the ultimate conclusion was: 


"A small number of adult Chinook salmon will be disturbed from floatboat activities, and the total effect of this disturbance on the extended population is expected to be very small." 


The small level of harassment was authorized by the incidental take statement. The biological opinion itself essentially argues that the Aug 15 to Sept 15 cancellation policy is unnecessary.


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## zbaird (Oct 11, 2003)

I'm with you dude. Even without the biological evidence, of which there is plenty, the fact that if permits don't cancel and it is fine for that number of users to go down the river, it means that they should be reissued.

(warning, thread tangent below) 
I have been dealing with this problem in Colorado for hunting tags. If tags won in the lottery are turned in for a refund they don't get put on the online leftover tag list. This keeps money out of the CPW pocket, makes it impossible to meet harvest goals, and keeps desirable tags out of hunters hands. The main unit I hunt in has 30 cow tags. CPW and local ranches want those 30 cows harvested. Last year there were 4 people I new that had tags in the unit that had things come up and the turned in their tags months in advance for refunds. Thats 4 out of 30 tags that were unavailable. I didnt draw so I ended up having to hunt with an over the counter tag instead of picking up a tag in the unit I know. CPW has a leftover system that tags automatically go into if they arent drawn in the lottery. It just doent seem that complicated a thing in todays world of software to have refunded tags get listed on the leftover list. A tag gets turned in, entered in the system and the refund is issued. Why at that point is isnt auto entered into the leftover list is crazy. This kind of shit frustrates me to no end. 

If a tag or permit is there to be used, let someone use it. Collect the fees associated, let users use whats allocated and everyone wins.

Here we are thinking of raising money for a lawsuit that will potentially let us use the user days we already have been allocated. Its nuts!!

Oh, and if you dont want to runs a super low middlefork stop applying for tags after mid july!


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## shappattack (Jul 17, 2008)

zbaird said:


> Oh, and if you dont want to runs a super low middlefork stop applying for tags after mid july!


Amen, this is something we really can do something about, public shame as many folks as possible that cancel permits between Aug 15 to Sept 15 that don't have an excuse other than low water.


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## restrac2000 (Mar 6, 2008)

If a lawsuit is actually of interest than I would strongly suggest when not incite infighting within our community. We are too small and the suggested solution is gargantuan. I can look past a few offhand remarks but publicly shaming people who are abiding by the system will push a lot of moderate people away (all for a change in cancellation policy and penalty).

Finding thousands of boaters to contribute requires unity. Just a thought.

Phillip


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## Paul7 (Aug 14, 2012)

Too bad the permit system couldn't pop up some historical flow data when someone is applying for a late summer date. I'd bet a lot of folks just don't really know what flows are to be expected. 

Sent from my SM-G900V using Mountain Buzz mobile app


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## lhowemt (Apr 5, 2007)

Perhaps a baby step is to get them to release permits that are not claimed by March 15th. That has always chapped me too, right out of the gate there are always dates with x's.


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## shappattack (Jul 17, 2008)

Unfortunately, I don't believe here is no way in hell the private boating community is going to organize or back a lawsuit.



restrac2000 said:


> If a lawsuit is actually of interest than I would strongly suggest when not incite infighting within our community. We are too small and the suggested solution is gargantuan. I can look past a few offhand remarks but publicly shaming people who are abiding by the system will push a lot of moderate people away (all for a change in cancellation policy and penalty).
> 
> Finding thousands of boaters to contribute requires unity. Just a thought.
> 
> Phillip


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## Genghis (May 28, 2007)

Probably so- But I will throw in a few hundred dollars to get this thing started.


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## mattman (Jan 30, 2015)

Thanks for the mountain of information Shap! Kinda impressed man!

Possibly the worst part of the issue is that it seems to be normal Forest Service behavior, 
they have been miss managing in this fashion for years, all over the country. It's kinda like watching a family guy episode, where the next seen is completely random and doesn't make any sense.

I'd be down with donating a $30 to help try and knock some amount of sense into a major agency that keeps ignoring reason in it's decisions. Just kinda sick of there bull.

Perhaps we shouldn't alienate boaters that cancel late season mfs permits, but we at least need to keep trying to educate. Although if you pay some amount of attention when you apply, it's kinda right there on the web site.....


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## restrac2000 (Mar 6, 2008)

Any idea why this not already a cause for AW?

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## lhowemt (Apr 5, 2007)

restrac2000 said:


> Any idea why this not already a cause for AW?
> 
> Sent from my MotoG3 using Mountain Buzz mobile app


Maybe the membership hasn't made it an issue. IRU might be a better group to take it on.


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## fdon (Jul 23, 2008)

Great conversation! I have to be counted as another one favoring the lawsuit. Just with the data provided in this thread, it seems a strong case is present. 

I have been a major party in a suit against the FS on an unrelated matter. We contracted with an attorney group who took the case for the eventual settlement fees which approached 200K so it cost our group zero. The FS ignored us until the suit was filed. After that they snapped to attention. 

Perhaps a letter from an attorney stating the intent to sue would bring them to the table but perhaps we are getting the cart before the horse here; should we not organize a small group of us to approach the FS with our ideas in a more friendly matter? We could organize a "friends" group to take on this cause rather simply or we could ask a large NGO to take it on. Either way, something needs to be done as we are losing private permits in this instance and that is a "taking" of unparalleled magnitude in my opinion.


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## restrac2000 (Mar 6, 2008)

Agree on organized group trying to negotiate with USFS instead of starting with lawsuit.

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## rivers2run (Jun 7, 2012)

However if boaters win the lawsuit they can collect attorney's fees that happens all the time. I worked for the USFS and getting a biological opinion out of NMFS was like pulling teeth. The way the regulations say the system should work and the way it actually works are quite different. The USFS runs scared because they are afraid NMFS will not respond in time and so the entire season would be delayed because there is no Biological Opinion so they are ultra conservative in their calls. Plus many of the Biologists working in NMFS have actually never worked on the ground so they rely on literature reviews. It is a horrible process most fish Biologist just hate it.


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## rivers2run (Jun 7, 2012)

The Biologist meet together, consultation, so they know in advance how NMFS will call it. They get manipulated into making may affect fish but not likely to adversely affect calls so they can avoid Biological Opinion that comes in months late. The elephant in the room are the dams but of course no one will touch that, so there is micro-management.


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## mattman (Jan 30, 2015)

restrac2000 said:


> Agree on organized group trying to negotiate with USFS instead of starting with lawsuit.
> 
> Sent from my MotoG3 using Mountain Buzz mobile app


So usually I believe in trying to come to a friendly solution with conflicts as well, but from the info on the topic shap had, it sounds like it is not even possible for that rule to be changed, without a law suite, at least that's what I understood.

I could see the Forrest Service getting really goosey for a season, with a law suite on there hands, it could screw up boating the middle fork for a season. Of course it could also lead to a much better MFS situation in the future, maybe even take a bit of strain off the earlier parts of the season, if there was more of a chance at a late season permit.
I also wonder what potential implications for commercial companies could be, if the Forest Circus were to get really goofy for a season, due to a law suite, would they loose there ass big time? Put guides out of work? Or would it be fine?


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## rivers2run (Jun 7, 2012)

I have wondered if holding NMFS feet to the fire in issuing Biological Opinions in the timeframes they supposed to respond. There were Fish Biologists on the forest I worked on that left the agency because the consultation process was so onerous. All they have to do is issue take, if they don't call jeopardy for the dams how could they do that for boaters it's utterly ridiculous. They could give terms and conditions which could put us back to where we are now, that's a possibility. I told them a few times on other projects give us a Biological Opinion or call jeopardy, of course I knew they never would.


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## shappattack (Jul 17, 2008)

Wake up call, read the Biological Opinion. It has an incidental take statement that allows "take" in the form of floating over and harassing spawners on up to 34 redds per year along the mainstem Middle Fork. 34 redds is like the maximum ever observed along the mainstem. The Biological Opinion determined that this level of take would not increase mortality and is allowed. Therefore, the Aug 15 to Sept 15 permit cancelation rule, designed to minimize harassment of spawners by floaters is entirely erroneous because the Biological Opinion itself already allows for take to an extent that would not be exceeded by any number of float craft. The biological opinion allows for harassment/floating by a total number of redds by the full number of boaters allowed through the existing permit system and makes no mention of any need for reduced floaters during Aug 15 to Sept 15. The USFS has been implanting this rule even though the Bioloigcal Opinion from NMFS makes it clear it is unnecessary.


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## shappattack (Jul 17, 2008)

rivers2run said:


> The elephant in the room are the dams but of course no one will touch that, so there is micro-management.


Actually the real elephant in the room is climate change and also inherent productivity changes in the ocean that happened prior the current climate change discussion, long term patterns in ocean productivity, which translate in to very large differences in adult returns and juvenile-to-adult survival rates. Ocean productivity is the biggest driver in population productivity by far. The real problem are cycles when the ocean has poor productivity and ocean survival is real low, which gets exacerbated by additional limiting factors in the freshwater environment, such as juvenile mortality at dams, adult mortality at fish ladders due to seals, colonary bird predation, Harvest mortality, etc. etc.


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