Bull trout recovery plan assessed by retired Fish & Wildlife employee - Opinion used by 'experts' rather than scientific evidence
Below is a summary of the WALF commissioned Ken Williams assessment of the bull trout Recovery Plan. Ken is a retired WDFW [Washington Department of Fish & Wildlife] employee who managed bull trout and steelhead in the Upper Columbia.
Ken Williams Bull Trout Recovery Assessment Summary
The NMFS" local moniker for professional judgement is "best
available science". The USFWS uses the term professional judgement,
which is more forthright, but still the implication towards party
line science is not obvious to the innocent. Professional judgment
has its place, but only where science ends and there is no further
recourse. In this recovery
A hallmark of unimpeachable science is rigorous peer review. One
of the bald inadequacies of the ESA is that it violates the scientific
method by striking the peer review tenet. In my experience institutional
science flows along with sectarian oversight which invariably yields
malleable science, science vulnerable to institutional bias,
The shortcut to authenticating and adopting a plan is wont to be
habitat-based, as all recovery plans are wont to be in this age, because
today only the cause of cause and effect need be demonstrated. Therefore,
it's not necessary to show that a culvert is blocking fish only that
the culvert exists. There is no science in counting culverts.
Similarly, all the evidences of man"s eco-infractions of streams' riprap, livestock, irrigation, roads, etc.- are assigned equal weight to be tallied up in a spectacular incriminating heap that can in itself explain the "demise" of bull trout. Culpability can be determined and documented in an office without a dead fish in hand or hardly a glance toward the river. The slant against man jumps out from the bypassing of natural habitat factors to dwell on human factors. The Plan does not even mention the USGS hydrological study in the Methow and how the USFWS might incorporate that information into the plan. The habitat status section of the report is so superficial and canted that it is useless and dangerous in diagnosing fish status and charting a recovery plan.
Habitat is like gravity, everyone observes it, but no one can explain
it. Everyone understands the reality and importance of habitat, but
who can define it or its correlation to fish in quantitative terms?
In this vacuum of scientific certainty confusion and non-science (professional
judgments) flourish. The habitat theme now reposes on a pedestal so
venerated that falsification is untenable even by science, a point
that Karl Popper warned ofirrefutability may seem like a virtue,
but in reality it is a vice. In other words a rule that has an answer
WDFW rhapsodizes the virtues of the Methow"s Arrowleaf Reach-
a naturally dewatering reach - in the same breath he finds irrigation
an agent of extinction in reaches that never dewater. Or should we
puzzle when the fish restoration folks would rather drown than reach
out for an irrigation recharge life preserver. And why they enthusiastically
embrace "professional opinions" from non-professionals who
overlook how irrigation may actually improve the amount and quality
of water for fish. Or be amazed that it"s not about salmon but
The habitat-based recovery preoccupation should be corroborated by
alternative methods, if the plan is to be more than an echo from the
non-scientific culture and a clone of the New England Atlantic salmon
disaster. Life history ecology and population biology understanding
are glaringly AWOL, as are harvest management principles, all blows
to the competency of the plan. Calling on professional judgment to
set target recovery numbers based on genetic theory is inappropriate.
Such numbers are implausibly and indefensibly high on the order of
magnitude of 10 to 15. With them recovery becomes impossible and eternal.
Predicting the institutions will be loath to admit that the target
numbers are off-the-chart high, the only recourse is to tighten the
stranglehold on humans, particularly farmers, further infringing upon
their ability to interact with natural resources in responsible ways.
It is clear to me
I agree that some populations are low, but I disagree strongly about
causation. The current plight, with a few minor exceptions, is a natural
process- interglacial warming followed by invasion of salmon and
The complete assessment is available on request.
WALF has also commissioned a white paper legal review of drainage district authority and management in Washington State that will be available soon.
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