Critique of Draft Bull Trout Recovery Plan
U.S. Fish and Wildlife Service
Portland, Oregon
October 2002

By Kenneth R. Williams
Fish Consultant

The Washington Agriculture Legal Foundation


My credentials for critically reviewing this document is found in my expertise developed over 28 years (1971-1999) as District fisheries biologist for the Washington Department of Fish and Wildlife (WDFW) in the upper Columbia Region. I was the major author in conducting seminal research on the distribution, abundance, and life history of steelhead and bull trout in the Methow River Basin published in the Mullan et al. (1992a). As manager I specified proposed fishery rules-bag limits, seasons, gear, boundaries, etc.-to provide sustainable yields and conserve fisheries resources. In the 1990s my management responsibility was expanded to include the Entiat and Wenatchee basins in addition to the Methow and Okanogan Basins. I authored the local contribution to WDFW's statewide steelhead and bull trout status reports of 1996 and 1998, respectively. I authored WDFW's response to the petition for listing westslope cutthroat. I initiated the protocol and defined the index sites for monitoring bull trout spawning populations in the Methow Basin. I estimated the population of resident bull trout in the Lost River between Diamond and Drake Creeks and monitored potential fishery impacts. I conducted systematic searches in virtually all streams for the presence of bull trout in the Okanogan Basin without success (unpublished reports). I am familiar with most the voluminous literature accumulated since David Thompson passed through the region in 1811. Since my retirement in 1999, I've specialized in ESA issues. Important among several Methow projects have been analyzing spawner-recruit functions of spring chinook salmon (Methow Basin) and critically reviewing the Washington State Conservation Commission's Limiting Factor's report (WSCC 2000).

Scope and resources

Time constraints force me to merely touch on broad themes of bull trout status, limiting factors, recovery criteria most directly related to agriculture interests. Though my comments are to cover concerns for Washington state agriculture I do this obliquely for bull trout populations outside of my focal point-upper Columbia (Chapter 22)-of the Draft Recovery Plan since time does not permit me to include areas outside the domain of my expertise.

The Mullan Report (Mullan et al. 1992a) will be referenced on numerous occasions throughout my review. The report is based on empirical results from seven years of field research and comprehensive literature reviews by authors tallying 140 years of tenure, two Ph.D. degrees, and several papers published in scientific journals. The report was reviewed by the WDFW and the USFWS subsequent to the prodigious review conducted by the authors themselves, who managed to cajoled reviews from some of the most recognized names in the fisheries profession. Bruce McIntosh, one of the reviewers in the second round of reviews sponsored by the USFWS back in 1992 who criticized the habitat analysis part of the Mullan Report, confidently arguing his generic views superceded local empirical findings. Shortly thereafter it turns out McIntosh investigated select habitat parameters in the Methow to discover habitat status to be in much better condition than he originally imagined. To his credit he changed his mind when confronted with reality, and actually used the very points he previously criticized to support his findings. Ironically, in spite of McIntosh's renaissance the USFWS faithfully issues his original review with every copy of the Mullan Report sent out. Eight years after publication, the WDFW took another crack at the report by contracting the American Fisheries Society (AFS) to critique it. Three of four reviews were unfavorable. Nevertheless, the Mullan Report has no peers as the most comprehensive assessment of the upper Columbia and continues to challenge those hypothesizing that human actions are the primary limiting factors for salmon, steelhead and bull trout in the upper Columbia. Except where noted, I generally refrain from using in this review that information the AFS reviewers criticized regardless of whether I agree with them or not.


I applaud the considerable effort expended by many teams of biologists in the creation of a document of this magnitude. Though I have many points of serious disagreement, the most critical aspect of the Plan is not that it is polished perfect but that it is a starting point. The common thread that binds agriculture and bull trout well being is science. My sincere belief is that quintessential science will demonstrate that agriculture and healthy bull trout populations are mutually inclusive. My purpose in this review is not to disparage but rather to assist bull trout recovery by constructively challenging the science I feel is unsupportable, incomplete, or absent.

Life History

Glacial relics
I'm struck by the absence of a big picture perspective of bull trout status, life history, and limiting factors. The plan assembles many of the pieces of the puzzle, but its architects have not put enough of them together to see the grand theme. Bull trout are glacial relics, vestiges of the last ice age. They along with other cold-water fish such as westslope cutthroat dominated the fish communities of the Columbia Basin and many basins of the west when the climate was colder. For example, when the great ice dams of Idaho and Montana gave way in such quantities that floodwaters reached the elevation of Lake Chelan, only cold water species such as bull trout, westslope cutthroat, pygmy whitefish, burbot, etc. existed to colonize the lake. Barrier falls (namely Metaline, Albani, Spokane) that formed after de-glaciation and headwater penetration of bull trout and westslope cutthroat isolated and protected these species once the intolerably cold warmed enough to accommodate invading anadromous species.

The Plan's statement that bull trout require more exacting habitat requirements (e.g. colder temperature) than most salmonids is incorrect. Early in the 20th century the Lake Chelan population of bull trout and westslope cutthroat was impressive, and the fishery attained national acclaim. I personally know a man who as a youngster accompanied by his clan annually made the trip from Malott to Stehekin Falls at the head of Lake Chelan to snag bull trout-big bull trout-as his photos prove. By the 1950s both bull trout and westslope cutthroat were extinct. There are no habitat changes, stochastic events at play, or over-fishing to blame, and the Stehekin River remains essentially as pristine today as it was in pre-settlement times, supporting thriving populations of kokanee salmon and rainbow trout. Rainbow trout stocked in the first decade of the 20th century over the course of 40 years doomed bull trout and cutthroat. Both rainbows and cutthroats were planted above the falls and rainbows dominated up to Bridge Creek, but above the warming influence of Bridge Creek the rainbow distribution abruptly ceases and cutthroats (and bull trout if they were planted) rule.

The imperative is that bull trout have much greater spatial (and thermal) flexibility in spawning and natal rearing habitat than is generally recognized but only in isolation from competitive species-namely steelhead and chinook salmon-the Oncorhynchids. The thermal optima of bull trout and westslope cutthroat at spawning and natal rearing are slightly colder than that for salmon and steelhead, and bull trout prevail only when water temperature favors them. And where does sufficiently cold water exist for bull trout-the high elevation headwaters. The reason for those small, disjunct populations clinging to existence in the frigid, far reaches of headwater streams is not due to more exacting habitat requirements but rather different habitat where cold temperatures advantage bull trout. In isolation Chelan bull trout historically spawned successfully in temperatures that favored the Onchorynchids (habitat requirements not exacting), which explains their disappearance when man introduced Onchorynchids. In the Methow sufficiently cold water necessary to fend off the Onchorynchid amounts to a miniscule 29 surface acres (Mullan et al. 1992a)! Remove the Oncorhynchids and the quantity of available critical habitat for bull trout and cutthroat would expand many magnitudes and they would flourish in their former ice-age glory.

The post-glacial status of bull trout is analogous to another glacial species defying extinction-the white-tailed ptarmigan, which in Washington is found on the alpine summits of a handful of mountains in the northern Cascades. There is no delusion about the futility of recovering these birds because its exceedingly clear that qualifying habitat is rare, unaltered much by man, and not readily reproducible by humans. The alpine summit for ptarmigan is a metaphor for the headwater spawning/natal rearing for bull trout. In these inter-glacial times neither species can be any more than vestiges because critical habitat is vestigial. This understanding is largely cryptic for bull trout because they are not sequestered to their natal environs for a lifetime as are ptarmigan, undergoing a physiological change so character-altering that they are like a new species answering the call to a sojourner's life and a whole new suite of habitat preferences. The reproductive urge triggers a reverse migration upstream all the way back across perfectly good spawning habitat for salmon and steelhead to reclusive safe-harbor in the headwaters to breed.

Lake Chelan's sad bull trout tale pales compared to the impacts of Oncorhynchid plants above the barrier falls of vast watersheds draining northern Idaho and western Montana, where the longitudinal contraction of bull trout and westslope cutthroat is staggering. Astonishingly, the single most critical limiting factor and determinant of bull trout distribution and status is absent from this recovery plan. Without this essential understanding this plan will not recover bull trout holistically speaking; to the contrary it will accelerate geographical shrinkage and the extinction of some small populations barely hanging on. In almost every case within the upper Columbia streams bull trout are making their last stand with their heads pinned against upstream barrier falls blocking them from colder water upstream and their tails nipped by opportunistic Oncorhynchid invaders ever advancing as the water warms. In many cases sufficiently cold habitat safeguarding bull trout is most appropriately measured in yards, not miles. These populations are teetering at the brink of extinction and even subliminal warming, either natural inter-glacial warming or man-induced global warming, will tip the balance for Oncorhynchids (See Appendix K in Mullan et al.1992a).

Once a population loses its habitat all the kings horses and all the kings men . . . All of the other limiting factors on which the Plan relies for recovery are moot once the habitat is usurped. In other words disregarding the invasion of Oncorhynchus is tantamount to fiddling while Rome burns. Any plan failing to address this risk is derelict. If earth climate models are only modestly accurate all bull trout in Washington will be extirpated in the 21st century except those above impassable barriers in my opinion. For the upper Columbia (Chapter 22) the simple acts of introducing and establishing bull trout above the falls on the White and Napeequa River would boost Wenatchee bull trout populations more than all other measures combined. Since brook trout infest the Entiat R. above the falls, retaining bull in the Entiat Basin would depend on establishing them in a high lake or maintaining them in a hatchery. Re-establishing bull trout in the Lake Chelan/Stehekin River Basin is as simple as introducing them into the river above Bridge Creek and/or Trapper Lake. As for the Methow Basin only the Early Winter Creek population (above a falls) is secure from the onslaught of Oncorhynchus. Falls on Crater, E.F. Buttermilk, Reynolds, North, Wolf, and Cedar Creeks plus the Twisp River offer protection from invasion, but these streams are rather small. Falls on the West Fork Methow, Lost, and Chewuch Rivers are compromised by reproducing rainbow populations. There are a number of high lakes that could be colonized, and two hatcheries having the capacity to rear bull trout now operate in the Methow. The only habitat sufficiently cold for bull trout in the Okanogan Basin is found in upper North Fork Salmon Creek, which once held bull trout until they disappeared via introgression with brook trout in the 1950s. Short of creating a barrier dam on the North Fork Salmon Creek and purging brook trout above the dam, there is no other suitably cold habitat in the Okanogan Basin, except in the headwaters of the Pasayten Wilderness.

Is all available spawning habitat being utilized? Where will all those "recovered" bull trout spawn and rear-in expanded habitat or in greater concentrations in current habitat? For its own clarity this plan should define the physical habitat suitable for spawning and natal rearing-the real critical habitat. Indiscriminately assigning parity to all habitats throughout their range and life history dismisses the abrupt increase in tolerance to environmental conditions, paving the way for smolts to leave their headwater sanctuaries to invade the Oncorhynchids and begin eating them. These ubiquitous downstream habitats are much different but less critical than the "incubator" habitat in the headwaters.


The concept of plasticity of form (polymorphism, i.e., resident, fluvial, adfluvial forms of bull trout within a given gene-pool (metapopulation) is problematic to the proposition that bull trout are at risk. Polymorphism in steelhead is the analog to that of bull trout wherein all those headwater populations of rainbow trout (purportedly genetically distinct from anadromous steelhead) are actually resident steelhead (genetically identical to anadromous steelhead) exhibiting resident life histories due to cold temperature (Mullan et al. 1992a). From downstream drift subsequent to hatching and emergence, common virtually to all fluvial salmonids as a dispersion mechanism to maximize habitat utilization, some juveniles of the resident ecotype reach warmer, richer water favoring the anadromous ecotype and are induced to transfigure from one life history ecotype into another. Accordingly, ecotype is determined by ontological environment (Balon 1984), and for migratory bull trout to face extinction their resident cohorts must join them. Since the resident populations occupy headwater environments above many potential abuses of man and are generally healthy and self-sustaining numbering in the thousands in the Methow, extinction becomes improbable for steelhead even if the anadromous returns are obstructed for a thousand years. The smoking gun is the historical fact that when access to the Methow was interrupted for 16 years (1916-1930) by a hydroelectric dam (Bryant and Parkhurst 1950) coho salmon (no freshwater ecotype) were extirpated, but not steelhead or bull trout.

Another fly in the ointment for imminent extirpation is the underestimation of spawners and genetic variation from overlooking resident males spawning with migratory fish. Mullan et al. (1992a) showed that sex ratios progressively favored females in the lower reaches of the headwater spawning/rearing zone, improving population fitness by placing females in the habitat most encouraging migration, which results in larger females with higher fecundity and larger eggs. More males adopt the resident life history because they tend to grow faster and mature earlier. I've found these small sexually mature males in substantial numbers on spawning grounds, and migratory size males often harass them while attending females on redds. That these resident males participate in spawning and gene flow is not represented in this plan because redd survey crews don't count these small fish or even suspect that they mate with larger migratory females. Many (Gephards 1960, Leman 1968, Healey 1991, Mullan et al. (1992b) report tiny precocious non-migratory chinook males mating with huge anadromous females. Bley (1987) reports the same for Atlantic salmon. Though visual verification is difficult for anadromous steelhead due to high, semi-turbid flows, Mullan et al. (1992a) report growth characteristic in otoliths of wild steelhead returning to the Leavenworth Hatchery that could only have come from the frigid water high in the mountains miles above the barrier dam at the hatchery. While verification of a genetic nexus between bull trout ecotypes has not been reported almost assuredly it does, meaning the number of spawners has been underestimated by some unknown but substantial amount. The Plan leads to a conclusion that bull trout are at high risk because they are underescaped and that low numbers have or will lead to loss of genetic variation and inbreeding depression. Without considering polymorphism, however, the conclusion is wrong or at least unsupportable.

Population Biology

From the above discourse the term recovery as it applies to bull trout is actually a false-hope misnomer. The Plan's premise that bull trout status went from health to hell in the past century is unsupportable. The overarching factor defining bull trout distribution and abundance is set naturally by available spawning and natal rearing habitat. The fate of bull trout is linked to glaciers and when the earth warmed and the glaciers disappeared millennia past so faded the grand era of bull trout. Even cyber-man can't effectively control global temperature-the key to materially increasing bull trout habitat. The only populations missing from the upper Columbia metapopulation are Lake Chelan, Beaver, Salmon, and perhaps Eightmile Creeks, but restoration of these small populations would not change overall status according to USFWS criteria.

All available habitat is being utilized save a small amount above the Leavenworth Hatchery Dam, and the pathway to increasing abundance is somehow affecting greater production from a small, fixed amount of habitat. According to plan presenters at the Wenatchee Public Hearing (Wenatchee World, January, 2003) the current population of adult migratory bull trout in the Methow is about 200 fish, which seems about right to me given redd count data. The recovered number ranges from 3,610 to 5,886 fish. Such figures are so eye-popping unrealistic that one's first consideration is misplaced decimals.

There are multiple ways to ground-truth the recovered numbers, but the USFWS makes no such attempt, seemingly oblivious to the problem. The problem is that the Plan has bull trout more abundant than healthy spring chinook salmon and steelhead populations combined! The Maximum Sustained Yield (MSY) escapement for steelhead is about 2,300 spawners (Mullan et al. 1992a, Appendix H) and 2,000 or less spring chinook spawners (Williams unpublished analysis). Steelhead are ubiquitous spawners utilizing virtually all accessible streams and rivers large and small, warm or cold (1,586 acres). Spring chinook use less habitat than steelhead (981 acres), preferring the larger tributaries and mainstem Methow above Carlton. By contrast, bull trout spawners use only a tiny fraction (29 acres) of the Methow Basin (Mullan et al. 1992, Appendix K). It's critical to understand that though juvenile bull trout rear throughout the Methow Basin the ultimate number of migratory adults is set by the production within the confines of the spawning and natal rearing habitat in headwater refuges before the parr become migrants and move downstream. Downstream habitats can affect the fate (growth and survival) of smolts produced in the headwaters but such habitat has no say in how many smolts it will receive for nurturing. The over-exuberance of expecting 29 acres of habitat to out-produce 1,586 acres of habitat is self-evident.

Not only are the physical dimensions of the spawning reaches meager, the paucity of gravel there is striking. These are high gradient, turbulent, degrading reaches dominated with cobbles and boulders; patches of suitable gravel are widely scattered. The number of spawners required for full seeding is comparatively low versus the figure for anadromous Oncorhynchids, which enjoy prodigious spawning gravel in the aggrading valley floors.

Not only is the quantity of critical habitat precious little, its productivity is much less because of low temperatures and chemical paucity (Mullan et al. 1992a). Some of the lowest growth rates every recorded in the literature are reported for headwater salmonids in the Methow Basin (Mullan et al. 1992a, Appendix K). The Plan states that the natural fertilization of decomposing salmon carcasses, reduced with decimated salmon runs, may be a limiting factor is not true for juveniles rearing in natal, headwater habitats, all of which lie above salmon spawning.

Abundance is reduced not only from the habitat's lower carrying capacity but also from the length of time spent in the habitat. Spring chinook and steelhead normally become smolts in 1 and 2-3 years, respectively, compared to 3-4 years for bull trout. Since the annual mortality rate for salmonids is great-50% or higher-advancing age is severely penalized by high mortality and fewer bull trout smolts are produced per unit area Mullan et al. (1992a). Sexual maturity also is retarded in bull trout populations advantaging survival to anadromous species for completing life cycles quicker, dampening cumulative mortality. Anadromous smolt production is maximized to compensate for the vagaries of ocean productivity. Free from uncertainty of ocean survival and needing few spawners to seed small, austere environments, the life strategy emphasis for bull trout is quality instead of sheer numbers, therefore the full seeding strategy is met with greater age classes representation with fewer individuals per age class. Nevertheless younger age classes predominate because few fish can beat that steep death curve.

Finally, the food chain constraint-90% loss of energy at each step up facing apex predators like bull trout-must be accounted for. Therefore, immutable biological law forbids more bears than salmon, more lynx than rabbits, more cougars than deer, and more bull trout predators than prey species. In fact, the ratio is roughly 1 bull trout to 9 salmonids, meaning that if the optimum escapement for all anadromous salmon (spring and summer chinook) and steelhead is 5,000 fish and equivalent amounts of spawning habitat (actually bull trout only have 2% of that available to other fishes) migratory bull trout would number roughly 500 adults. Even if we double the number to 1000 fish to account for sculpins, whitefish, suckers, and dace, the number reduces to only 20 fish when adjusting for the gross habitat availability differential. Assuming that many bull trout enter the Columbia and feed on fish originating outside of the Methow and that five-fold more fish do so, the tally reaches 100 fish. If bull trout live twice as long as other salmon and steelhead then the number can be boosted to 200 fish. The total increases to 400 if it's assumed that the Methow can support double what is needed for MSY escapement. But beyond that it becomes difficult to realistically demonstrate how the pre-anglo population could be appreciably larger.

On page 43 of Chapter 22 claims that the forage base for bull trout has been reduced because of a decline in abundance of endangered salmonids. Such a naïve statement illustrates wrong-headedness. The endangerment listing of spring chinook and steelhead is not based on juvenile production within the tributary streams but rather on the low number of returning wild adults. The institutions have no idea how many smolts are produced yet they reject the empirical data that shows that standing crop estimates are commensurate with optimum (MSY) production (Mullan et al. 1992a). The whole problem of few wild adults can be accounted for after optimum number of smolts leave the tributary streams for the ocean. Hatchery spawners are not considered. Using the NMFS criteria the stocks would be endangered even if 500,000,000 hatchery spawners returned. Steelhead spawning escapements (hatchery plus wild) approach or exceed the optimum number (2,300 fish) almost every year. The same can be said for spring chinook, except for the Methow where biologists opt to divert the run into hatcheries on low run years instead of allowing them to spawn naturally. The hatcheries dump millions of smolts into the rivers, which are available to bull trout. Bull trout also consume non-listed summer chinook and other fish species mentioned above. Historically, bull trout dominated the region when the water was too cold for Oncorhynchids except westslope cutthroat. In the resident populations bull trout eat bull trout.

If the historical number of large migratory bull trout exceeded 3,000 fish in the Methow it is difficult to image that Indians and pioneers would not have noticed, yet there's nothing in the ethnohistorical record that even hints at bull trout being anything other than a novelty. Certainly nothing compared to the volume of reports of great salmon runs and numerous Indian fishing villages replete with drying racks straining under the load of drying salmon. There were no directed fisheries towards them by either Indians or settlers. Anthropologist R.H. Post's (1938) study of the subsistence quest of southern Okanogan Indians does not even mention bull trout. Bryant and Parkhurst's (1950) overview of Wenatchee and Entiat Basin fishery resources does not refer to bull trout, though their presence is indicated in a few assessments of individual waters but not the stronghold populations in Lake Wenatchee, the White River, and the Chiwawa River. Fair fishing for Dolly Varden was noted for the mainstem Methow River. In 1942 the Bureau of Reclamation collected affidavits of 16 local experts whose knowledge extended back 25 to 40 years expressing relative abundance and distribution of salmon runs in the Wenatchee, Methow, and Okanogan Rivers (Craig and Suomela 1941). Though the focus was on salmon, its not likely that those men would have missed reporting on thousands of bull trout even if abundance had crashed by 1942, but not a peep was heard. Ayerst (1958) conducted extensive creel census in the Columbia River between Rock Island and Chief Joseph Dams prior to the construction of Rocky Reach and Wells Dam at a time when salmon abundance reached peak, self-sustaining levels during the 20th century but checked only the occasional bull trout.

The inescapable conclusion that numbers of recovered bull trout using cold, sterile habitat amounting to less than 2% of anadromous spawning habitat could outnumber healthy MSY escapement levels of salmon and steelhead is a biological impossibility. The recovery benchmark is so high that recovery rivals the Sisyphean curse.

Using professional judgment or theoretical calculations to foil inbreeding depression or genetic drift are inadequate to ascertain appropriate population size. The conventional approach is to use stock-recruitment models (Ricker 1975, Chapman 1986). Maximum population is achieved by limiting the number of spawners by harvesting surpluses at an optimum (MSY) level. Beyond this level populations decline, because of redd superimposition, increased competition of the progeny, leading to poor growth and higher mortality, and other population stressors that reduce fitness and survival. The downstream drift mechanism to disperse newly emerged fry noted for most fluvial salmonids into habitats far downstream ceases for bull trout at the interface with the Oncorhynchids, for bull trout at this stage cannot successfully survive the competition. This handicap plus the sparse availability of spawning habitat and sterile rearing habitat suggest that relatively few spawners are needed for full seeding.

Stock-recruitment functions for many salmon and steelhead stocks have been computed (Chapman 1986). Optimum exploitation rates for achieving MSY escapements are highly variable among salmonids, ranging from 88% for fall chinook salmon, 68% for spring chinook, 69% for steelhead, and 48% for chum salmon. I know of no stock-recruitment function for bull trout, but I suspect that it might be low. Limiting factors that reduce numbers above natural levels are considered forms of exploitation, therefore, the exploitation rate of a stock is the sum total of all man-caused losses.

Scientific fisheries management focuses on determining and meeting MSY escapements and assigning exploitation rates for each man-cause factor depleting bull trout whether it be culverts, lack of wood, or fishing. My concern with the Plan is the absence of scientific fishery management. The Plan in essence is a mystical, habitat-based approach that is reliant on professional opinion, with a mindset that man has abused the habitat. The problem, of course, with the habitat-based approach is the absence of mathematical correlation of habitat attributes with fish abundance. That's precisely how professional judgment is surrogating real science. The habitat limiting factors reports-WSCC (1999, 2000, 2001)-widely cited in the Plan are little more than speculative professional opinions. I'll state unequivocally that not a single activity of man with upper Columbia streams has been shown scientifically to be limiting to bull trout.

The Plan is a flagrant violation of White (1986) who cautioned that trying to understand fish populations outside the ecological setting is as meaningless as trying to understand habitat without information on the fish that use it. The lesson is this we need to integrate scientific-based fish management principles with habitat understanding. Only until we can compare spawning escapements against the MSY standard can we evaluate risk and measure the affect of limiting factors. The cornerstone of evaluating fish status is the emotional comparison of what is today against those unspeakably large runs blessing Native Americans every year. Chapman (1986) challenged this myth using stock-recruitment understanding to argue that salmon runs peaked after anglos began fishing and exploitation rates increased to optimum levels before overfishing caused the runs to almost disappear. Pre-anglo Indian harvest amounted to only 10-15%, causing average runs to languish about 50% below maximum. What happen to the salmon runs when the Indian population was decimated by disease in the early 1800s and harvest fell to about 2%? The conventional wisdom of that day and naïve uninformed professionals today are seduced by the power of the intuitive logic that more spawners yield more recruits. Careful review of the diaries of the early explorers reveals another story; the common sight of starving Indians waiting for runs which never materialized throughout the mid-and upper-Columbia region (Mullan et al. 1992a, Chapter 2) affirm Chapman that more is better only up to the MSY level of escapement.

Carlson (1996) states, "people throughout the ages have thought that the fishing in earlier times was better than in their present day." New England biologists across several states and jurisdictions were not immune to romantic fantasy and collectively built a grand habitat-based program to recover Atlantic salmon runs to rival historical runs purportedly so prodigious that they overturned small boats in rivers. Archaeologists puzzled over the discrepancy between the near absence of salmon bones in Indian middens across New England and the claims of once great runs. In the final analysis Carson's studied conclusion was "likely the romantic folklore of once vast salmon runs is legend, a tall fish tale that has influenced all thinking about salmon in this century." Remediation programs in New England have generally failed because habitat degradation was not the primary limiting factor in most streams. Salmon are rare in most New England waters because the streams are too warm. Restoration biologists missed the obvious by neglecting to critically assess the primary historical documents of abundance and to assess the most basic of habitat attributes-temperature.

Habitat limiting factors

The authors of Chapter 22 assert that irrigation limits bull trout in the upper Columbia region, however the historical context showing the number of ditches in the Methow decreasing substantially over time from the disappearance of hundreds of acres of orchards and the lapse of the water right granted the defunct lumber mill at Twisp are not acknowledged. The smoking gun of dead fish below the Peshastin Irrigation Dam is sophistic because no mention is made of USFWS' trucking of several hundred adult spring chinook from Leavenworth Federal Hatchery to Peshastin Creek to spawn naturally. The pre-spawning mortality for spring chinook is about 18 % (Chapman et al. 1995), which means that 90 fish out of 500 trucked fish would be expected to die naturally before spawning. Since chinook salmon die after spawning and generally drift downstream their collection at the screen in the forebay of the dam where fish are prone to lodge is expected. The presence of a single bull trout and steelhead cadaver at the screens prove that these fish successfully passed the dam, contradicting many officials who incorrectly claim the dam is impassable to bull trout and spring chinook (e.g., USFS 1999, WSCC 2001). The highest standing crop of salmonids found anywhere in of the upper Columbia streams was Peshastin Creek above the Tandy Diversion and lower Ingalls Creek (Mullan et al. 1992a), a point sustained by Ringel (1997). Until the cause and location of death is determined for fish collecting in the forebay, the Peshastin Diversion Facility can hardly be held culpable any more than Wells Dam can be blamed for retaining the body of a man killed in a boating accident upriver three days prior.

The authors erroneously claim that dewatering terminates all fish migrations in late summer and fall. First, the irrigation season concludes by October 1 which hardy constitutes the fall season. Secondly, what fish are migrating during late summer? Spring chinook and bull trout are spawning or about to spawn then, but they are not migrating. The vast majority of bull trout pass the Chiwawa trapping weir by July (pers. comm. Mike Tonseth) when flows are still high in Peshastin Creek. The transfer of spring chinook adults from Leavenworth Hatchery to Peshastin Creek occurs in early July, meaning the migration occurs in prodigious flows immediately after spring runoff in June and July.

The timing of chinooks and bull trout when flows are high expose the folly of professional judgment (emotional reflex of seeing low flows in September) behind the contention that reduced flows from irrigation withdrawal block migration to and from spawning habitats. The authors of the Plan did not and cannot produce a single factual or even anecdotal scintilla of evidence that irrigation diversions are blocking fish. In the 1950s healthy, self-sustaining spring chinook salmon runs in the Methow River had recovered from alarming lows of the late 19th century. Yet the MVID diversion dam on the lower Twisp, usually considered the worst case to show migration blockage, was operating by the 1930s and did not hinder the Twisp population from becoming the second best population (Chewuch first) in the Methow, including the Methow mainstem (French and Wahle 1965). And if all those Methow diversions, outdated screens, and water deletions are so destructive then why was the Methow producing 60% of the spring chinook over Rock Island Dam and 10,000 spawners in 1958 at peak irrigation withdrawal and before meaningful hatchery supplementation (French and Wahle 1965)?

What culverts block bull trout migrations to and from their headwater spawning sites? The answer is none, including the ones in the East Fork Buttermilk Creek and Beaver Creek.


Three of four American Fisheries Society (AFS) reviewers were critical of the Mullan Report overall, yet if one examines their specific comments about irrigation recharge-the crucial issue harpooning the NMFS recovery plan-it's clear the concept was seminal to them and their silence or reeling comments were tacit signs of confirmation. Nevertheless, the NMFS officials defended their denial of irrigation recharge by diverting criticism to irrelevant sections of the report-throwing the baby out with the wash. Local restoration authorities including the authors of Chapter 22 embargo not only the Mullan Report but others with offending heresy such as McIntosh et al. (1994) and Chapman et al. (1995) to name two. Not only is dissenting science suppressed or denounced, they stifled new research. Embarrassingly, it was the private sector of the Methow Basin Planning Unit, which overcame institutional foot-dragging to contract the USGS to study irrigation recharge.

The assertion that irrigation reduces flow (except at the immediate vicinity of the point of diversion) is an unsupportable platitude, which is why the concept of irrigation recharge is so vehemently attacked or ignored. There is a mountain of incontrovertible information available inside and outside the region. Hydrographs dating back to 1902 at Pateros long before peak irrigation show that flows have actually increased in the winter and declined only slightly in the summer (likely an artifact due to the wet climatic period of that time) (Walters and Nassar 1974). In the Methow the benefit of irrigation recharge was recognized as early as 1919 (Chase 1919). During the adjudication of Beaver Creek, where the state hydrologist testified that irrigation seepage back into the stream channel double surface flow, prompting him to recommend that irrigators maximize irrigation in the spring and early summer to sustain water supplies in late summer (Chase 1919). The Department of Ecology (DOE) recognized the concept in their findings (Walter and Nassar 1974, Kauffman and Bucknell 1976), though they did not understand its biological significance. Mullan et al. (1992a) showed that the percentage of low flow (7-day average, 2 year frequency) of the mean annual flow was no greater for irrigated streams than streams without irrigation. Every practicing well driller and hydrologist operating in the Methow takes irrigation recharge for granted. Considering the close proximity to the Columbia Basin and one of the planet's most resplendent transformations of barren desert to verdant oasis via leaking irrigation systems it's inconceivable that the dots go unconnected.

Dramatic visual evidence is now available in the Methow courtesy of the NMFS who forced abandonment of the Patterson Ditch in favor in of a leak-free pipe. The result was immediate and dramatic-Big and Little Twin Lakes water levels began a sharp decline, which is reducing the water-table and the amount of water discharging back into the Methow. They call it conservation because it takes less water to fill the pipe than the ditch, but where is the conservation in allowing the surplus water of spring runoff to race off to the Pacific when it could be stored in recharged aquifers that drain back into the rivers during the late summer. There is a grand opportunity to work with irrigators to boost late summer flows-flood irrigate in open ditches in the spring and go to pipes in the summer-but the institutions are blowing it. The emptying of Methow aquifers in the name of salmon recovery will become a legacy of infamy.

The authors of Chapter 22 must answer that if irrigation is limiting fish why did the Methow during the 1950s produce a greater percentage (60%) of spring chinook than the Wenatchee and Entiat River combined, both of which have much less water diverted for irrigation (French and Wahle 1965)? Why were salmon and steelhead runs in this time frame-before the dams and hatcheries-healthy and self-sustaining (Mullan et al. 1992a, Chapman et al. 1995)? Why were the mean standing crops of juvenile anadromous salmonids throughout the upper-Columbia region streams during the current era essentially the same as the mean of other streams reported elsewhere in the this ecoregion (Pacific Forest Ecoregion) (Mullan et al. 1992a)? Why is the Lemhi River, a small river (2/3 the size of the Methow) in central Idaho (above 8 Columbia and Snake River dams) and subjected to an irrigation diversion rate three-fold greater than the Methow's (Donato 1998) supporting healthier populations of wild, non-supplemented steelhead and spring chinook salmon. Moreover, why is the status of Lemhi salmon/steelhead better than nearby Middle Fork Salmon River, which drains a portion of the fabled and pristine River of No Return Wilderness? The response by the local fish biologist to my query for explaining how fish runs in a severely irrigated river could outperform those from a stream with no human perturbations was groundwater (pers. comm. Tom Curet).

Therein lies perhaps a greater benefit to fish than mere volume of flow-water quality. Groundwater is colder and richer than surface water, and the benefits are critical in winter freezing as well as summer burning. The nexus between groundwater and salmonid abundance is well known among fisheries biologist (e.g., Hendrickson and Doonan 1972, White et al. 1976, Meisner et al. 1988). In fact Meisner et al. (1988) argues that groundwater will be the single most important habitat feature that determines the persistence of salmonids if climatic warming continues. Bartholow (1989) opined that it may be preferable on very hot days to actually reduce flows in order to protect cool-water refuges for salmonids. The NMFS goal of converting open ditches into pressurized systems harbors great risk because they have neglected water quality. Buell (1998) says it best, "the upshot of this is that warm surface supplies would replace the current cold groundwater supplies, and we have a very high risk of producing miles of good sucker habitat at the expense of resident and anadromous salmonids."

At least in one instance (Entiat R.) the authors of Chapter 22 rely of 303 (d) as a benchmark for thermal status, an approach that I see more and more and one that is troubling. The setting of 303 (d) temperatures was an arbitrary judgment call. The hope that a single temperature could define a very diverse group of waters within a single category is the height of credulity. More farcical is the notion that one temperature can meet thermal needs for all life stages of all species. For Class AA streams the magic 303 (d) temperature is 61o F, a temperature too warm for spawning and natal rearing and cooler than the maxima for subadult rearing, especially when diurnal cooling occurs. Bull trout routinely withstand 70o F plus temperatures when maturing or on spawning migrations (Brown 1994). Mullan et al. (1992a) found a large, maturing bull trout in the lower Methow in August when temperatures seasonally exceed 70o F. In the Wenatchee basin the only Class AA streams that don't exceed the 303 (d) standard are the White and Chiwawa Rivers, which are relatively high elevation waters headed with glaciers. Nason Creek is one of the top producers of spring chinook in the Wenatchee basin, yet it violates the 303 (d) standard every summer (WRWAP 1998). Nason Creek is not a prime bull trout stream not because it violates 303 (d) but because it has insufficiently cold water for spawning and natal rearing. If exceeding 303 (d) is cause from irrigation as implied for the Entiat, where the maximum irrigation withdrawal of water at low flow in September is only 9 %, then why are maximum temperatures there slightly warmer than the Methow, where up to 79% of the low flow is diverted for irrigation (Mullan et al.1992a)? Why are maximum temperatures in the lower Mad River above all irrigation just as warm or higher than the Entiat (Mullan et al. (1992a)? And finally, the Entiat River upstream (RM 25.2) above all irrigation exceeds 303 (d) every summer, proving the arbitrary nature of 303 (d). For all the reasons above Class A streams are just as productive as Class AA waters for anadromous species and bull trout after bull trout smolts journey out of the headwaters (Welch and Perkins 1978).

Interestingly, there is no 303 (d) minimum standard for temperature, which assumes that cold temperatures are not affected by man and don't have any bearing on cold-blooded fish, a preposterous assumption since cold reduces growth and survival and determines freshwater ecotype or even anadromy. The implied preference, then, is for the ice-water that produces those 6 inch cutthroats in 13 years in the headwaters of Wolf Creek over the warmer water in the Methow at the mouth of Wolf Creek, which might spike above some meaningless temperature standard for a few hours, that produces spring chinook and steelhead smolts in 1 or 2 years.

The focus on low flow in the irrigation season is unwarranted because flows generally are lower in the winter after irrigation. Again, the Pollyanna paradigm that low flows in the winter don't count because they are natural isn't supported by the literature or critical analysis. The most limiting time for salmonids in upper Columbia streams is winter not late summer. This region is the coldest of 24 climate zones in the coterminous U.S (Mullan et al. 1992a). On many years arctic air masses trapped in valley bottoms (inversions) quick-freeze the streams covering the bottoms with frazile ice then freezing the surface with thick ice. When the cold is abruptly scoured out by warm southwest winds the ice breaks up and flow en mass downriver. At constricted points ice dams form until the building pressure of impounded water and ice blows them out, sending high speed mini-glaciers bulldozing downstream, ripping open streambanks, carrying away any vestiges of wood, and scouring the streambed. Tuttle (1948) witnessed moving ice jams dredge out 12 inches or more of gravel in lower Nason Creek, and felt spring chinook eggs and fry experienced considerable loss.

Universally, winter losses average about 50% for stream salmonids, and there has been a growing awareness that winter is the bottleneck for production (e.g. Hunt 1969, Hawthorne and Butler 1979, Seelbach 1986, and Griffith 1987). Scarnecchia and Bergemson (1987) found much lower salmonid standing crops than predicted by models in cold streams, otherwise rated as excellent habitat.


The Plan again fails to assess this parameter with balance and rigor. The authors of Chapter 22 carelessly misrepresent Mullan et al. (1992a). That report does not claim that 60% of the Methow bottomlands have erosion problems from overgrazing; the claim is that of the grazing lands in the private bottomlands 60% exhibited evidence of erosion problems. Their bias is manifest when they fail to report that Mullan et al. did not believe that grazing was a significant limiting factor, but they offer no reason why they believe it is. Instead of presenting both sides, the authors slip in their own professional judgement. The rub, obviously, is that there are divergent professional opinions. Do we choose the opinions of those who did the research or those who cite the research and do so incorrectly? The authors seem willing to leap over tall buildings to connect grazing with environmental abuse. What is the background noise (historical) of natural erosion? Did Indians ponies overgraze the portions of the riparian areas (Bennett 1979)? What is meant by an erosion problem? What is the scale, i.e., 60% of what? Does the visual determination of erosion by "drive-by" assessors actually translate into sedimentation and fewer bull trout? Did the livestock cause the erosion or is it due to natural causes such as spring flooding, especially 1948 (500 year flood) and 1972 (100 year flood), or periodic ice-jam flooding? To what degree, if any, do 35 miles of bank protection (riprap) (Mullan et al. 1992a) mitigate erosion? The questions are many and complex; the answers are few, superficial, and canted.

Woody Debris

The fishery profession rightfully champions and cherishes wood. My complaint is that the dynamics of wood recruitment, placement, removal is not well understood. The notion that unless wood is strewn about in copious amounts throughout a watershed that something is wrong and man is to blame is pandemic. The AFS reviewers of Mullan et al. (1992a) took umbrage to the statement that wood accumulation is less for the upper Columbia tributary streams compared to the lowland rivers west of the Cascades, but they were wrong. There is no evidence that substantive quantities of wood ever existed in Type 4 and larger rivers in the Methow or anywhere in the inland West. Lewis and Clark navigated the Missouri from Saint Louis to the foot of the Continental Divided and never complained or even mentioned woody debris obstructing their odyssey, only rapids, falls, and shallow water. Crossing the Rocky Mt. and descending into the Clearwater basin they journaled the absence of wood. Wood was so scarce on the Snake River they stole some from the Indians to build warming-cooking fires on a cold October night. In 1883 Second Lieutenant Samuel Rodman Jr. entered the Methow from the Chillowist Trail and noted that the river was bordered by cottonwoods and the hillsides were covered by stately pines (USFS 1994). The cottonwoods remain today, but there is no wood in the river, and there never was.

Early photos dismiss the myth of verdant riparian zones (see Figures 29-32 in Mullan et al. 1992a). The prodigious photo collection of Frank Matsura shows clearly that riparian vegetation had not been altered much along the Okanogan River in the first decade of the 20th century. I have just examined (1947) aerial photos of the mainstem Methow from Mazama to Pateros, the Chewuch from Falls Creek to the mouth, and the Twisp from Little Bridge Creek to Elbow Coulee and found impoverished wood inventories during a time before intensive logging, concerted log removal to protect bridges by the Army Corps of Engineers, and the purging of wood by the 1948 flood. One of the AFS reviewers cited the removal of wood by the Corps of Engineers following the 1972 flood as proof that the basin contained more wood historically. Closer inspection reveals that the wood removal was largely confined to the bars and flood plains (Portman 2002), except for an undetermined amount from the upper Twisp and Chewuch Rivers, where wood has been accumulating since 1972 (USFS 1994). Mullan et al. (1992a) used time-lapse aerial photos to chronicle riparian habitat recovery since the 1948 flood, which had erased the post-1894 flood recovery. McIntosh et al. (1994) reported from actual field work that pieces of wood and logjams in managed (human influences) versus unmanaged reaches in the Wenatchee and Methow Rivers are not significantly different despite the inherent bias for more wood in the unmanaged reaches located further upstream where wood accumulates in greater amounts.

In the past two years I have followed roadways along portions of many rivers in the Rocky Mountains-the Clearwater, Middle and South Forks Clearwater, Lochsa, Salmon, Little Salmon, Lemhi, North and South Fork Payette, Clark Fork, Bitterroot, Beaverhead, and Greys Rivers-and none of these waters have discernable amounts of wood, even in the reaches protected from perturbation.

Why wood in those coastal streams and not inland streams? The former drain dense forests, generally have longer reaches of lower gradients, and are not bulldozed clean by ice-jam flooding. I've yet to find ice flooding mentioned as a causation agent of bank erosion and wood purging in the fishery literature. Figure 8 of Mullan et al. (1992a) sensationally displays why there is no wood and why some banks erode from no apparent cause.

Upstream the creeks are smaller (upper reaches of Type 4 or smaller streams at or near the upper terminus of anadromous zones), course at elevation through the shadows of incised canyons in boreal forests, and accumulate wood because flows in these small streams can't muster the energy and volume to flush it out. Ice flooding is absent because the streams bridge over with ice in the fall and become buried under insulating snow protecting them from Arctic air. During the spring awakening the snow and ice thaw incrementally, allowing some streams to stockpile impressive loads of wood. Bull trout spawning/natal rearing reaches are located in these benign winter habitats on U.S. Forest Service land, which have been altered only slightly except for a few minor exceptions, such as Blue Buck Creek (logging) in the Methow basin. This means there is little opportunity to increase wood in significant amounts. Fussing over shoreline trees downstream in the mainstems where natural processes prohibit recruitment is academic. Moreover, living in wood in the winter is suicidal, and the only way to avoid being ground into fish slurry is to disappear into the cracks of rocks, which leads to the next subject.

Bank Protection (Dikes and Riprap)

The primacy of rocks for fluvial salmonids has been glossed over in favor of the easy-to-comprehend and highly visible wood. Research showing huge densities of salmonids in wood-rich versus wood-scarce sites with fine sediment substrates (no cobble or boulders) does not imply that wood-scarce sites with rocky substrates harbor fewer fish. The densities of fish in rocky sites is often profoundly underestimated because biologists can't see the fish hidden in the cracks, which leads them to the false conclusion that rocky substrates are inferior. Hillman et al. (1992) found in local streams that at or below 57oF visual observation (snorkel) could only account for half of the fish actually present as determined by sodium cyanide use. At 48oF virtually no fish are visible during the day. The most abundant species of fish in the mainstems of upper Columbia tributary streams is the longnose dace, a species unknown to most biologists because they live wholly secrete lives in rock interstices and are not catchable by hook and line.

Mullan et al. (1992a) conducted 184 standing crop estimates throughout upper Columbia streams in diverse habitats and found rock riprap to be a critical summer and winter habitat. Hillman et al. (1989a,b) stressed the importance of riprap as winter habitat in the Wenatchee basin. The greatest density of salmonids in the Methow above Winthrop was found in the riprap dike behind Winthrop Federal Hatchery (Fig. 33 in Mullan et al. 1992a), one of the dikes recommended for possible removal for improving fish habitat (WSCC 2000). The healthiest bull trout population in the Methow is found in the Lost River Canyon that has talus rock slopes extending into the water throughout. Most of the headwater streams supporting bull trout have large angular rock for banks. Restoration biologists have rejected reams of powerful empirical data linking high densities of salmonids with riprap in favor of professional opinion. The 35 miles of riprap protecting streambanks in the Methow should be considered habitat improvements for the most part.

I conclude my comments about habitat with a word about perspective. Smolt production of bull trout is so limited because of the tiny physical size of the spawning/natal rearing areas. Once smolts exit downstream they enter a vast world of unlimited habitat. All that standing crop work performed by Mullan et al. (1992a) showed exceedingly low numbers of bull trout outside their natal concentrations in the headwaters. Competition with other bull trout is non-existent, and each fish has its choice of optimum habitat. For this reason, the whole question of habitat productivity and availability as a limiting factors becomes academic.

Fishery harvest

The public acrimony against bull trout from preying on salmon has not survived. I knew a fishing guide, deceased for many years now, who went out of his way to take clients up the West Fork Methow to catch and kill migratory bull trout. The liberal fisheries are now history. In my opinion the single most man-caused limiting factor for bull trout by far was the incidental mortality incurred by bull trout in the mainstems reaches by intensive steelhead fisheries allowing bait. Even when bull trout were protected from harvest hooking mortality was high, especially by anglers using fresh steelhead eggs. Steelheaders told me of releasing deeply hooked bull trout bleeding profusely. When the steelhead fishery was terminated in 1997 an immediate (1998) increase in the number of redds occurred in some Methow streams. Since bait never again will be legalized in the upper Columbia tributary streams and steelhead fisheries will be authorized only on bumper years, the harvest rate will surely remain low, lower than the optimum (MSY) rate. Yes there will be some hooking mortality in the Columbia River, Lake Wenatchee, the Methow summer trout fishery, and the winter whitefish fisheries, but these rates are much lower than those of the past and certainly less than optimum for bull trout.

The effort to maximize spawning escapements defies stock-recruitment principles, meaning that bull trout abundance will stabilize or even decline in some waters at some point below its maximum potential. Panther Creek redd trend seems to illustrate my point. Spawners have not increased over time but the number of harvested fish has decreased, meaning the overall population has declined as it must. But because the plan lacks stock-recruitment savvy and centers on habitat degradation, my guess is that instead of optimizing the harvest rate even more stringent restrictions will be imposed, e.g., closing the Lake Wenatchee fishery. Both the NMFS and USFWS are re-inventing the wheel.

Quick-fix recovery and philosophical harmony

As I mentioned above the salvation for bull trout given climatic warming is via translocation to isolated environments-above barriers or in alpine lakes. The model for remediation is the westslope cutthroat (O. lewisi) model (Williams 1999). The only verifiable population of lewisi in eastern Washington below Grand Coulee Dam was the lake Chelan population. The cause for this paucity was natural-Onchorynchid usurpation. This population was extirpated in the 1950s but they abound today because the first trout hatchery in Washington began taking lewisi eggs at Stehekin in 1903 and outplanting them into hundreds of streams and alpine lakes throughout Washington, including western Washington outside of their historical range. Just in eastern Washington the number of lakes containing self-sustaining populations jumped from 1 to 311; the number of streams and stream miles increased from 101 and 321 (Pend Oreille county) to 493 and 1,509, respectively. The same kind of spectacular increase for bull trout is possible. Many lakes containing stunted populations of over-reproducing lewisi would benefit from bull trout predation. Given the ease in which bull trout may be increased, the doomsday rhetoric is mostly hyperbole.

Some have condemned the artificial lewisi sprawl on the basis that translocations were made to historically fish-less waters and that fish threaten indigenous invertebrate species. If the philosophical doctrine is deference to natural processes, then recovering a species that Mother Nature has slated for extinction is arrant contradiction. Since extinction is a by-product of evolution and a host of other biological, chemical, and physical forces, one is not surprised that mostly natural processes have extirpated about 95% of all of the species that ever existed (UNEP 1995) or that the destiny of every living species is extinction (Botkin and Keller 1998). Ceding that extinction can be natural is virtually impossible today, given that clarion, politically titillating cry-extinction is not an option. Connecting extinction to habitat pillage is the sneaky but effective method to have your cake and eat it too. The public is catching on to the ploy of controlling landscapes with the ESA (McDonald 2000). In order to remove any hint of impropriety, the USFWS must build a stronger case that status is indeed human caused. The litany of more-information-is-needed statements sprinkling the pages of Chapter 22 and the heavy reliance on professional opinion are clear indications that cause and effect understanding is inadequate and the Plan is pre-mature.


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 plan professional judgment is used in lieu of or even in preference to science, as if interchangeable. Contrary empirical evidence is routinely ignored in favor of professional opinion by authors with dubious qualifications. The Mullan Report, for example, was reduced to a few citations that were useful to the authors, but much of the empirical evidence was ignored. Professional opinion in many cases was used as evidence for more professional opinion, building what amounts to a house of cards. For example, the Washington State Conservation Commission reports, which were little more than polling of spontaneous professional opinions from personnel not intimately involved with the report, were cited many times because those reports espoused the correct answers. The authors of the Plan must go back and collate all of the relevant literature-pro and con-to qualify as serious science.

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, blind-spots, and even venality. Recall that it was the unsolicited review of archaeologists that exposed the chinks in the Atlantic Salmon recovery effort. Closer to home, independent reviewers representing the National Academy Sciences contracted by the federal government illuminated the institutional bias fomented by a coalition of institutions and tribes attempting to recover Klamath River fishes. Independent, interdisciplinary review by reputable scientists working outside of provincial purview is mandatory for achieving tour de force science, which must be the goal of every recovery plan. Rightfully the local institutions have worn out the Mullan Report reviewing and re-viewing it, which is precisely the model for this tome.

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 of-irrefutability may seem like a virtue, but in reality it is a vice. In other words a rule that has an answer for everything really answers nothing. Michael Polanyi insightfully averred that society gives meaning to science rather than science giving meaning to society. In this context we are not dumbfounded when the Director of 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 rather geographical control (McDonald (2000).

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 that this plan is too idealistic, simplistic, and incomplete to serve bull trout and to justify promulgating changes of current human practices.

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 steelhead. The status and recovery is predicated on the diminution of bull trout via human actions, but neither the diminution or the actions have been determined with any degree of reliability. The linchpin of risk analysis is not based on range and abundance declines but rather "backdoor" approaches-whimsical genetic theory and speculated habitat degradation. There is no compelling evidence for extinction, apart from future climatic warming. All of the populations are self-sustaining and occupy their pre-anglo historical range except the Lake Chelan population, one (possibly two) very small populations in the Methow and one small population in the Okanogan. In all cases where populations have disappeared the blame, ironically, lies squarely on the institutions for stocking incompatible species of fish or constructing impassable dams (Icicle Creek). Despite all of the rhetoric there is no scientifically demonstrated nexus between agricultural practices and bull trout abundance. In fact, a stronger case can be made that agriculture has improved habitat via riprap and irrigation recharge.

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Act and geographic control in the Methow Valley, WA. Ph.D. Thesis, Univ. of
WA, Seattle, WA

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study of the water and related land resources. PNRBC Comm., Vancouver, WA.

Portman, S. 2002. The smiling country: a history of the Methow Valley. Sun Mountain
Resorts, Inc., Winthrop, WA.

Ringel, B. K. 1997. Analysis of fish populations in Icicle Creek, Trout Creek, Jack
Creek, Peshastin Creek, Ingalls Creek, and Negro Creek, Washington 1994 and
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populations. Fish. Res. Bd. of Can. Bul. 191.

Scarnecchia, D.L. and E.P. Bergerson. 1987. Trout production and standing crop in
Colorado's small streams, as related to environmental features. N. Am. J. Fish.
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Seelbach, P.W. 1986. Population biology of steelhead in the Little Manistee River,
Michigan, Ph.D. Thesis, Univ. of Michigan, Ann Arbor, MI.

Tonseth, M. 2002. Personal communication. Fish biologist for the WDFW, Wenatchee,

Tuttle, E.M. 1948. Annual report, calendar year 1947, Leavenworth Washington station.
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USFS (U.S. Forest Service). 1994. Chewuch River Watershed Analysis. Okanogan
National Forest, Okanogan, WA.

USFS (U. S. Forest Service). 1999. Peshastin Watershed Analysis. Wenatchee National
Forest, Wenatchee, WA.

Walters, K.L. and E.G. Nassar. 1974. Water in the Methow River basin, Washington.
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White, R.J., E.A. Hansen, and G.R. Alexander. 1976. Relationship of trout abundance to
stream flow in midwestern streams. pp. 597-615. In Proc. Symp. and Specialty
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White, R.J. 1986. Physical and biological aspects of stream habitat management for
fish: the primacy of hiding/security cover. pp. 241-265. In Proc. Fifth Trout
Stream Habitat Improvement Workshop, Lock Haven Univ., PA.

Williams, K.R. 2001. Redd count trends of spring chinook salmon in the Methow River.
Unpublished Rept. Prepared for the Methow Basin Planning Unit.

WRWAP (Wenatchee River Watershed Plan). 1998. A plan containing nonpoint
pollution source control and implementation strategies. Chelan County
Conservation Distritct, Wenatchee, WA.

WSCC (Washington State Conservation Commission). 2000. Salmon and steelhead
habitat limiting factors (Water Resource Inventory Area 48-Methow
Watershed). Prepared by C. Andonaegui

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