Letter sent on 01/29/2008 by the Salmon Protection and Watershed Network (SPAWN) and the Center for Biological Diversity on behalf of Redwood Creek coho salmon.

Steve Hampton
Oil Spill Response and Recovery, Department of Fish and Game
1700 K Street, Suite 250 Sacramento, CA 95811

Greg Baker
National Oceanic and Atmospheric Administration
USGS, 345 Middlefield Road, m.s. 999, Menlo Park, CA 94025

Al Donner
Fish and Wildlife Service
2800 Cottage Way, Room W-2605, Sacramento, CA 95825

29 January 2008

Dear Sirs:

We understand that the Office of Spill Prevention and Recovery and NOAA are currently compiling statistics for lost wildlife to be included in damage assessments for the November 7th, 2007, Cosco Busan oil spill.

Any such assessment should include the potential loss of the 2007/08 year-class of Redwood Creek coho salmon, a population within the Central California Coast Evolutionarily Significant Unit that is listed as “endangered” at both the federal and State level.

The Redwood Creek coho salmon run comes in from the Pacific Ocean at Muir Beach in Marin County and is closely monitored each year by biologists from the National Park Service. Redwood Creek coho congregate off Muir Beach at the start of the rainy season waiting for seasonal rains to break the berm at Muir Beach so they can begin their upstream migration. On the date of the oil spill, November 7th, 2007, that berm had not yet broken. Thus the fish were likely directly offshore — and may have been in the path of the oil that affected coastal Marin and particularly Muir Beach.

To date, during this spawning season of winter 2007/08, no coho salmon have been observed spawning in Redwood Creek. This may be the first time since the National Park Service began inventorying salmon in this watershed in 1997/98 that no coho spawning has been documented here. Smolt production estimates from this year-class in Redwood Creek during spring of 2006 were 3,253 +/- 542 fish (Adult Escapement Monitoring Program Summary 2006-2007, National Park Service, San Francisco Bay Area Network. Prepared for California Department of Fish and Game Contract P0560415). Based on the lowest published ocean survival rates for this region, in the 3% range, we would expect a return of approximately 81- 113 adults spawners. Other coho streams above the spill zone (Pine Gulch, Lagunitas, Olema) had coho spawning this year, although those runs, too, were lower than average. For comparison, returns to neighboring Marin creeks such as Lagunitas and San Geronimo this year indicated about a 4% ocean survival rate. Pine Gulch to date yields just over 1%, and returns from Olema Creek are <1%. Reports from Mendocino County this year indicate a return rate also < 1%. Even given a 1% return rate for Redwood Creek we would still have expected that 27- 38 fish would have returned to Redwood Creek to spawn.

While background ocean conditions cannot be completely ruled out as the cause of the loss of this year-class, the location of the oil spill along the Marin Coast, particulary in the Muir Beach area, and subsequent complete absence of coho from the Redwood Creek Watershed this year suggest that the loss of this year-class may have been the result of the oil spill and should be thoroughly investigated.

The Redwood Creek population of coho salmon holds unique ecological and scientific value since they are a wild run of genetically distinct fish. Accordingly, we are of the opinion that it is imperative that the damage assessment and claims made for lost wildlife including funding to support rigorous monitoring by the National Park Service of this year-class of coho salmon, as well as for a potential re-introduction program if spring and summer surveys do not yield observations of juveniles.


Todd Steiner, Director, Salmon Protection and Watershed Network

Paola Bouley, Watershed Biologist, Salmon Protection and Watershed Network

Jeff Miller. Conservation Adocate, Center for Biological Diversity

Candace Hale, Member, Salmon Protection and Watershed Network