Requested Public Comment for Draft Recovery Plan for Southern Oregon Northern California Coast (SONCC) Coho Salmon, released by the National Marine Fisheries Service (NMFS) on January 5, 2012

May 3, 2012

We are 4 generations living in, on, and with the Klamath River directly below where Iron Gate now exists, before and after, at the focal point of dams’ impact rhetoric.  We have direct connection and documentation for our area extending prior to ‘Upper Basin Project’ and significant ‘european impact’.  Unlike many Agencies/ Special Interests that share profiting potential conflict of interest in calling for increased regulatory authority and altered/selective interpretation of regional experience and history, we benefit in no respect as a consequence of the comments we make.  We, along with many other multi-generational residents and unlike many of those special interests now involved, have sacrificed greatly throughout the century past and present to understand, preserve, protect, and enhance the unique environment we love and upon which continued quality of life depend.

Without question, the SONCC Draft exemplifies a selective and biased propensity towards a predefined outcome of regional oppression.  From the Draft described ‘historical background’, assumed causes of recent ‘decline’, Coho extent of habitat, unsupported estimates of previous numbers, estimates of prior ‘natural background conditions’, presumptive boilerplate ‘mitigations’, and current expected ‘conducive environments’, there is extremely little semblance of  accuracy to the region and history we know.

A great many of those local experiences, documentation, and current studies supporting that experience, have been repeatedly submitted to this and other cooperating Agencies, particularly Agencies such as NMFS which are also seated members of the Klamath Basin Restoration Agreement exacerbating conflict of interest, to no acknowledgement whatsoever.  That historically disparate NMFS perceptive discrepancy calls into serious question the accuracy and intent relative to the entire Draft Plan.

With past conditions and current described ‘habitats’ so far removed from local reality, as with the vast majority of Klamath upper midstem ‘coho habitat’ streams listed which have NO significant human impacts, sustainable upper refugia, or even yearly flows, there are only two inescapable conclusions possible.  Either the Agency has demonstrated complete incompetency and/or inability to effectively ‘administer’ the unique region involved, or it proves the existence of an undisclosed ulterior motive and biased agenda being pursued.  Both cases argue against the motive, right, and ability of NMFS to effectively administer, ‘regulate’, and enforce ‘policies’ known to be locally detrimental to both the environment and communities NMFS is claiming to protect.

If NMFS were actually certain of declared outcome and convinced of the benefit of their agenda, rather than simple pursuit of regulatory Agency expansion and benefit, they would NOT pursue ‘adaptive management’ policy without tangible accountability.  Rather they would accept full accountability and responsibility for mitigating ALL detrimental impacts to both the environment and citizenry for the policies they impose.

If NMFS administrators and selected ‘peer reviewers’ were subject to the same personal impacts to life and vested interests as those upon whom the drafted ‘Policies’ are so enthusiastically enforced, it is my firm belief that acknowledged draft and agenda extreme ‘uncertainties’, ‘estimates’, and  unaccountable ‘adaptive management’ would suddenly be found far less ‘scientifically acceptable’.

The discouraging countless hours to the sacrifice of individuals, families, community, and environment during nearly 20 years of locally applicable ‘Public Comment’ to Agencies including NMFS, have resulted in zero inclusion and subsequent regional detriment to all except for the cooperating creating Agencies and special interests themselves.  Defining naturally unattainable and contradicted expectations without accountability or consistency invariably anticipates ‘success’ by the forced attrition of the vested unrepresented majority.

The proposed presumptions and actions intentionally set the stage for required future regulatory expansion and funding of the very benefitting Agencies and Special Interests which authored the policies, a clear conflict of interest within the current procedures that must be addressed.

Rex Cozzalio