Sam Wright, who has been remarkably successful in getting various fish species protected under the Endangered Species Act, has learned that his latest ESA petition — possibly his final petition — has been rejected.

Sam, who retired from the Washington Department of Fish and Wildlife after years of studying salmon and other fish, would like to get special recognition for a unique population of chum salmon that return to South Puget Sound in the winter.

The Nisqually-Chambers Creek run of winter chum is the only population of chum salmon in the world that spawn as late as February, with some fish entirely missing the worst floods of December and January, Sam told me. His petition to the federal government was designed to get these winter chum recognized as a distinct population segment — much as the threatened summer chum population in Hood Canal has been designated as separate from the fall runs of chum throughout Puget Sound.

Being a small population, the Nisqually-Chambers Creek winter chum would probably qualify for threatened or endangered status, he said, but first it would need to be recognized as distinct. If not listed initially as threatened or endangered, those decisions could follow if the population crashes, he said.

“The petition was meant to correct what was, from my perspective, a mistake made 20 years ago when they made a coastwise series of reports assessing the chum salmon populations,” said Sam, who is now 81 years old.

“In the entire range of chum salmon — both in North America and Asia — there are 3,500 streams with chum salmon,” he continued, “but there is only one single winter-run chum salmon, and that is the Nisqually.”

Sam’s petition (PDF 4.2 mb), filed more than two years ago, was subject to a 90-day review by the National Marine Fisheries Service, also known as NOAA Fisheries. Sam was told that the petition had been misplaced all this time. Last week, he got the news that the Nisqually-Chambers Creek winter chum would not be recognized as a distinct population, nor would it be considered for further review without new information being brought forward.

In rejecting Sam’s petition, NOAA’s Northwest Fisheries Science Center reviewed available data — including a 2015 genetic study on chum populations — and concluded that the original analysis done in 1997 was still valid. That analysis concluded that the winter-run chum are closely related to the fall-run chum in Puget Sound and Hood Canal and that “there is no clear genetic evidence to support the idea that the winter-run chum salmon in Puget Sound are substantially reproductively isolated from other chum salmon populations in southern Puget Sound.” See “Listing Endangered or Threatened Species …”

Sam argues that the winter chum remain genetically isolated from fall chum populations because of their unusual spawning schedule. That is demonstrated by annual population counts, which go up and down independently of fall chum numbers in South Puget Sound.

“They are reacting to different environmental conditions,” Sam explained.

Studies are needed to show the differences, Sam said, but they may have an advantage over fall chum by avoiding most of the winter floods, which can displace salmon eggs incubating in the gravel or else smother them in silt.

Incubation time is based on temperature, so the late-arriving chum are subject to warmer water and faster incubation. The winter chum fry are only a little behind the fall chum fry, Sam said.

One of the most productive areas for winter chum is Muck Creek, a tributary of the Nisqually River that runs through Joint Base Lewis McCord, where the Army conducts military exercises, according to Sam.

“We’ve had decades of battles with Fort Lewis over whether to use Muck Creek as part of their firing range,” Sam told me, adding that he suspects that pressure from the military played a role in NOAA’s original decision to lump the winter chum together with the fall chum.

Personally, I don’t know anything about such conflicts, but Muck Creek has been the site of a major restoration effort involving JBLM, the Nisqually Tribe and other groups. In 2011, reporter Ingrid Barrentine wrote about the annual salmon homecoming for Northwest Guardian, a JBLM publication.

As for the habitat in Muck Creek, Sam told me something else that was surprising. The stream is spring-fed with freshwater bubbling up from below and providing stable flows, he said. That helps the eggs to survive. Unlike many streams in which only 10 percent of the chum eggs grow into fry headed for saltwater, Muck Creek has had a 90-percent survival rate.

One reason that Sam is so concerned about the Nisqually-Chambers Creek winter chum is the uncertainty about what is coming in the future. Climate change is likely to bring higher stream flows in winter, he said, and chum runs that come later may hold the keys to survival of the species.

“To me, the last thing we want to do is throw away that particular piece,” Sam said, paraphrasing Aldo Leopold, whose exact quote is this:

“If the biota, in the course of aeons, has built something we like but do not understand, then who but a fool would discard seemingly useless parts? To keep every cog and wheel is the first precaution of intelligent tinkering.” (Round River)

Sam Wright’s persistence has paid off in the past when he has asked for reconsideration and finally received threatened or endangered status for various populations of salmon, steelhead, rockfish and other marine species. This time, he may or may not provide additional information and ask the agency to reconsider its position. In any case, Sam told me that he has no new petitions in the works, and this may be his last effort.

Whether Nisqually-Chambers Creek winter chum — or any salmon population — is considered distinct rests on NOAA’s definition of species, 16 U.S.C. 1531, which includes two criteria:

1. The population must be substantially reproductively isolated from other nonspecific population units; and
2. The population must represent an important component in the evolutionary legacy of the species.

In turning down Sam’s petition, reviewers pointed to genetic studies that supported the finding that summer chum in Hood Canal and the Strait of Juan de Fuca were distinct from other chum runs. A second grouping included the remaining fall, summer and winter runs in Puget Sound, with a third grouping of fall chum from the Strait of Juan de Fuca, the Washington Coast and Oregon.

The reviewers also pointed out that the Nisqually River and Chambers Creek to the north are not geographically isolated from the rest of South Puget Sound.

As for “evolutionary legacy,” Sam contends that loss of the winter chum would be forever, as with extinct summer chum in many river systems including Chambers Creek. That critical issue, he said, is the very definition of legacy.

The reviewers of his petition found, like the 1997 review team, that winter and summer runs in Puget Sound only showed “patterns of diversity within a relatively large and complex evolutionarily significant unit,” known as an ESU.

“Both the Nisqually River and Chambers Creek watersheds have supported both summer- and fall-run chum salmon in the past, along with winter-run chum salmon,” concluded the agency’s written findings, “so there is nothing unique preventing these watersheds from supporting multiple chum salmon runs.”

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