(1) Adequate protection of the species under other laws, including the federal endangered species listings,

(2) Failure to consider the severe economic impact of a state coho listing;

(3) Failure to consider substantial third-party research on coho status by scientists such as Dr. Charles Hanson; and

(4) A substantial history of voluntary conservation measures that have been effective in addressing habitat issues.

In addition to the federal Endangered Species Act, several laws already provide protections for coho. These include:

(1) The federal Clean Water Act and state Porter-Cologne Clean Water Act that require the establishment of Total Maximum Daily Loads (TMDL’s) for factors affecting salmon, such as water temperature, low dissolved oxygen and sediment.

(2) The Anadromous Fish Conservation Act and the California Keene-Nielsen Fisheries Restoration Act.

(3) The National Environmental Policy Act (NEPA) and California Environmental Quality Act (CEQA) that invite public input in identifying and mitigating the environmental impacts of proposed land use projects.

(4) The Z’berg-Nejedly Forest Practice Act (Forest Practice Rules;) and

(5) The state coho recovery plan, including the Shasta and Scott coho recovery plan, already in place.

Past columns and news articles have indicated the substantial impact that the coho listing will have on local agricultural operations in the Scott and Shasta Valleys. In addition to the Incidental Take Permit (ITP) process, water diverters will have to negotiate 1602 agreements with the Department of Fish and Game (DFG.) Even with the efforts to design "programmatic" permits on a watershed basis to lessen the impact, the costs and minimization and mitigation requirements can be a tremendous burden on small family operations.

The California Forestry Association estimates that the new regulations expected to accompany the listing will cost forest land managers more than $30 million annually. This is on top of the more than $100 million land managers continue to spend on both voluntary and cooperative restoration efforts as well as nearly $20 million in annual costs and permit fees for timber harvest plans.

SOSS (Save our Shasta and Scott Valleys and towns) was among organizations that supported the work of Charles Hanson. PhD. in reviewing the body of information on coho in California. Hanson concluded that the California Fish and Game Commission and the DFG had failed to take into consideration all of the available information. In addition, there is insufficient population data and information on trend to establish the necessity for listing.