OC's Comment on 90-day Finding on a Petition to List Chinook Salmon in the Upper Klamath-Trinity Rivers Basin

Recently published data demonstrates that NMFS’ rationale for denying the previous petition was based on a misunderstanding of the underlying genetic mechanisms which give rise to the ‘premature migration’ fish. This new information published in a peer reviewed journal, scientifically establishes the genetic uniqueness of KTS Chinook and refutes NMFS’ prior assertion that the spring run life history is the result of polyphyletic pattern evolutionary history.[1][1] Prince et al. 2017. The evolutionary basis of premature migration in Pacific salmon highlights the utility of genomics for informing conservation.Although not currently a major food source, the Klamath River, historically was the third or fourth most important river to the Southern Resident killer whale (SRKW), and should continue to be what historically was a vital component contributing to SRKW calf survival.