In presentations to the Commission, WDFW indicated that the Dec. 1 plan exceeded NOAA's rebuilding exploitation rates (RER) for all P.S. Chinook populations except for the N.F. Stilly. There is no way NOAA can approve and hope to defend a plan in federal court that exceeds its RERs for all but one population.

(RERs are the maximum exploitation rates that populations can withstand without adding risk to their survival or rebuilding according to NOAA's calculations. Salmo g or others with more technical knowledge can probably explain this better.)

Evidently, there is some additional technical work that needs to be done to square NOAA's RFRs (which I understand are based on coded wire tag data used by the PST Chinook technical committee) with the exploitation rates used in the Dec. 1 plan (which I understand are based on the FRAM model used by WDFW and the Tribes).

I think the RER issue is going to be a key one, not only for the P.S. plan, but also in PST negotiations.