Northwest Power and Conservation Council Comments


Dear Mr. Bill Bradbury, Chairman

NW Power and Conservation Council
851 S.W. Sixth Avenue
Suite 1100
Portland, Oregon 97204-1348

The Native Fish Society and the Wild Steelhead Coalition appreciate the opportunity to participate in developing amendments for the Council’s Fish and Wildlife Program. We submit these proposed amendments in the sincere hope that they will assist the Council in providing conservation and recovery for Columbia River basin wild salmonids.


Bill Bakke, Conservation and Science Director, Native Fish Society

Bob Margolis, Executive Director, Wild Steelhead Coalition

Include recommendations of the ISAB in adoption of a new Fish and Wildlife Program:
The Native Fish Society and the Wild Steelhead Coalition recommend the following amendments for the Fish and Wildlife Program of the Power Planning and Conservation Council and request that the recommendations provided the Council by the Independent Scientific Advisory Board (ISAB), in their review of the 2009 Fish and Wildlife Program, be included in creating a new Fish and Wildlife Program for the Columbia River basin.

It is unlikely that the scope, competence and scientific rigor provided to the Council by the ISAB in their review and recommendations for improving the Fish and Wildlife Program could be duplicated by the public, so we are submitting the ISAB recommendations to the Council for adoption by reference.

We have also borrowed recommendations from the ISAB review of the 2009 Fish and Wildlife Program in forming our own recommendations, so there will be some level of duplication. In addition, the Native Fish Society and the Wild Steelhead Coalition has provided additional amendment proposals for adoption by the Council.

Important Issues Relating to the Fish and Wildlife Program that need to be addressed by amendments to the Council Fish and Wildlife Program:

1. The 1994 Fish and Wildlife program was reviewed by Lichatowich and Williams (2009). The conclusion of this review points out that the Council’s goal to double the runs has not been achieved and that science has not been effectively integrated into the development and implementation of the fish and wildlife program. “Following its review of the Pacific salmon crisis in 1996, the National Research Council concluded, ‘The current set of insti¬tutional arrangements is not appropriate to the bioregional requirements of salmon and their ecosystems,’ and that, ‘the current set of institutional arrangements contributes to the decline of salmon and cannot halt the de-cline’ (NRC 1996). ‘The Snake River Salmon Recovery Team (SRSRT 1994) linked the fragmented institu¬tional structure to the failure to incorporate the best science into salmon recovery programs in the Columbia Basin. In its final recommendations on recovery of salmon populations in the Snake River, the SRSRT characterized the situation as ‘… jurisdictional chaos, no one in charge, important decisions not based on science, and stifled science.” (Lichatowich and Williams 2009) These assessments regarding the fractured management of Columbia River salmon follow earlier concerns by President Theodore Roosevelt (1908), the states of Oregon and Washington in the 1930s and 1940s, and The Oregon State Planning Board 1943). Action has been taken for salmon and steelhead conservation inaction by management agencies by citizen initiative petitions in the 1930s and in 1975.

“The current institutional structure stifles the incorporation of science into salmon management and recovery in two ways: 1) continued reliance on a flawed concep¬tual foundation, and 2) distribution of funds based on existing relationships rather than in accordance with science-based priorities.” (Lichatowich and Williams 2009).

The Council was formed to solve this historical problem of salmon decline, therefore, the Council should incorporate the recommendations of the ISAB and other independent science panels that provide a science based solution to wild salmon decline.

Amendment Proposal: Establish a Council subcommittee to work with the Independent Scientific Advisory Board and other science panels to establish a solution to the gap between science and policy. The outcome should be an improved integration of science into the Council’s decision making process.

2. The Council’s Fish and Wildlife Program is more concerned about the impact of actions on wild salmonids than in developing a program that is focused on actions to benefit wild salmonids. For example, using hatchery supplementation of wild salmon populations for recovery has been reviewed by the Council’s science teams and in the peer reviewed scientific literature that concludes hatchery supplementation is an action that imposes risk to wild salmonid recovery, conservation and sustainability.

Amendment Proposal: Develop and adopt an amendment category that is focused on conservation and recovery of wild salmonids including those that are threatened or endangered under the federal Endangered Species Act. These amendments and actions would be directed at providing consistency within subbasin and ESU plans with the best available science regarding harvest and hatchery impacts on wild native salmonids in each watershed; habitat agreements with land and water managers to protect, maintain and improve the life history requirements supported by subbasin habitats, and a monitoring, evaluation and research investment in each subbasin to provide the quantitative data needed to secure the productivity and diversity of native wild salmonids while providing the basis for adaptive management. This approach to providing conservation management for wild native salmonids will require a coordinated approach among the fish agency managers so that the salmon and steelhead life cycle is less fragmented by institutional issues in the Columbia River basin.

3. Conservation and recovery of wild salmonids needs to be based on a conservation requirement for each subbasin and species, including life history and genetic diversity, productivity, abundance, distribution objectives, and a monitoring, evaluation and research program to provide a quantitative assessment of objective achievement.

Amendment Proposal: The Council would develop a conservation requirement for each subbasin for each species and race of wild salmonids using it. The conservation requirement is based on an estimate of habitat capacity and managed for a spawning population that fully utilizes that habitat. Monitoring, evaluation and research refinements are used to improve management objectives related to harvest, achievement of spawner abundance objectives, life history and genetic diversity, productivity and distribution objectives in each subbasin.

The fishery agencies and the Council’s Program have not specifically addressed the actions required to recover salmonids threatened with extinction and other wild populations in the Columbia River basin. Actions taken have been to reduce impacts of on-going fishery programs such as harvest and hatchery production. Among the actions that could be taken to directly address wild salmonid recovery are:

A. Establish spawner abundance goals (escapement) for each species and race in each watershed based on an estimate of the carrying capacity of each watershed (subbasin plans). This process would be refined with additional monitoring and evaluation.

B. Determine the ecological and genetic impact on natural production of wild salmonids in each watershed from releases of hatchery fish, and stray hatchery fish. This would include impacts from hatchery releases of juvenile fish including smolts that residualize in streams and compete with wild fish for food and habitat. It would also include the impact of stray hatchery fish and residualized hatchery fish on the survival and reproductive success of wild salmonids that are spawning and rearing with hatchery fish strays. Introgression of hatchery fish and hybridization is controlled so that the reproductive success and adaptive capacity of wild salmonids is enhanced.

C. Develop a stock transfer policy that maintains the genetic integrity of wild populations and their reproductive success in each watershed (subbasin) within the Columbia River basin. Because wild salmonids are locally adapted to their home streams for reproduction, transfer of stocks from other watersheds cause wild salmonid population performance to degrade. Reproductive success of wild salmonids is also affected by stock transfers through ecological impacts related to competition, predation and predator attraction.

D. Complete a genetic and life history inventory of each wild salmonid population by watershed (subbasin) in order to establish a benchmark snap shot of wild salmonid biological diversity that could be used to evaluate harvest, hatchery and habitat management in the Columbia River basin.

E. Establish “Hatchery Free Zones” watersheds such as Wind River, Asotin Creek, Joseph Creek, John Day River, and Molalla River and implement a monitoring and evaluation of the biological response for wild native salmonid populations in these streams to provide a scientific basis for evaluating the hatchery experiment in the Columbia River Basin. Not all hatchery-free watersheds are being monitored so it is impossible to evaluate the hatchery and wild salmonid production investments in the Columbia River basin. Additional hatchery-free watersheds must be established in the Columbia River basin in each ESU, MPG, DPS, and SMU at a minimum.

F. Establish nutrient enrichment targets for watersheds from naturally spawning wild salmonid carcasses to achieve specific criteria that benefit the productivity of watersheds for salmonids, riparian areas, and wildlife.

G. Habitat protection and restoration investments would be designed to maintain the chain of habitat requirements for each species of wild salmon and steelhead to complete their life history requirements in freshwater. This would include structure, temperature, flow and retention of gravel and nutrients. To be effective this would include the entire habitat utilized by salmonids from headwater stream protection, mainstem tributaries, mainstem Columbia River, estuary and near-shore ocean habitats.

H. Manage the hatchery production in the Columbia River basin so that the nutrient budget in the tributaries, mainstem, estuary and near- shore ocean environments benefit wild salmonid recovery, and control hatchery releases so that predator attraction and predation by hatchery fish, birds and mammals no longer block wild salmonid recovery.

I. Manage for variation and biological diversity of wild salmonids rather than for stable production of a salmonid product for utilization.

J. Develop a conceptual framework for salmon and steelhead recovery based on ecosystem function, promoting sustainable wild salmonid productivity, diversity, distribution and abundance.

K. Identify and protect thermal refuge areas in the main stem Columbia and tributaries. Protection would include both the refuge areas and the sources of cool water that feed them. Develop a plan for controlling fishing in refuge areas especially during periods of high water temperatures in excess of 68 degrees F.

Thermal refuges have been identified in the Columbia River and research points out that salmon and especially summer steelhead utilize these areas of cooler water when the Columbia River temperatures increase to the high 60s and low 70s degrees F. As climate change affects flows and temperature of the Columbia and its tributaries these thermal refuge areas may become critical for the survival of hatchery and wild salmonids as they migrate to their spawning areas. Additional attention should be given to fishing in refuge areas for the fish are concentrated and more vulnerable to harvest.

4. Even though salmonids are adapted to habitat disturbance, an important ecological function, a requirement for wild salmonid sustaining ecological conditions in subbasins, mainstem and estuary habitats is needed so that salmonids are able to complete their life cycle.

Amendment Proposal: In order to accomplish this important objective, the Council would require that subbasin and fish recovery plans would include an agreement between fish management agencies and land and water management agencies and private land owners in each area affecting salmonid life cycle requirements to develop plans that effectively support salmon life history requirements. Monitoring and evaluation would be required to determine whether the investment in habitat improvement provided the target life cycle benefits, increased smolt production and increased abundance of wild salmonids.

5. Historically, wild salmonids were supported by abundant spawners providing nutrients to watersheds. Nutrient enrichment requirements need to be developed for each subbasin to support the productivity of salmonid and wildlife habitats.

“We examined the phosphorus-transport dynamics by spring/summer Chinook salmon (Oncorhynchus tshawytscha) in the Snake River basin and estimated that net phosphorus transport into the basin over the past 40 years was <2% of historical levels. Furthermore, a nonlinear relationship existed between nutrient import by adults and subsequent export by smolts, such that smolts exported proportionally more phosphorus as spawner abundance decreased. In 12% of years, smolts exported more than adults imported, resulting in a net loss of phosphorus from the ecosystem. This loss of marine subsidies may have caused a state shift in the productivity of the freshwater ecosystem, resulting in strong density-dependent survival observed in juvenile salmon. These results suggest that conserving this threatened stock of salmon requires the need to explicitly address the important role of marine-derived nutrients and energy in sustaining salmon populations.” (Scheuerell, M. D. et al. 2005)

“We have estimated the historic biomass of salmon returning to the Pacific Northwest (Washington, Oregon, Idaho, and California) to be 160-226 million kg. The number of fish now returning to these rivers has a biomass of 11.8-13.7 million kg. These numbers indicate that just 6-7% of the marine derived nitrogen and phosphorous once delivered to the rivers of the Pacific Northwest is currently reaching those streams. This nutrient deficit may be one indication of ecosystem failure that has contributed to the downward spiral of salmonid abundance and diversity in general, further diminishing the possibility of salmon population recovery to self-sustaining levels.” (Gresh et al. 2000)

Amendment Proposal: The Council establishes a nutrient enrichment standard based on the available scientific research for each watershed that is supported by naturally spawning wild salmonids and other fish species. The nutrient enrichment standard is evaluated through monitoring to maximize stream productivity. Habitat improvement projects would be designed to retain nutrients in watersheds and evaluated. Since salmon derived nutrients are important for wildlife species and riparian vegetation, improvements for wildlife breeding, food resources and thermal cover should be included in evaluation and assessment of benefits. It is likely that as nutrient input from naturally spawning salmon carcasses increases, density dependent limitations on production would decrease, expanding the productivity of watersheds to produce wild salmonids.

6. Acid precipitation from industrial pollution has caused the extinction of Atlantic salmon in rivers of Nova Scotia, Northeast U.S.A. rivers, and Norway among other European countries. As Asia industrializes using coal as the primary source of energy, an increase acid precipitation in the Northwest watersheds of North America and the North Pacific Ocean is a likely outcome. Establishing a baseline on acidification of Northwest rivers is important and a monitoring program is needed to provide a time series quantifiable data base on acid impacts on salmonid production.

“Local studies in the Kennebec River plume in the Gulf of Maine ( 9), the Chesapeake Bay ( 10), and the Manning River estuary in New South Wales, Australia ( 11), illustrate that freshwater inputs, pollutants, and soil erosion can acidify coastal waters at substantially higher rates than atmospheric CO2 alone.

“…the EPA highlighted the seriousness of acidification’s impacts on ocean life and encouraged states to list pH-impaired waters where data are available.” (Kelly 2011Science)

Amendment Proposal: The Council should request an assessment of the acidification ecological threat to salmonid production by the ISAB and request recommendations for a monitoring program of Northwest rivers including the Columbia River Basin.

7. By stating the gross number of salmon by species, most of which are of hatchery origin, as they pass mainstem and tributary dams, creates an impression that salmon are doing fine when in fact wild salmon recovery is a mere fraction of the gross abundance being reported. Monitoring the number of adult wild salmonids each year by species that enter the Columbia River basin would provide an important insight on the status of these species and their recovery. This measure would provide the public and the Council with a useful tracking document on the status of wild salmonids in the Columbia and the success or failure of the recovery investment. This information would be provided in updates of runs each year as fish pass dams and an annual report on the status of wild salmonid abundance by species in each watershed and by ESU. This information would be provided to the public. At this time the public is informed of the gross numbers of salmonids passing dams on the Columbia, but there is seldom any information on the size of the wild salmonid adult return. In addition, there is no annual report on the wild salmonids returning to subbasins and their relative abundance to total abundance. Consequently, the public is unaware of the status of wild salmonids and the benefits of recovery efforts in the Columbia River basin.

Amendment Proposal: The Council would work with federal, state and tribal agencies to develop a seasonal and annual wild salmon and steelhead abundance count at dams and in subbasins, developing a time series data base on wild salmonid abundance throughout the Columbia River basin.

8. Amendment Proposal: Each project investment should include funding that provides a quantitative assessment so that information is available to support adaptive management and to determine whether the project investment was a success or a failure. By doing this the Council would have more information from monitoring and evaluation to assess the benefits of project investments for fish and wildlife in the Columbia River basin. A monitoring and evaluation program for each project investment should be reviewed by an independent science panel to assure the Council, contractors and the public that the monitoring and evaluation is designed to provide quantitative assessments needed to evaluate the effect of the project. The monitoring, evaluation and research requirements should be stated for each project and included in the funding of each project.

9. Hatchery fish stray rates are based on an assumption rather than on biological criteria. Consequently, adopted hatchery stray rate standards are not based on an assessment of biological impact on wild salmonids in natal streams in terms of hybridization, loss of reproductive success in wild populations, ecological impacts such as competition, predation and predator attraction, the replacement of wild salmonids with hatchery produced fish, and harvest impacts on wild salmonids in fisheries targeted on hatchery produced fish. “Hatcheries are by their very nature are a compromise – a balancing of benefits and risks to the target populations, other populations, and the natural and human environment they affect.” (Paquet, HSRG 2011) Consequently, the Council and management agencies should explicitly describe the tradeoffs associated with hatchery production including stray rate impacts on native, wild salmonid productivity and recovery.

Natural stray rates range from less than 1 percent to 3 percent (Shapovalov and Taft 1954). The Council should ask its independent scientific panels to determine the biological basis for hatchery salmonid stray rates that protect and support recovery of wild salmonids in the Columbia River basin, taking into account low abundance of wild salmonids. Based on the recommendations of the science panels, agencies would adopt stray rate standards for hatchery salmonids that support rather than impede wild salmonid recovery.

“Most genes in natural populations probably have selection coefficients less than 5% and would thus be subject to loss if gene flow occurred at this level. The panel found no genetic justification for allowing gene flow from non-native fish at levels as high as 5%.” (Grant 1997) Since hatchery origin fish behavior, reproductive success and disease infection makes them different from wild origin salmonids even when derived from wild brood stock, hatchery fish can be considered non-native fish. Stray rates for hatchery origin fish should be managed so that stray rates are not larger than 1% for ESA-listed fish.

Proposed Amendment: The Council recognizes the risk to wild salmonid conservation and recovery from naturally spawning hatchery origin fish in each subbasin. The Council asks the appropriate independent science panel to determine the scientific basis for existing stray rate standards and propose a standard that is protective of ESA-listed wild salmonids in the Columbia River basin.

10. Proposed Amendment: The Council will evaluate the hatchery programs in the Columbia River basin to determine the cost to provide hatchery fish for harvest. In 2002 the Independent Economic Advisory Board (IEAB) completed phase I of their economic review of Columbia River hatchery programs. In that review they evaluated the cost to provide a harvest benefit, showing how much it costs to provide a harvested fish. Since these hatchery programs are for the purpose of providing mitigation for wild salmonid losses related to development of the Columbia River for hydroelectric purposes, the funding for these hatchery programs is paid for with public utility rates and taxes, so it is only appropriate for the public to know how much it costs to provide a benefit from the public investment in artificial propagation of salmonids. Even though the IEAB proposed to evaluate all salmonid hatcheries in the Columbia River basin, the Council rejected the proposal. Consequently, the cost to provide benefits from the hatchery program remains unevaluated and unknown. In addition, the cost related to hatchery impacts on wild salmon recovery should be included in this evaluation.

Hatchery Issues:

1. Hatchery Impacts on Wild Salmonids (ISAB)

“At the heart of reconciling the value of harvest opportunities versus sustaining natural populations are two unresolved questions:
1. If the scale of artificial production were curtailed would natural populations increase in abundance and productivity?
2. If artificial production continues at the current scale will natural productivity and diversity be eroded to the point that natural reproduction is no longer sustainable?

“A key question is whether the sustainability of ESA-listed species would be maintained or enhanced if large-scale artificial production were curtailed.”

Proposed Amendment: In each ESU, MPG, DPS, SMU designate at least one watershed that is managed for wild salmonids by excluding hatchery fish. The purpose is to monitor and evaluate the effect on the wild native salmonids and to provide non-hatchery reference watershed to compare with the watersheds that allow naturally spawning hatchery fish.

“If HSRG suggestions are not incorporated into the Program, an explanation of alternative options should be provided. Artificial production involves trade-offs with natural production, and these tradeoffs need to be explicitly described and acknowledged so that they can be adequately evaluated. Revising the existing artificial production standards (section 3.a.) to be consistent with the HSRG principles and recommendations would provide useful guidelines for reforming existing hatchery programs.

Proposed Amendment: Incorporate the recommendations of the HSRG and ISAB and for each hatchery program and proposed hatchery programs conduct a risk analysis of hatchery impacts and tradeoffs for wild salmonids. These trade-offs need to be explicitly described so that they can be evaluated. The trade-off evaluation would include impacts of stray hatchery fish on wild salmonids, harvest impacts to wild salmonids in fisheries targeted on hatchery fish, and impacts related to predation, predator attraction, and ecological impacts of competition among wild and hatchery fish for rearing space and on nutrient budgets in the mainstem, tributaries and estuary. The risk analysis and tradeoff analysis would be conducted every five years to incorporate advances in scientific information and technologies to conduct such evaluations.

Proposed Amendment: Evaluate whether the multiple objectives of recovering ESA-listed and non-listed wild salmonids to establish healthy natural populations, and mitigating harvest opportunity using artificial propagation are in conflict and can be reconciled. If they cannot be reconciled explicitly address any trade-offs for wild salmonid conservation and recovery.

Hatchery – Wild Salmonid Impact Recommendations

Proposed Amendment: Recognize and quantify the cumulative impacts of artificial production on natural production and ecosystem processes at population, subbasin, Columbia River basin and estuary scales.

Proposed Amendment: Treat integrated hatchery supplementation and harvest as distinct programs requiring their own standards of operation.

Proposed Amendment: Specify that segregated artificial production requires removal of hatchery fish before they reach spawning grounds to maintain the genetic and life history diversity of locally adapted populations.

Proposed Amendment: Establish empirical evidence concerning the effect of hatchery supplementation on rebuilding natural populations and improve integration between hatchery supplementation and habitat restoration programs. Evaluate limiting factors by life stage, including density dependent effects of hatchery produced fish on productivity, abundance, and diversity of natural origin salmonids.

Proposed Amendment: Develop quantitative objectives and basin-wide monitoring for hatchery production.

Proposed Amendment: Evaluate the fishery contribution of hatchery summer steelhead in the Columbia River and tributaries to determine whether mitigation hatcheries are providing a harvest benefit equal to wild summer steelhead. Determine the cost to produce a hatchery summer steelhead to the catch for each hatchery program. The Council should ask their scientific and economic advisory panels for an evaluation and to make recommendations to correct problems. The Council can then use these recommendations to develop changes in the hatchery practices that would cause the contribution of hatchery fish to the sport fishery to be equal to or better than that provided by wild steelhead. This evaluation and the corrective measures would be available for public review.

ODFW has determined that wild summer steelhead contribution to the sport fishery compared to hatchery summer steelhead contribution is 2 to 1 on the Deschutes River. Anecdotal information and observations indicate that wild steelhead contribute to the sport fishery at a higher rate than do hatchery steelhead in the mainstem Columbia River and Snake River fisheries. Since hatchery steelhead are produced in mitigation hatcheries to compensate for the reduced abundance of wild steelhead due to hydroelectric dam operations in the Columbia River basin, it is assumed that hatchery fish contribution to the sport fishery is equal to the wild steelhead. Information suggests that this assumption is wrong and the sport fishery is not getting the benefit from mitigation investments of public dollars that were promised.

Proposed Amendment: Evaluate the population status for wild salmon and steelhead in the Columbia River by species and run for each ESU and as a whole compared to the aggregate run composed of hatchery and wild fish to determine whether hatchery fish are replacing wild salmon and steelhead in the Columbia River basin. An annual report shall be provided to the public, media and agencies on the status of ESA-listed and non-listed wild salmon and steelhead in the Columbia River. This status report shall provide graphics that show the time series trend line for each wild salmon and steelhead ESU compared to and relative to hatchery salmon and steelhead. An annual accounting by species and ESU shall be conducted for the public and agency records that show the status of wild salmonids in each aggregate run.

Since 1980 upper Columbia wild spring chinook (ESA-listed endangered) are only 10% of the aggregate run. (ISAB 2013)

Snake River wild spring-summer chinook has declined to only 25% of the aggregate run. (ISAB 2013)

Upriver summer steelhead including fish from the upper, middle, and Snake River ESUs are protected as threatened, but the 10 year average for wild steelhead have remained at 15 to 40% of the aggregate run. Natural origin B-run steelhead in the Snake River are at risk of extinction. (ISAB 2013)

After 20 years of restoration, steelhead redd counts have declined by 68% in the John Day River and up to 30% of the natural spawners are strays from hatcheries.(ISAB 2013)
Natural origin coho salmon in the Columbia River have remained very low at 7% of the aggregate run. (ISAB 2013)

Total numbers of hatchery and natural origin salmon and steelhead returning to the Columbia River are not estimated annually to establish a time series data base available to the public through the media and for recovery evaluation.

Additional Hatchery Amendments:

1. Evaluate whether the multiple objectives of recovering ESA-listed species, establishing healthy natural populations, and mitigating harvest opportunity using artificial production can be reconciled and address any trade-offs explicitly.

2. Recognize and address the need to quantify the cumulative impacts of artificial production on natural production and ecosystem processes at population, subbasin, and basin scales.

3. Revise artificial production strategies to incorporate HSRG advice. Recognize and address the need to develop quantitative objectives for each artificial production program based on HSRG recommendations.

4. Treat integrated supplementation (for conservation) and harvest as distinct programs requiring their own standards of operation.

5. Specify that segregated artificial production requires removal of hatchery fish before they reach spawning grounds to maintain the genetic integrity of local populations.

6. Commit to establishing more empirical evidence concerning the effect of supplementation on rebuilding natural populations and improving integration between artificial production supplementation and habitat restoration programs. Address the importance of evaluating limiting factors by life-stage, including density-dependent effects of artificial production fish on production of natural-origin adult fish.

7. Adopt guidelines, benchmarks, and a basin-level experimental framework specifically for reintroduction of salmon and steelhead into watersheds from which they have been extirpated.

8. Develop quantitative goals and basin-scale monitoring for artificial production.

9. Proposed Amendment Hatchery Cost Accounting: The Power Planning and Conservation Council would direct the IEAB to complete phase II of the economic review of the Columbia River hatchery programs. This review would evaluate the benefits provided by these hatchery programs and the cost to provide those benefits. Phase II of the hatchery cost-benefit analysis is completed for each hatchery program in the Columbia River Basin and published on the Council’s web page.

In 2002 the Independent Economic Advisory Board provided the Council with phase I of hatchery costs. Phase I was limited to a few hatcheries from the mouth of the Columbia River to the upper Columbia and Snake rivers. One problem the IEAB encountered is the lack of available data by which to conduct an economic review of hatchery programs. In phase II the IEAB proposed to conduct cost benefit analysis of all hatchery programs in the Columbia River basin, however, they were not given permission to complete this review.

Economic evaluations performed by the management agencies are typically confined to showing benefits of the hatchery program but do not display the costs involved in providing those benefits. Phase I of the IEAB reported on the benefits and the costs to provide those benefits through hatchery investments. Since hatcheries are paid for with public funds it is only a matter of time before the approach taken by the IEAB will become a standard means of evaluating this public investment. The Council should provide the leadership that is needed to do a competent cost-benefit analysis of the Columbia River hatchery program so that the public investment is given a full accounting.

Phase I of the IEAB evaluated the cost to produce a hatchery fish that is harvested. Since Columbia River hatchery programs are designed to provide harvest mitigation for development of the river, a cost accounting for replacing wild salmonid production with hatchery salmonids is appropriate and necessary for a full accounting of the public investment. In addition, the hatchery program also has an impact on public investments in habitat restoration and expenditures for recovery of wild salmon and steelhead. Since hatchery fish have lower survival rates, and cause reduced reproductive success of wild salmonids through interbreeding and ecological impacts, the investment in habitat restoration provides lower than expected benefits and impacts on recovery of threatened and endangered species increases the cost while impeding recovery. Determining the cost to produce a hatchery fish that is harvested is an essential element in hatchery cost accounting that is typically avoided by agency economic studies.

Harvest Management:

Harvest could be a major factor constraining the program goals, vision, and biological performance measures. Escapement objectives by species and race for each watershed are necessary to fully seed the habitat. An estimate of habitat carrying capacity by species and race is required to define escapement objectives. Refinement of escapement and habitat capacity can be refined as quantitative information is accumulated in each watershed. Harvest management plans have not been scientifically reviewed and analyzed to assess compatibility with ESA-listed salmon and steelhead recovery. (ISAB 2013)

Proposed Amendment: Harvest plans need to be scientifically justified and consistent with subbasin and other plans to establish sustainable, viable population objectives that also include utilization goals for each salmon and steelhead population in Columbia River subbasins.

Proposed Amendment for Protected Areas: The Protected Areas program is an important mitigation component for not only rebuilding fish and wildlife populations that have been damaged by hydroelectric development throughout Idaho, Montana, Oregon and Washington, but also for offsetting larger ecosystem impacts. The Southern Resident Killer Whales (SRKW) consists of less than 90 orcas that reside in the Salish Sea and are currently endangered. One of the greatest threats to the SRKW is the declining availability of Chinook and other salmonids. The SRKW annual diet requires approximately 800,000 Chinook salmon annually. This represents the entire annual return of Columbia River basin Chinook. Clearly the SRKW depend upon other Chinook populations in addition to Columbia River basin fish. This serves as an excellent example of the interdependence of non-Columbia River basin ecosystems and why it is imperative that the Protected Area concept not be weakened.

Hydropower developers continue to seek permits throughout the region to create limited additional capacity (where no shortage exists); however, the entire energy picture is in a multi-decade period of transition. Small scale, localized power production using solar, wind and other technologies, combined with conservation and lowered costs due to mass market adoption of these technologies, produce an energy future that is difficult to describe with any precision, but can reasonably be expected to be significantly different than the past. As the long term impacts of hydroelectric projects cannot be justified by short term benefits, a strong Protected Areas program remains critically important as hydropower developers continue to pursue projects in these areas.

As a result, we strongly encourage the Council to deny any recommendation that would weaken the program. In addition, we recommend that the Council prohibit exemptions in Protected Areas, as in the 2009 Fish and Wildlife Program. Protected Area’s cover just 20% of the Northwest’s river and stream mileage. Denying any attempt at an exemption from a Protected Area meets the Council’s responsibilities to maximize policy and program benefits and minimize process costs.

Grant, S.W. (editor). 1997. Genetic effects of straying of non-native hatchery fish into natural populations: Proceedings of the workshop. U.S. Department of Commerce, NOAA Tech. Memo. NMFS-NWFSC-30. 130p.

Gresh, Ted, Jim Lichatowich, and Peter Schoonmaker. 2000. An Estimation of Historic and Current Levels of Salmon Production in the Northwest Pacific Ecosystem: Evidence of a Nutrient Deficit in the Freshwater Systems of the Pacific Northwest. American Fisheries Society. Fisheries. Vol. 25. No. 1.

Lichatowich, Jim and Richard Williams 2009. Failures to incorporate science into fishery management and recovery programs: Lessons from the Columbia River. Am. Fish. Soc. Symposium 70: 1005-1019.

Kelly, R.P., M. M. Foley, W. S. Fishery, R. A. Feely, B. S. Halpern, and G. G. Waldbusser. 2011. Mitigating local causes of ocean acidification with existing laws. Policy Forum. Science. 332: 1036-1037.

Oregon Fish Commission. 1933. Biennial report of the Fish Commission of the State of Oregon to the Governor and the Thirty-seventh Legislative As¬sembly, 1933. State of Oregon, Salem, Oregon.

Paquet, P. J., T. Flagg, A. Appleby, J. Barr, L. Blankenship, D. Campton, M. Delarm, T. Evelyn, D. Fast, J. Gislason, P. Kline, D. Maynard, L. Mobrand, G. Nandor, P. Seidel & S. Smith (2011): Hatcheries, Conservation, and Sustainable Fisheries—Achieving Multiple Goals: Results of the Hatchery Scientific Review Group’s Columbia River Basin Review, Fisheries, 36:11, 547-561

National Research Council (NRC). 1996. Upstream: salmon and society in the Pacific Northwest. Re¬port of the Committee on Protection and Manage¬ment of Pacific Northwest anadromous salmonids for the National Research Council of the National Academy of Sciences. National Academy Press, Washington, D.C.

Scheuerell, M.D., P.S. Levin, R.W. Zabel, J.G. Williams, and B.L. Sanderson. 2005. A new perspective on the importance of marine-derived nutrients to threatened stocks of Pacific salmon (Oncorhynchus spp.). Canadian Journal of Fisheries and Aquatic Sciences, 62: 961-964.

Snake River Salmon Recovery Team. 1994. Final rec¬ommendations to the National Marine Fisheries Service. National Marine Fisheries Service, Seattle.

Washington State Senate (WSS). 1943. Report on the problems affecting the fisheries of the Columbia River. Fisheries Interim Investigating Committee. Olympia, Washington.

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